By Nick Lung    Photo：CANVA

I. Legal Basis and Basel Convention Regulations

Although polyvinylidene fluoride (PVDF) is a fluorinated polymer plastic, according to Annex IX (entry B3011) of the 2021 Basel Convention, pure, uncontaminated single PVDF waste, if intended for environmentally friendly recycling, is not subject to the PIC procedure.

However, if PVDF is mixed with other plastics, contaminants, or is a mixed waste, it may fall under the restrictions of Annexes II (Y48) or VIII (A3210), requiring Prior Informed Consent (PIC) from the exporting, importing, and transit countries. Failure to do so constitutes illegal cross-border waste trade.

II. Hazard Assessment and Transport Classification

Many Safety Data Sheets (SDSs) for PVDF products indicate that, if the resin is in a solid, pure state, it is not classified as a hazardous material under transport regulations such as IATA, ICAO, ADR, and IMDG, and does not require a UN number or hazard label.

Therefore, before making actual transport arrangements, it is important to confirm that Section 14 of the SDS clearly identifies the transport classification. If the product is additive-free, non-liquid, or does not contain flammable solvents, the hazardous material classification procedure is generally unnecessary and non-compliant.

III. Potential Impact of EU PFAS Restrictions

The EU recently announced plans to publish a horizontal restriction on PFAS (permanent substances) in 2025, which is expected to fully cover fluorinated polymers, including PVDF.

If the final regulations are adopted, PVDF membranes and related products may face sales suspensions or strict usage restrictions, unless they are used in critical industrial applications and have been granted limited temporary exemptions.

Exporting companies should assess the impact as soon as possible, prepare alternative solutions, or apply for appropriate exemptions.

IV. Operational Practices and Customs Clearance Recommendations

Packaging and Labeling: Use moisture-proof and contamination-proof sealed containers and ship individually. Labels must clearly indicate the product name (PVDF), batch number, intended use (e.g., pellets, sheets, etc.), and indicate that it is non-hazardous.

Document Preparation: Include a complete SDS (including the section on transport classification as hazardous materials) and a certificate of origin with the shipment. If exporting scrap, include proof of recycling methods and PIC treatment.

HS Code and Customs Procedures: PVDF is generally classified under HS 3904, a sub-category for fluorinated polymer plastics, such as 3904.69 or 3904.90. Confirm the correct code and declare according to the customs requirements of the destination country.

Special Declaration for the EU Market: If the destination is an EU country, it is recommended to prepare a PFAS safety assessment or supply chain declaration to increase resilience to future regulatory changes.

Always confirm whether the PVDF being shipped is "pure, non-hazardous" or "mixed/waste" to determine whether it is subject to the Basel Convention's PIC procedure. If it is pure solid, it can be transported as normal cargo, requiring only the preparation of an SDS, the correct HS code, and labeling. For EU markets, it is strongly recommended to plan for potential PFAS restrictions in advance and prepare the necessary documentation to improve compliance and customs clearance efficiency.

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