Compliance
How Mandatory Certification for Recycled Content Could Impact Businesses under UK’s Plastic Packaging Tax
A proposal to require mandatory certification for mechanically recycled plastic content in packaging may affect manufacturers & importers. Learn what’s changing and how to prepare.
By NomadicTax Research Team • 5-8 min read • June 15, 2026
## What’s proposed and why it matters
On **18 May 2026**, HMRC published a **consultation** proposing a requirement that packaging containing **mechanically recycled plastic** must be **certified** in order to claim an exemption from the Plastic Packaging Tax (PPT) — which applies when plastic packaging has **less than 30% recycled content**. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging?utm_source=openai))
If adopted, this would standardize the evidential requirements for recycled content claims, address fraud concerns, and align with rules for chemically recycled plastic. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging/plastic-packaging-tax-potential-certification-for-mechanically-recycled-plastic-packaging?utm_source=openai))
## What businesses need to consider now
### Scope and timing
- The consultation runs until **10 August 2026** — feedback is critical. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging/plastic-packaging-tax-potential-certification-for-mechanically-recycled-plastic-packaging?utm_source=openai))
- If introduced, changes would likely align with other PPT reforms becoming effective from **1 April 2027**. ([gov.uk](https://www.gov.uk/government/publications/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic?utm_source=openai))
### What certification means in practice
- Certification scheme defines standards for verifying recycled plastic content, chain of custody, minimum recycled content proportion.
- Certification bodies (e.g. UKAS-accredited or equivalent) would audit and issue certificates. Imported packaging must be supported by valid certification if overseas certification bodies are used. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging/plastic-packaging-tax-potential-certification-for-mechanically-recycled-plastic-packaging?utm_source=openai))
### Compliance costs & risks
- Costs: certification fees, audit readiness, documentation processes, possibly changing suppliers.
- Risks: claims could be rejected without valid certification; paying PPT if fails to meet requirements.
### Example
**GreenWrap Ltd**, a UK packaging manufacturer imports mechanically recycled plastics from abroad. Under current rules, it uses supplier invoices and internal tests. Under new proposal, it might need **certified proof from recognized scheme**, possibly UKAS-accredited, and ensure their overseas supplier is certified — meaning additional audit, new supplier relationships, documentation.
## Preparation action plan
1. **Audit current practices**: Review how you currently evidence recycled content claims. Are these robust, documented, recognized by third parties?
2. **Explore certification schemes** already in industry or under discussion. Identify ones that meet likely future minimum standards.
3. **Map supply chain**: For imported material, check whether suppliers comply, get their certification info.
4. **Budget for changes**: Audit fees, possible chain-of-custody traceability systems, software/documentation upgrades.
5. **Submit consultation feedback**: raise practical issues, burden on small businesses, proposed timing, transitional reliefs.
## What comes next
- The government will analyse responses by end of consultation (10 August 2026), then decide whether to legislate.
- If legislated, businesses will need lead time — often 6-12 months or tied to accounting periods.
- Watch for related guidance on toxic materials, VAT, declarations, import compliance.
### Why this matters now
- Plastic Packaging Tax exemptions are important for cost savings — without certification, exemption claims might fail.
- Early adopters of compliant systems may benefit before formal requirements arrive.
- Competitive advantage for those with strong environmental credentials.
In short, if your business uses mechanically recycled plastic, you don’t want to wait until this policy is enacted — preparing now could save time, cost, and compliance headaches down the line.