PVC scrap itself is not directly regulated for phthalate content at the border, but if the scrap is destined for use in articles subject to CPSC jurisdiction — such as children's products or toys — the downstream recycled compound must comply with applicable phthalate restrictions. Importers and recyclers should assess end-use applications and test recycled PVC compounds accordingly before incorporating them into regulated consumer products.

PVC scrap and parings that retain their waste character classify under 3915300000. Once PVC has been cleaned, remelted, and pelletized to a commercial specification — with defined color, plasticizer content, and physical properties — CBP may classify it as a primary-form PVC polymer under heading 3904 rather than as scrap. The distinction turns on whether the material has been restored to a usable primary form, so product specifications and processing documentation are critical.