A two-number check turns that concern into a margin figure, a cash figure and a named action. It is designed for commercial, finance, procurement and operations leaders in UK businesses that use PET resin in bottles, food packaging, textiles or other products.
What SG0094 covers
The Trade Remedies Authority (TRA) opened case SG0094 on 5 August 2026. It is the authority's first new safeguard investigation since it was established following the UK's exit from the EU. The case covers PET resin under commodity codes 390761 and 390769. The TRA says total UK PET imports were worth more than £300 million in 2025.
A safeguard is a temporary response to an unforeseen rise in imports that causes serious injury to UK producers. The investigation will examine import data from 1 January 2021 to 31 December 2025 and consider the position of the UK producer that applied for protection.
SG0094 remains an active investigation. A future measure could take the form of an additional import duty or a tariff-rate quota, where a higher duty applies after a volume limit is reached. The TRA investigates the legal conditions, conducts the economic interest test and may recommend a measure. It advises the Secretary of State on whether the measure is in the UK's economic interest. The Secretary of State decides whether to accept or reject the recommendation. The outcome, form, rate and start date are still open.
The current scope gives a company three facts to establish before running a financial scenario:
- Confirm whether the purchased material falls within commodity code 390761 or 390769.
- Identify the legal entity that acts as importer of record and would pay any additional border cost.
- Record the tonnes expected to clear customs during the planning period.
An uncertain answer to either of the first two questions stops the calculation. Confirm the product classification and importing position first.
How a border cost reaches the business
The importer pays a border cost. The commercial effect then depends on the supply contract, the customer contract and the timing of each payment.
A supplier may absorb part of the cost, issue a credit or pass it through in full. A customer contract may allow an immediate price change, a delayed review or recovery limited to specified material indices. Each position produces a different result.
This creates two exposures:
- Unrecoverable margin exposure is the scenario cost left after supplier credit and customer recovery for sales made during the planning period.
- Peak cash exposure is the highest amount the company funds before supplier credits and customer recovery are received.
These figures answer different management questions. Margin exposure belongs with the commercial owner of price and contract terms. Peak cash exposure belongs with finance and procurement because a recoverable cost can still create a funding gap.
Calculate the two numbers
Choose a planning period that matches a real decision, such as the next 90 days or the time until the next customer price review. Set a landed-cost scenario per tonne. Record it as a company planning assumption while the investigation remains open.
Use these calculations:
Scenario cost = in-scope tonnes × planning uplift per tonne
Unrecoverable margin exposure = max(£0, scenario cost − supplier credit − customer recovery attributable to the same sales period)
For peak cash exposure, place the additional supplier payment, supplier credit and customer recovery on a simple weekly cash timeline. The largest funding requirement is the output. Record £0 when the timeline remains cash-positive.
Set two company limits before viewing the result:
- the largest margin loss the business will accept for the selected period;
- the largest temporary cash requirement it will fund without intervention.
Pre-set limits prevent the result from being rationalised after the calculation.
A worked 90-day scenario
Consider a converter expecting 600 tonnes of in-scope PET during the next 90 days. It selects a planning uplift of £100 per tonne. This is an illustrative assumption for the calculation.
The scenario cost is £60,000. Customer contracts allow £24,000 to be recovered for the same sales period, while supplier credit is £0. Unrecoverable margin exposure is therefore £36,000.
Customer recovery arrives after the importer pays the additional cost. The weekly cash timeline reaches a peak funding requirement of £60,000 before the £24,000 recovery is collected.
The company had set a £25,000 margin-loss limit and a £50,000 peak-cash limit. Both are crossed, so the result routes to a joint response. The commercial owner reviews price and contract action. Finance and procurement agree the funding, order timing and supplier action.
A different contract could produce £10,000 of margin exposure and £60,000 of peak cash exposure. That result routes to finance and procurement. The customer eventually covers most of the cost, while the timing still exceeds the company's cash limit.
Assign the next action
Use one routing rule for the completed check. A limit is crossed only when exposure is greater than the approved limit. Equality remains within the limit. The five conditions are mutually exclusive:
| Result | Owner | Next action |
|---|---|---|
| Product scope or importer position is unclear | Trade, customs or compliance owner | Confirm scope before financial work continues |
| Margin exposure is above its limit and cash exposure is above its limit | Commercial, finance and procurement | Run a joint response, with the next contractual and cash decisions recorded together |
| Margin exposure is above its limit and cash exposure is at or below its limit | Commercial owner | Identify the affected customer terms and prepare the permitted price or contract action |
| Margin exposure is at or below its limit and cash exposure is above its limit | Finance and procurement | Agree funding, purchase timing and supplier action |
| Both exposures are at or below their limits | Named monitoring owner | Rerun the check at the next official case milestone or material contract change |
The TRA's economic interest test considers the effect of a possible measure on wider UK industries and consumers. Its published process can use questionnaires, business surveys and written submissions. Verified downstream evidence can inform the investigation. A completed company calculation can also support internal decisions while the public process continues.
The two-number PET exposure check
Complete one record for each material and contract set that could produce a different result.
- Scope: commodity code, material description, supplier, origin and importer of record.
- Period: start date, end date and expected in-scope tonnes.
- Scenario: company-set landed-cost uplift per tonne.
- Recovery: supplier credit and customer recovery attributable to sales in the period.
- Timing: dates when the additional cost is paid and each recovery is received.
- Limits: approved margin-loss limit and peak-cash limit.
- Outputs: unrecoverable margin exposure and peak cash exposure.
- Route: confirm scope, commercial action, finance and procurement action, joint response, or monitor.
- Control: named owner, next action, due date and official milestone that triggers a rerun.
Stop when the route, owner and next action are recorded. Repeat the check when the TRA publishes a material case update, when a contract changes or when purchasing volumes move enough to alter either result.
Sources
- TRA announcement opening the PET safeguard investigation
- SG0094 public file
- TRA investigation process
- TRA guidance on the economic interest test
- Taxation (Cross-border Trade) Act 2018, Schedule 5
This article was produced using AI-assisted research and drafting, with source checking and editorial quality controls before staging.
