Context & What’s Under Consultation
On 18 May 2026, HMRC announced a consultation to explore introducing a mandatory certification requirement for mechanically recycled plastic packaging. The focus is on:
- Strengthening evidence requirements for claims about recycled content. (gov.uk)
- Investigating how fraudulent or misleading claims may be addressed.
- Determining the scale and timing of certification, and business impact.
This doesn’t yet change law—it’s at the proposed stage—but firms are expected to prepare.
Key Areas to Analyze Internally
| Area | Questions to Ask |
|---|---|
| Supply chain traceability | Can you track recycled content percentage mechanically recycled plastic supplied to you? Do you have reliable documentation from upstream suppliers? |
| Current record-keeping | What is your system for recording recycled vs virgin plastic percentages? How robust are your audit trails and testing results? |
| Cost impact | Estimate additional costs for certification, third-party audits, verification, or lab testing. |
| Timeline risk | Depending on the speed of adoption, you may have only months to adjust if proposals move quickly. Gather data early. |
Steps to Get Ahead of the Curve
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Conduct a gap-analysis of your current compliance vs proposed certification standards. Include suppliers, declarations, lab certifications.
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Start documenting recycled plastic inputs meticulously with invoices, certificates, tests. Even if voluntary now, these records will support compliance.
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Engage with industry bodies or HMRC consultation process to influence the proposed framework and understand expected timelines.
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Consider setting aside budget and operation capacity for certification processes—testing, verifying, third-party auditors.
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Review your product labeling, marketing, or customer communications to ensure any recycled content claims are accurate, defensible, and evidence-based.
Example Scenario
A packaging import company imports crates claiming 40% recycled plastic mechanically reprocessed. Under the proposal, without proper certification, that claim might be challenged, requiring removal from invoice or sales literature, possibly triggering penalties. To protect margin and reputation, the company arranges supplier lab tests, collects chain of custody documentation, and explores certification providers now.
What To Watch Out For
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Consultation ends on 10 August 2026—after that HMRC will evaluate responses before proposals become policy. (kpmg.com)
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Businesses with volumes above 10 tonnes per year (whether all recycled or not) are already within scope for PPT registration; the certification would overlay on that liability. (gov.uk)
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Potential for increased cost of capital or compliance for small operators especially if audit or verification costs are involved disproportionately.
Take-away: Even though this is proposed, early preparation can give you competitive advantage and avoid scrambling when new rules hit.