Compliance
Navigating Plastic Packaging Tax: What Proposed Certification Might Mean for Manufacturers
A recent HMRC consultation seeks to introduce mandatory certification for mechanically recycled plastic packaging—here’s what that could mean for compliance, costs, and operations.
By NomadicTax Research Team • 5-8 min read • June 18, 2026
## What’s Proposed in the Consultation
On **18 May 2026**, HM Revenue & Customs published a consultation to explore introducing **mandatory certification for mechanically recycled plastic packaging**. The goal is to address fraudulent claims, improve transparency, and ensure that claims about recycled content are supported by verifiable evidence. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging?utm_source=openai))
The consultation seeks input on:
- What types of evidence or documentation should be required to prove recycled content levels. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging?utm_source=openai))
- How strict the certification should be, and whether small operators are disproportionately burdened. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging?utm_source=openai))
- Timing and implementation paths—whether staged or fast-track for larger importers/manufacturers. ([gov.uk](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging?utm_source=openai))
## Who Needs to Pay Attention
- **UK plastic packaging manufacturers and importers** who deal with finished packaging components with less than 30% recycled plastic. They’re already subject to Plastic Packaging Tax (PPT) and must register if they manufacture or import **10-tonnes or more** in a 12-month period. ([gov.uk](https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax?utm_source=openai))
- **Design, procurement, and quality assurance teams**, who will need to maintain records, testing documentation, and possibly seek external certification.
- **Small and medium enterprises (SMEs)** where the cost of certification and compliance could disproportionately impact margins. They should consider engaging in the consultation or collaborating to share resources.
## Practical Implications & Action Steps
- **Engage with the consultation** before the deadline (10 August 2026). It’s an opportunity to influence the rules and raise concerns about cost, technical feasibility, and fairness. ([kpmg.com](https://kpmg.com/us/en/taxnewsflash/news/2026/05/tnf-uk-temporary-reductions-in-transport-related-taxes-guidance-on-taxation-of-ecosystem-services-consultation-on-changes-to-plastic-packaging-tax.html?utm_source=openai))
- **Audit your current recycled content claims**. If you’re already using recycled plastic, ensure the testing method or supply chain traceability meets likely certification standards.
- **Upgrade record-keeping**: Keep supplier certifications, lab test results, invoices, batch data. If changes come into effect, this data will be essential for compliance.
- **Factor in potential costs**: Certification may involve fees (certifying bodies, lab testing), delayed approvals, possibly stricter standards. Model worst-case costs now to avoid cash-flow surprises.
## Long-Term Opportunities & Risks
- **Competitive advantage**: Companies that can prove recycled content and have a transparent supply chain will likely be preferred, especially with sustainability-conscious buyers.
- **Risk of non-compliance**, penalties, or reputational damage if claims prove misleading after rules come in.
- **Supply chain adjustments**: Some recycled plastic supplies are inconsistent; ensuring reliability will matter. Certified sources may become more valuable.
## Example Scenario
A packaging company imports 30 tonnes of packaging per year, currently using various suppliers of recycled resin. If mandatory certification is introduced:
- They’ll need to collect valid certificates from each supplier. If one lacks it, the packaging could be considered non-compliant.
- Their effective PPT liability may increase if certification reveals recycled content is below thresholds, or if they must accept higher compliance costs.
- To mitigate risk, they may shift to recycled-plastic content above 30%, where possible, or get into supplier contracts supplying certified materials.
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Stay updated as HMRC publishes feedback and next steps. Early preparation can make the difference between being ahead of changes and playing catch-up.