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)
The consultation seeks input on:
- What types of evidence or documentation should be required to prove recycled content levels. (gov.uk)
- How strict the certification should be, and whether small operators are disproportionately burdened. (gov.uk)
- Timing and implementation paths—whether staged or fast-track for larger importers/manufacturers. (gov.uk)
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)
- 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)
- 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.
Stay updated as HMRC publishes feedback and next steps. Early preparation can make the difference between being ahead of changes and playing catch-up.