Plastic Packaging Tax consultation: Mandatory certification for recycled content
On 19 May 2026, HMRC opened a new consultation into the UK’s Plastic Packaging Tax (PPT) regulation focusing on mandatory third-party certification for mechanically recycled plastic content.
PPT, introduced in 2022, aims to provide an economic incentive for businesses to use recycled plastic in plastic packaging manufactured in or imported into the UK, diverting waste away from landfill and helping the UK transition to a circular economy. While the policy intent is clear, there have been persistent issues around gathering evidence and fraud within the supply chain.
The tax charged on plastic packaging which contains less than 30% recycled plastic is currently set at £228.82/t.
Scope of the consultation
Issues around PPT stem from the fact that recycled content exemption is often hard to evidence, with many companies opting to pay the PPT costs rather than spend money gathering evidence from complex manufacturing chains that may not meet requirements.
The proposed changes would mandate certification for evidence of mechanically recycled plastic in packaging, helping to mitigate the risk of fraudulent or erroneous claims, standardise evidence requirements, and to strengthen compliance activity. The consultation is specifically looking for views on fraud prevalence, impacts to businesses, and how the requirement should operate in practice.
The changes would also link through to wider PPT changes taking effect from 1 April 2027. From that date, evidencing chemically recycled plastic will be allowed, using a mass balance approach. The introduction of chemically recycled plastic would also introduce a certification requirement for that recovery stream, which this consultation is looking to align with for mechanically recycled plastic.
Also, as part of the changes, pre-consumer plastic waste will no longer count towards meeting the 30% recycled content threshold for PPT exemption.
This consultation closes 10 August 2026.
Beyondly welcomes this consultation and the benefits this could deliver for obligated companies and the PPT as a whole. However, it’s important to take care to keep compliance costs low due to the fees involved in obtaining and maintaining certification, potential supply chain restructuring, and ensuring a level playing field between domestic recyclers and importers.
Chris Smith, Lead Consultant for Resource Efficiency & Circularity at Beyondly comments: “Beyondly has helped many businesses to gather evidence for credible recycled content exemptions since 2022, so we understand the challenges both HMRC and industry face. Disallowing pre-consumer plastic will result in more businesses and packaging becoming liable; however, to genuinely increase demand and supply of post-consumer plastic, HMRC must address the fact that paying the tax costs less than incorporating credibly recycled content.”
We encourage HMRC to continue the government’s use of co-design and to work closely with all sectors involved in PPT to make sure these changes are rebuilding trust in the system and moving away from ‘just pay it’ thinking.
You can read and respond to the consultation here: Plastic Packaging Tax: potential certification for mechanically recycled plastic packaging - GOV.UK
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