Introduction
The Plastic Packaging Tax (PPT) has applied since 2022, and from 1 April 2025 charges £223.69 per tonne on plastic packaging with less than 30% recycled content. The tax rises annually in line with the Consumer Price Index.
UK manufacturers and importers of plastic packaging (filled or unfilled) are directly liable, though costs are often passed through the supply chain. A de minimis applies for businesses manufacturing or importing under 10 tonnes of plastic packaging in a 12‑month period, but HMRC still expects you to keep records to evidence why the tax doesn’t apply, even if you are under the threshold to register.
This article walks you through the steps needed to ensure PPT compliance, with links to detailed guidance on gov.uk that we strongly recommend reviewing.
1. Identify which of your plastic packaging is subject to the PPT
PPT is charged on each individual packaging component, not the finished item, so a bottle and its cap are taxed individually. A number of general exemptions and exclusions apply, outlined below.
Packaging exempt from PPT:
- Multiple-material packaging where plastic is not the predominant material by weight.
- Exported plastic packaging.
- Packaging used for the immediate packaging of licensed human medicine. This packaging still counts towards the 10 tonne de minimis.
- Packaging permanently recorded as set aside for non-packaging use. This packaging still counts towards the 10 tonne de minimis.
- Packaging used as transport packaging to import multiple grouped sales units safely into the UK (tertiary packaging).
- Packaging used in aircraft, ship and rail goods stores.
Packaging excluded from PPT:
- Packaging used in the long-term storage of goods.
- Packaging that is an integral part of the good.
- Reused packaging for the presentation of goods.
There are detailed examples of packaging in or out of scope, available on the link below.
Check if your plastic packaging is in scope of the Plastic Packaging Tax on gov.uk
2. Identify if you are liable for the PPT
If any of your plastic packaging is in scope for PPT, you need to calculate its weight accurately to determine liability and reporting requirements.
Where multiple UK businesses are involved in manufacturing, the liable party is the one making the last substantial modification before pack/filling. The importer is the one on whose behalf the packaging enters the UK, or the first to commercially exploit it.
Work out the weight of packaging for Plastic Packaging Tax on gov.uk
Check when you must register for Plastic Packaging Tax on gov.uk
3. Register for the PPT
There are two tests to check if you need to register - you must look back over the last 12 months and look forward to the next 30 days.
You must register for PPT if you import or manufacture more than 10 tonnes of plastic packaging in any rolling 12‑month period. You also must register if you expect to exceed the 10 tonnes threshold in the next 30 days - in which case liability begins from the day you expect to cross the threshold.
How to apply the register tests on gov.uk
You must register for PPT within 30 days of becoming liable, and the tax applies to all components from the date you became liable.
If you meet either threshold test, keep clear records and evidence showing how you determined your liability. If you don’t meet the tests, you should keep evidence proving you manufacture or import under 10 tonnes of finished plastic packaging per year.
To register, you may need to provide the following information:
- Your business type
- Your businesses address and contact details
- The date your business became liable for Plastic Packaging Tax
- An estimate of how much finished plastic packaging you expect to manufacture or import in the next 12 months
- A customer reference number, which could be your:
- Corporation Tax Unique Tax Reference
- Self Assessment Unique Tax Reference
- Company Reference number
- Charity Registration number
- National Insurance number
- Temporary National Insurance number
Register for the PPT on gov.uk
4. Work out the recycled content percentage of your plastic packaging
To calculate recycled content, divide the weight of recycled plastic by the total plastic weight in the component, then multiply by 100.
You can determine recycled and non‑recycled weights using either the material‑inputs method or a verified specification (see link below). Records must be kept to demonstrate this, and due diligence carried out if using specifications.
How to calculate the recycled plastic content of plastic packaging components on gov.uk
HMRC guidance for a mass balance approach
HMRC has published guidance on the use of a mass balance approach for Plastic Packaging Tax (PPT) from 1 April 2027. This will allow chemically recycled plastic to count towards the 30% recycled content threshold used to determine whether PPT is payable.
Use of mass balance accounting will be optional. However, chemically recycled plastic will only be treated as recycled content for PPT purposes where it is certified under an approved mass balance system. HMRC has also published minimum certification requirements covering certification schemes, certification bodies and businesses across the supply chain.
Businesses participating in a certified supply chain will need to maintain appropriate records, certificates and attribution declarations to support recycled content claims.
HMRC has also confirmed that reprocessed pre-consumer plastic waste will no longer count as recycled content for PPT purposes from 1 April 2027.
Find out more: Preparing to use a mass balance approach for Plastic Packaging Tax - GOV.UK
5. Work out the weight of your packaging
To work out how much PPT is due, you must know the:
- Weight of the packaging component recorded in metric values and shown in kilograms on your return
- Percentage of recycled plastic content
Where waste remains attached to the finished component, you can deduct the weight of the waste from the total but keep evidence and records of this process.
To work out the overall weight of a component, you can use a:
- Individual component method
- Sample component method
- Material inputs method
- Verified specification method - keeping appropriate records and carrying out due diligence on the specifications provided.
- Bulk weighing method
Records must be kept demonstrating the method used. Details of each method can be found in the link below.
How to work out the weight of packaging for the PPT on gov.uk
6. Keep records and accounts for the PPT
You must keep accounts showing how you calculated the figures on your PPT return, along with evidence to support them. These records must be kept for at least six years and recorded in tonnes, kilograms and grams.
