Plastic Packaging Tax consultation released

HM Revenue & Customs (HMRC) released a consultation on 18 May, asking respondents to comment on a proposed change to the way the presence of mechanically recycled plastic is evidenced.

The Plastic Packaging Tax (PPT) charges manufacturers and importers on the tonnage of packaging they produce that has less than 30% recycled content. However, for those businesses claiming 30% recycled content or more, evidence needs to be retained proving the packaging is exempt from the tax.

What changes are proposed?

The consultation outlines that the evidence threshold may need to be raised due to ‘industry concerns’ and proposes a potential mandatory certification process to ‘mitigate the risk of fraudulent or erroneous claims’, particularly for imported packaging.

The consultation suggests that rather than a single mandated certification scheme, importers and manufacturers could choose their provider, given they meet minimum standards that will be set out in future legislation.

The verification and certification process would specifically focus on chain-of-custody and audits by these accredited organisations and importers of plastic packaging would need to hold equivalent certification from overseas suppliers.

Separately, work is ongoing to allow chemically recycled plastic to contribute towards the 30% threshold. This will be implemented by allowing reprocessors and manufacturers to use a mass balance approach, in order to calculate the weight of chemically recycled content within a packaging component.

As part of the consultation process, HMRC announced that a mandatory certification process will be required from the outset. Implementing the same for mechanical processes then, would level the playing field.

The consultation will run for 12 weeks, the deadline to respond is 10 August 2026.

We welcome HMRC’s consultation on strengthening the evidence requirements for recycled content under the Plastic Packaging Tax. Ensuring robust safeguards are in place to prevent fraudulent or erroneous claims is essential to maintaining a fair and credible system for all obligated businesses.

However, it is equally important that any new certification or evidential requirements are proportionate and practical to implement as overly burdensome administrative processes risk undermining progress by discouraging the use of circular materials.

Therefore, we encourage HMRC to work closely with industry to design a system that is robust against fraud, but not so complex or costly that it creates barriers to compliance or slows the transition to a more circular plastics economy.