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)
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)
What businesses need to consider now
Scope and timing
- The consultation runs until 10 August 2026 — feedback is critical. (gov.uk)
- If introduced, changes would likely align with other PPT reforms becoming effective from 1 April 2027. (gov.uk)
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)
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
- Audit current practices: Review how you currently evidence recycled content claims. Are these robust, documented, recognized by third parties?
- Explore certification schemes already in industry or under discussion. Identify ones that meet likely future minimum standards.
- Map supply chain: For imported material, check whether suppliers comply, get their certification info.
- Budget for changes: Audit fees, possible chain-of-custody traceability systems, software/documentation upgrades.
- 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.