The UK government has opened a consultation on potential changes to the Plastic Packaging Tax (PPT), including stricter verification rules for recycled plastic claims.

Issued by HMRC on 18 May 2026, the consultation will run for 12 weeks and examine whether companies seeking PPT exemptions should provide certified proof for mechanically recycled plastic used in packaging.

The government says the review is intended to address concerns about inaccurate or potentially fraudulent declarations relating to recycled content.

It is also gathering feedback on the possible introduction of compulsory third-party certification for packaging that contains mechanically recycled plastics.

This follows earlier announcements confirming that chemically recycled plastics will require certification from April 2027, alongside the adoption of a mass balance accounting approach under the PPT framework.

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The Plastic Packaging Tax

Introduced in April 2022, the Plastic Packaging Tax was designed to encourage greater use of recycled plastics in packaging production.

Packaging made with 30% or more recycled plastic is exempt from the levy. Packaging that falls below this threshold is currently taxed at a rate of £228.82 per tonne.

HMRC stated that businesses and industry groups have continued to express concerns about the reliability of evidence used to support recycled content declarations, particularly where imported packaging is involved.

The consultation document says certification requirements could help reduce the likelihood of false or inaccurate claims, create more consistent evidence standards, and strengthen enforcement efforts.

Although HMRC noted that it currently has limited evidence of widespread fraud, organisations such as the British Plastics Federation (BPF) and RECOUP have repeatedly argued for more robust verification procedures.

Much of the concern relates to imported materials and the challenge of tracking recycled content across complex international supply chains.

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Proposed Certification Model

Rather than introducing a single mandatory certification provider, the government is considering a system in which businesses could select from approved third-party schemes that meet defined legal criteria.

The proposed schemes would focus on traceability and chain-of-custody checks for recycled materials, with inspections carried out by accredited auditors.

If implemented, companies across the supply chain – including recyclers and packaging manufacturers – would need certification for the PPT exemption to apply.

Importers would likewise be expected to secure valid certification from overseas suppliers.

HMRC added that the proposed framework would closely mirror the certification system currently being developed for chemically recycled plastic packaging.

The consultation period ends on 10 August 2026, and responses will help shape any future legislative changes.

Recent data published by HMRC has highlighted that the Plastic Packaging Tax (PPT) brought in £42 million more than forecast in 2022/23.

Data published by the department showed that £276 million was brought in from the tax, against an original estimate of £235 million. There have been 4,142 businesses registered.

The tax was introduced in April 2022 and saw a £200 per tonne levy placed on plastic packaging with less than 30% recycled content. The tax was raised to £210.82 per tonne as of 1 April 2023.

Data

Other statistics released by HMRC show that of the total plastic packaging manufactured in and imported into the UK 39% was declared as taxable under the PPT.

Of the total plastic packaging declared 52% was manufactured in the UK and 48% was imported into the UK.

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While we await clarity on extended producer responsibility (EPR) in the upcoming years, significant policy developments have emerged in the past week, indicating potential changes in the recycling landscape. Concerns raised by industry leaders and the ongoing cost-of-living crisis have added uncertainty to the EPR program's timeline, while government departments have been actively engaging with stakeholders on related recycling legislation.

During a recent parliamentary session, Prime Minister Rishi Sunak addressed concerns raised by businesses regarding the introduction of extended producer responsibility. The Conservative MP for Amber Valley, Nigel Mills, expressed worries over price rises and uncertainty about the costs associated with the program, making it challenging for businesses to plan their pricing strategies for next January.

Mr. Sunak acknowledged that industry had raised concerns with him and mentioned that Defra is actively working with manufacturers, retailers, and packaging companies to fine-tune the scheme's design.

However, the exact fate of the program remains uncertain, with calls for its potential delay amid mounting concerns.

Additionally, a senior policy advisor at HMRC spoke at the INCPEN conference about the recent consultation on adopting a 'mass balance approach' to calculate the use of chemically recycled plastic in packaging. Mark Palmer emphasised that the consultation is only the beginning of a collaborative effort with the industry. HMRC intends to work closely with stakeholders to ensure the success of any changes to the tax system. Palmer urged stakeholders to provide concrete evidence to support their submissions and assured them that HMRC would hold regular stakeholder meetings to inform the policy.

Moreover, recently published minutes from the Advisory Committee on Packaging (ACP) meeting held in May provided insights into Defra's plans for the EPR rollout. Defra expressed its intention to transition the rollout of the legislation gradually, with a pragmatic approach during the first two years of operation to allow for the system and processes to adapt smoothly. Discussions about a phased-in rollout have fuelled speculations that EPR might be delayed in some form, though Defra has reiterated its stance on the scheduled 2024 rollout date.

The ACP meeting also highlighted concerns from stakeholders about various aspects of EPR implementation. questions were raised about EPR and highlighted the importance of distinguishing between household and non-household packaging. Robert Fell, chief executive at Metal Packaging Manufacturers Association, expressed concerns about companies' lack of awareness of their obligations and the need for clarity on fee rates. Defra responded by assuring that plans are in place to address these concerns and that individual sessions with members and the ACP would focus on business readiness.

As the recycling landscape continues to evolve, stakeholders and government departments are actively engaged in discussions to shape sustainable policies and address industry concerns. While EPR's timeline remains uncertain, collaborative efforts and stakeholder engagement are crucial to achieving a greener and more sustainable future for recycling and waste management in the UK.

