Sector guides

TBBPA and halogenated phenols from China

Halogenated, sulphonated, nitrated or nitrosated phenol derivatives from China have a 4% UK duty rate with no anti-dumping, but TBBPA, bisphenol AF, 4-chlorophenol and several fluorophenols are suspended to 0% until 2028, and residual lines are 0% for listed pharmaceutical substances. Pentachlorophenol is banned as a persistent organic pollutant.

Written by Bono Xu, Founder, Cambridge China Bridge · 4 min read · Updated 2026-09-27

TBBPA flame retardant, bisphenol AF, chlorophenols, fluorophenols and nitrophenols from China: 4% UK duty with 0% suspensions. POPs and REACH explained.

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4% duty with suspensions

Read from the UK Trade Tariff on 27 September 2026, heading 2908 covers halogenated, sulphonated, nitrated or nitrosated derivatives of phenols or phenol-alcohols. All 8 lines carried 4% on goods from China, with no anti-dumping measure. Suspensions to 31 December 2028 give 0% to 4,4'-(perfluoroisopropylidene)diphenol (bisphenol AF) and 4-chlorophenol on their own lines, and on the residual halogenated line to named substances only: tetrabromobisphenol A (TBBPA), pentafluorophenol, 3,4,5-trifluorophenol and 4-fluorophenol. 2,3,6-Trifluorophenol, pentachlorophenol, dinoseb and DNOC pay 4%.

The two residual lines (2908 19 00 90 and 2908 99 00 00) show 0% under additional code 2500 for pharmaceutical substances listed in Tables 10 to 13 of the customs reliefs reference document and 4% under code 2501 for others. Phenol and bisphenol A themselves are heading 2907 (see our phenol and bisphenol A guide); confirm the commodity code.

UK duty on phenol derivatives of Chinese origin, read from the UK Trade Tariff on 27 September 2026.
GoodsCommodity codeDutyAnti-dumping duty on China
Pentachlorophenol (banned as a POP)2908 11 00 004%None
Bisphenol AF2908 19 00 204% (0% suspension to 31 Dec 2028)None
4-Chlorophenol2908 19 00 304% (0% suspension to 31 Dec 2028)None
Other halogenated derivatives, including TBBPA2908 19 00 904% (0% for TBBPA and named fluorophenols to 31 Dec 2028; 0% listed pharmaceuticals)None
Dinoseb and its salts2908 91 00 004%None
Other nitrated or sulphonated derivatives2908 99 00 000% listed pharmaceuticals; 4% otherNone

POPs, pesticides and REACH

Pentachlorophenol and its salts and esters are listed in Annex I of retained Regulation (EU) 2019/1021 on persistent organic pollutants, so they cannot be placed on the market, and the entry sets a 5 mg/kg limit for unintentional traces in substances, mixtures and articles. Dinoseb and DNOC are old pesticide actives; plant protection products may only be placed on the GB market with authorisation under retained Regulation (EC) No 1107/2009.

A GB importer of one tonne or more a year of TBBPA or another substance must register it under UK REACH, retained Regulation (EC) No 1907/2006, or use an only representative, and each shipment needs a safety data sheet.

Specifying TBBPA and phenol derivatives

Specify the CAS number, assay, bromine or halogen content, melting range, colour, impurity limits (for TBBPA, ionic bromide and lower-brominated phenols), particle size, packing, and a certificate of analysis per lot.

Worked duty example

For a made-up shipment of 20 tonnes of TBBPA flame retardant under 2908 19 00 90, add the £3,000 of freight and insurance to the £60,000 free-on-board price and customs sees £63,000. Duty on TBBPA is zero, leaving import VAT of £12,600, 20% of the customs value. For a VAT-registered buyer that is a cash-flow cost rather than a lasting one. That assumes the named-substance suspension is claimed; without it the 4% rate would add £2,520. The duty and VAT guide walks through the calculation.

Inspection checklist

Documents: check the certificate of analysis, the basis for any 0% claim and the UK REACH route.

Laboratory: test assay, halogen content, melting point and key impurities on an independent sample.

Packing: check bags or drums are sealed, labelled with GB CLP pictograms and lot numbers, and protected from moisture and dust release.

What goes wrong

Phenol derivative orders fail on purity, classification and restricted traces. Assay or colour misses the specification, a product is declared on a line whose suspension does not name it, and pentachlorophenol traces above the POPs limit appear in chlorophenol products.

Test independently, check the tariff basis for each substance, and ask for POPs trace testing on chlorinated products. See our quality inspection guide.

Cambridge China Bridge sources TBBPA and phenol derivatives for UK resin, laminate and chemical makers, checking the producer's laboratory and quality records first. See factory verification.

Frequently asked questions

What is the UK import duty on TBBPA from China?

Read from the UK Trade Tariff on 27 September 2026, TBBPA under 2908 19 00 90 is 4%, suspended to 0% until 31 December 2028.

Is pentachlorophenol allowed?

No. It is listed in Annex I of the persistent organic pollutants regulation.

Why do some lines show 0% and 4%?

Listed pharmaceutical substances are 0% under additional code 2500; other goods pay 4%.

Do I need UK REACH registration for TBBPA?

Yes, above one tonne a year, directly or through an only representative.

Sources

  1. UK Trade Tariff — commodity codes and duty
  2. Regulation (EU) 2019/1021 Annex I (POPs)
  3. UK REACH: retained Regulation (EC) No 1907/2006

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