The British tax authority HMRC has launched a consultation on the potential introduction of mandatory certification for mechanically recycled plastics in packaging. The aim is to tighten proof of compliance under the UK's Plastic Packaging Tax (PPT) and curb incorrect or fraudulent recycling claims.
Since the introduction of the Plastic Packaging Tax in April 2022, plastic packaging has been tax-free if it contains at least 30 percent recycled plastic. However, according to HMRC, there are doubts about the robustness of individual proofs, particularly for imported packaging. Industry associations and recyclers have repeatedly pointed to possible false declarations.
Mandatory certification for mechanical recycling under discussion
The consultation is now examining whether manufacturers and importers will be obliged to submit certified proof in the future to claim tax exemption. A system of independent third-party certifications with defined minimum standards would be envisaged. Existing certification systems could continue to be used, provided they meet legal requirements.
According to the British government, the measure is intended to fulfil several objectives: it is meant to improve the traceability of recycled plastics, create uniform proof standards, and facilitate supervision by the tax authorities. At the same time, it should prevent compliant companies from being disadvantaged by incorrect or fraudulent statements.
The government also points to existing problems with international supply chains. Particularly in the case of imported, pre-filled packaging, documentation is often incomplete or difficult to verify.
Orientation on Chemical Recycling
The planned regulation is based on the previously announced requirements for chemically recycled plastics. For these, the British government decided in the Spring Budget 2025 to allow a so-called mass balance approach from 1 April 2027 – but only in conjunction with mandatory certification.
For mechanically recycled plastics, the government is now planning a similar model. Certification systems with audit obligations, chain-of-custody certificates, and accreditation of certification bodies by recognised accreditation organisations such as UKAS or international equivalents are planned.
Under current considerations, the certification would concern the entire supply chain – from the recycler to the manufacturer of the finished packaging component. Importing companies would have to be able to present valid certificates from their suppliers.
The branch should assess effort and feasibility.
The consultation runs until 10 August 2026. HMRC is asking businesses for their views on, among other things, administrative burdens, audit costs, and potential impacts on international supply chains.
The discussion also covers how frequently audits should take place and what requirements certification systems would need to meet. Furthermore, the government is asking about alternative approaches that could be used to reliably demonstrate recycling quotas.
Source: HMRC