Accounts - You must keep accounts showing how you’ve calculated each entry on your quarterly PPT return. Where relevant, these must include:
- A breakdown of the weight of plastic packaging components finished or imported in each period
- Weights of plastic packaging exported in the period on which the tax was deferred
- A breakdown of the weight of any plastic packaging for which a credit is claimed if the packaging has been exported or converted into new packaging components
- Any adjustments or corrections made to previous accounting periods
You must keep accounts by reference to each ‘product line’ that you produce or import.
Records - Your records must be kept by reference to each product line and show:
- Evidence of any PPT exemptions
- The recycled plastic content, if 30% or more of the plastic used in the component is recycled
Packaging containing over 30% recycled content - If you claim this exemption, you must have records that:
- Show how you worked out the percentage of recycled plastic
- Provide sufficient supporting evidence that recycled plastic was used
- Show which dates the evidence relates to
- Show which plastic packaging component the percentage relates to, including product lines or production runs
- Are an accurate reflection of the proportion of recycled plastic contained in the output materials of that recycling process
- Confirm the source of the recycled plastic
For example, suitable evidence could include a product specification confirming the recycled content, along with records of any due‑diligence checks you’ve carried out.
Exporting plastic packaging - To defer payment on packaging you intend to export, you must keep records that are a document that:
- Is used for any other tax or duty, or
- Which clearly identifies the components to be exported, such as a sales contract or order
The records must be dated at or before the time of import/production, include details that identify the plastic packaging, and include the weight of packaging you intend to export.
To claim a credit on packaging that has been exported, you must keep evidence showing:
- The reason for the claim (either the components were exported or converted into new components)
- The accounting period which you first held this evidence
- Details of the tax you paid on the components, including the amount of tax you paid, the date you paid the tax and how you paid the tax
The evidence must show that the components have been exported, and must be either:
- A document for any other tax or duty
- Another document, such as an export invoice
Record keeping and accounts for the PPT on gov.uk
7. Obtain acceptable evidence for the PPT
To show that imported plastic packaging contains at least 30% recycled plastic, you must either:
- Provide evidence from the manufacturer of the plastic packaging
- Prove that you (or a competent third-party) have a robust supply chain audit that can provide this evidence
HMRC have a non-exhaustive list of evidence that will be accepted:
- Product specifications may be used to prove the proportion of recycled plastic, the weight of plastic packaging, that the packaging is plastic, and if the packaging is exempt from the PPT.
- Contracts may be used to demonstrate the quantity of plastic packaging, the proportion of recycled plastic, the weight of packaging, if the packaging is plastic, and if the packaging is exempt from the PPT.
- Product certificates and certificates of conformity may be used to prove the proportion of recycled plastic.
- Business accounting systems may be used to show the plastic recycled through the manufacturing process.
- Accreditations and international standards could help to show the proportion and source of recycled plastic, the weight of plastic packaging, if the packaging is plastic, and if the packaging is exempt from the PPT.
- Quality assurance audits can be used to demonstrate the level of recycled plastic, the weight of plastic packaging, if the packaging is plastic, and if the packaging is exempt from the PPT.
- Sales and purchase invoices may be used to demonstrate the quantity of plastic packaging supplied, the weight of any waste, the recycled plastic feedstock, the date of sale, and the tax paid.
Valid evidence for plastic packaging that you intend to export or have exported includes:
- Export declarations
- An invoice or packing list that identifies the goods being exported
- A transport document (such as a bill of lading, airway bill or road consignment note)
- Certified documents by the goods carrier showing the goods were loaded and shipped
- Commercial documents, such as a delivery note or invoice, signed by the consignee certifying the goods were received in a country outside of the UK
- A document authenticated by a customs authority, certifying the goods have left the UK
Documents that can be used as evidence for the PPT on gov.uk
8. Make PPT due diligence checks
Carry out PPT due‑diligence checks if you manufacture, import or purchase plastic packaging to reduce the risk of unpaid tax in your supply chain and avoid joint or several liability. HMRC hasn’t defined specific checks, but expects those that are ‘relevant, reasonable and proportionate’, and completed at least annually.
Examples include requesting confirmation that PPT has been paid, obtaining product specifications or manually weighing packaging if it has less than 30% recycled plastic. When recycled content exceeds 30% check prices are in line with current market conditions or obtain copies of certification or audits.
How to make due diligence checks for the PPT on gov.uk
9. Submit your PPT returns
If you’re liable for PPT, you must submit quarterly returns aligned to the financial year, and pay the tax no later than the last day of the succeeding month of the quarter in question.
You will need to include on your return:
- The total weight of plastic packaging manufactured in the accounting period in kilograms, including any packaging that was previously intended for export or has not been exported within the 12-month deferral period.
- The total weight of plastic packaging imported into the UK in kilograms, including any packaging that was previously intended for export or has not been exported within the 12-month deferral period.
- The total weight of finished goods not subject to the PPT, for instance, if they contain over 30% recycled content. Exemptions will need to be further reported on in the tax return, more details of which can be found in the link below.
- The total weight of plastic packaging that has been exported, or is due for export, and the value of credits being claimed in pounds sterling.
- The total weight of chargeable plastic packaging components, less deductions. The PPT due will then be automatically calculated. You must also declare that the above information given is true.
Some packaging exempt from the PPT does not need to be included on returns, detailed in the link below.
Completing your PPT return on gov.uk
10. Read the full government PPT guidance
We strongly advise you to be familiar with the full official PPT guidance on gov.uk, using the link below.
Read the collection of gov.uk guidance you should follow for the PPT
11. Reduce your PPT liabilities
We can help ensure your packaging data is accurate and detailed enough for PPT reporting and deeper analysis. We can also model your PPT costs, highlight key cost drivers and run scenario modelling to identify opportunities to reduce your PPT liability and strengthen your environmental performance. Get in touch to find out more.
