US LLDPE imports need a cash exposure file while the duty is unresolved.

Registration gives Finance a population to examine.

Linear low-density polyethylene, usually shortened to LLDPE, is the plastic covered by the UK's AD0091 anti-dumping investigation into imports originating from the United States. The Trade Remedies Authority's public file showed the investigation as active when checked on 8 October 2026. AD0091 public case.

HM Revenue and Customs has registered covered imports since 2 July 2026. Registration continues until the investigation terminates. The notice lists the commodity codes and the additional codes used to identify covered and excluded goods. Establish the product and origin facts behind each declaration before deciding that it belongs in the exposure file. Trade remedies notice 2026/19.

The notice provides for a conditional retrospective duty if a definitive remedy is implemented. It describes a possible date up to 90 days before a provisional remedy, with the charged level determined by the definitive remedy. Those conditions require a later legal decision. Registration establishes records to examine; it supplies no rate or probability to put into a forecast.

A finance team can still calculate what selected rates would do to its cash position. The resulting figure is a planning scenario. An accounting provision, legal liability or duty forecast needs its own evidential basis.

Keep the importer and recovery evidence attached to the value.

Start with the declaration reference, import date, product specification, origin evidence, commodity and additional codes, customs value and representation arrangement. Reconcile the values to the underlying declarations so a purchase ledger total cannot silently replace the customs-value base.

Keep registered imports separate from future commitments. A placed purchase order gives management something to test, but its projected value and import date have a different status from an accepted declaration. Show both populations and state which one each scenario includes.

The person bearing a later customs debt can depend on how the declaration was made. A supplier-paid invoice or an intermediary's involvement does not settle that question. Ask the customs lead to identify the declarant, the person represented and the relevant arrangement, using HMRC's debtor guidance. Who is liable for customs debts.

Recovery from a supplier or customer also needs evidence. Finance should record the contractual basis, the amount recoverable and when cash can reasonably arrive, with specialist confirmation where interpretation is needed. Use zero recovery in the main cash scenario while those conditions remain unverified. Keep a potential claim in a separate recovery action so it remains visible without reducing an amount prematurely.

HMRC's general debt process includes an opportunity to respond before a debt decision. Keep the declarations and supporting records retrievable for that process. This does not predict whether AD0091 will produce an assessment. HMRC customs-debt guidance.

Test the total exposure against a stated cash limit.

The Finance Director should choose the planning population, hypothetical rates, payment date and cash tolerance before calculating the result. Define the tolerance as the maximum scenario amount the company can absorb on that date without an additional cash action. Record how it was approved.

For each selected rate, multiply the confirmed in-scope customs value by that rate. Subtract only verified recovery available by the assumed payment date. Display later verified recovery separately because it may reduce eventual cost while leaving the immediate cash requirement intact.

Aggregate every included declaration or commitment once. The tolerance applies to that total. Several individually small amounts can exceed the available headroom when paid together.

Apply these rules in order:

1. Send unresolved product, origin, value or debtor evidence to the customs lead. Record the specific question, evidence needed and review date. Show that population separately; exclude it from a claim that the total is complete.
2. Remove a record from the covered population only when the exclusion is supported and retained. New product or origin facts reopen the check.
3. Compare each complete scenario total with the agreed cash tolerance. A total at or below the tolerance remains on the monitoring route. A higher total requires a Finance headroom action before the company relies on that cash position.

If evidence remains unresolved, the confirmed total is a partial calculation. Finance should assess the potential scale of the unresolved population immediately and obtain the missing evidence before closing the portfolio decision.

Recovery timing can change the response.

This illustration uses invented values, rates and company limits. Two confirmed registered-import batches have customs values of £400,000 and £300,000. Finance tests 10% and 20%, assumes the same payment date for both batches and sets a £60,000 cash tolerance. None of these rates is an AD0091 forecast.

At 10%, the two individual gross amounts are £40,000 and £30,000. Each sits below £60,000, while their £70,000 total exceeds it. Applying the tolerance to the portfolio catches the cash requirement that separate row decisions would miss.

If the verified £20,000 arrives after the assumed duty payment, the immediate exposure returns to £70,000 and the headroom action remains. The same recovery could still reduce the eventual cost. Reordering the two batches changes neither the total nor the route.

Maintain one exposure record and a separate recovery action.

Finance owns the record. The customs lead owns unresolved declaration evidence; the commercial or contract owner owns the recovery action. Use the following fields for each portfolio review.

A headroom action closes only when Finance records how the scenario amount will be funded or the inputs have changed enough to pass the tolerance. A sourcing change needs confirmed product qualification, availability and total cost before it can support that closure. Keep the exposure open until the relevant evidence and approval exist.