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With less than a year before April 2022 when the plastic packaging tax is set to go live, HMRC have released initial guidance policy papers; get your business ready for the plastic packaging tax and further information for businesses.

This confirms much of what we already know, for instance liable producers will have to register by 1^st April 2022 and records must be kept even if a business does not need to register for the tax. There are some further clarifications within the guidance, including the definition of a finished packaging component which gives a clearer indication of the tax point. It states that “this is when it has undergone its last substantial modification, even if waste or surplus materials remains attached to it”, adding that any attached surplus material is not taxable.

Exemptions and deferrals

The guidance also gives further clarity on exemptions stating that there are 4 exemptions as follows:

• plastic packaging manufactured or imported for use in the immediate packaging of a medicinal product
• transport packaging used on imported goods
• packaging used as aircraft, ship and rail stores
• components that are permanently designated or set aside for use other than a packaging use

In addition to the exemptions above there is also a deferral of liability for plastic packaging which is exported that meets the direct export condition – further guidance on the criteria that will need to be met to satisfy the direct export condition will be published later in the year.

Data and record keeping

Unfortunately, there is no new information or specifics on record keeping, despite the importance of accurate data records to evidence compliance with the tax. The guidance confirm that records must be kept even if a business does not need to register for the tax or is handling plastic packaging which is exempt or relieved from the tax, so it can be demonstrated to HMRC. In terms of imports, details of the plastic packaging’s composition must be obtained from the overseas manufacturer by the liable business in the UK, e.g. the importer.

Records must show:

• the total amount in weight and a breakdown by weight of the materials used to manufacture plastic packaging, excluding packaging which is used to transport imported goods.
• the data and calculations used to determine if a packaging component is, for the most part, plastic and how much recycled plastic it contains.
• the weight of exempted plastic packaging and the reason for the exemption
• the amount in weight of plastic packaging exported, and therefore the allowed relief from the tax.

Further guidance will be eagerly awaited

Despite this guidance clarity is still needed for certain aspects and timelines are becoming increasingly tighter with the tax not yet in law. The Government have confirmed that until the primary and secondary legislation become law, the contents of these policy papers are subject to change. The primary legislation is currently before parliament with secondary legislation to be introduced later this year. We continue to liaise with Government, industry, and producers to clarify the specific mechanics and requirements of the tax.

Our team are working with members to support their needs in relation to the future requirements of the plastic packaging tax. To assess the impact of the plastic packaging tax on your business and find out more about how our team can help, contact us today.

Last Thursday (12 November), HM Revenue & Customs published draft legislation for the plastic packaging tax, alongside a summary of responses to the recent consultation.

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The plastic packaging tax will apply to producers of packaging which is predominantly plastic by weight and does not contain at least 30% recycled plastic, whether imported or manufactured in the UK.

The tax aims to significantly increase the use of recycled content in plastic packaging, while driving recycling technologies here in the UK and helping to divert plastic from landfill or incineration.

At the Budget 2018, it was announced by Government that a plastic packaging tax would be introduced in April 2022 to increase demand and encourage the use of recycled plastic content. Since the announcement we have seen a call for evidence and two rounds of consultations.

It was declared at the Budget 2020 that the tax will be £200 per tonne of plastic packaging which does not meet the 30% recycled content threshold. It was also confirmed that once the tax is introduced the rate and recycled content threshold will be kept under review to ensure the tax remains effective in increasing the use of recycled plastic.

You can view the summary of responses for the most recent Policy Design consultation here.

Inclusions, Definitions & Clarifying the Tax Point

It has been revealed that imported pre-filled goods will be included in the tax, as will packaging-type products and long-term storage containers, e.g. cling film and storage containers such as large plastic boxes.

Government recognised concerns and mixed views from respondents regarding the revised definition of plastic which removed the ‘main structural component’ clause and limiting exclusions to ‘cellulose-based’, nevertheless they will continue with the revisions. Thus, confirming alternative plastic such as biodegradable and compostable plastics are liable for taxation for now since further evidence is needed on the impact of widespread adoption of these materials. However, they will further consider these plastics following conclusion of the Bioeconomy Strategy.

Government confirmed that ‘the tax will be applied to domestically produced goods at final stage conversion on finished plastic packaging components’. Although many agreed, concerns were raised regarding anti-competitiveness to UK businesses since plastic waste from ancillary processes would be taxed whereas the same imported packaging would not be. Therefore, the Government has agreed the tax point should arise ‘at the final stage of conversion, after ancillary processing, but before the packaging is packed or filled’. Going on to state a continued encouragement for businesses to ‘take all steps they can to reduce the amount of waste created by their manufacturing processes more widely’.

De Minimis & Exemptions

The de minimis has been confirmed so businesses that manufacture and/or import less than 10 tonnes of plastic packaging in a 12-month period will be exempt from the tax.

Other exemptions include plastic packaging which:has 30% or more recycled plastic content;

• is made of multiple materials of which plastic is not proportionately the heaviest when measured by weight;
• is manufactured or imported for use as immediate packaging of licensed human medicines;
• is in use as transport packaging to import products into the UK; or
• is exported, filled or unfilled, unless it is in use as transport packaging to export products out of the UK.

You can view the policy paper and draft legislation online here.

HMRC stated that “The tax will provide a clear economic incentive for businesses to use recycled material in plastic packaging, which will create greater demand for this material and in turn stimulate increased levels of recycling and collection of plastic waste, diverting it away from landfill or incineration.”

If you have any questions as to how the plastic packaging tax may impact your business please contact our team.