Plastic Packaging Tax Consultation 2026

Plastic Packaging Tax Consultation 2026: Mandatory Certification for Recycled Content Explained — On 18 May 2026, HMRC launched a 12-week consultation that could significantly change how manufacturers, importers and recyclers evidence recycled content in plastic packaging. If your business currently relies on the 30% recycled content threshold to qualify for exemption from the Plastic Packaging Tax (PPT), the proposed move toward mandatory third-party certification could reshape how you prove compliance—and who is responsible for validating those claims.

Why the Government Is Acting Now

The Plastic Packaging Tax has been live since April 2022. However, HMRC has grown increasingly concerned about the integrity of evidence on recycled plastic content. Self-declared figures, inconsistent supplier documentation and a handful of high-profile fraud cases have eroded confidence in the system. The worry is simple: if businesses can claim 30% recycled content without robust proof, the tax stops driving the behaviour change that it was designed to deliver.

As a result, the HMRC consultation proposes mandatory third-party certification for mechanically recycled plastic packaging. In plain terms, that means a self-declaration would no longer be enough. You'd need an independent, accredited certifier to verify that the recycled content is genuinely there.

What Third-Party Certification Could Look Like

The Government's preferred direction is recycled content certification underpinned by a documented chain of custody evidence, where audits would be carried out by accredited certification bodies. Two chain of custody models are on the table:

• Segregated model: Recycled material is kept physically separate from virgin plastic at every stage. Easier to evidence, harder to operationalise at scale.
• Controlled blending model: Recycled and virgin materials can be mixed, but only under strict input-output accounting rules. This is more flexible for high-throughput manufacturers of mechanically recycled plastic, but demands tighter record-keeping.

Both models would need to be backed by certificates of conformity issued by accredited bodies. This is where UKAS accreditation comes in.

GACI MRA and Why It Matters

For a certification body to be recognised under PPT, it would need to be accredited by a body that's a signatory to the Global Accreditation Cooperation Incorporated multilateral recognition agreement (GACI MRA).

In the UK, that's UKAS, the United Kingdom Accreditation Service. UKAS is already a GACI MRA signatory. As a result, UKAS accreditation would be the gold standard for plastic packaging compliance, with overseas equivalents also qualifying. This is important if you're importing finished packaging or filled goods from outside the UK.

The practical upshot? You'll need to know not only who certifies your supplier, but who accredits the certifier.

Alignment With Chemical Recycling Rules

The Government has already confirmed mandatory mass balance certification for chemically recycled plastic, due to take effect from 1 April 2027. In addition, the new consultation signals an intention to align standards for mechanically recycled plastic certification with those for chemically recycled plastic. This would create a single, consistent evidence regime across both recycling routes.

Government recognises that business need a clear planning horizon for changes such as this – and so it asks how soon such an approach could be introduced.

The Financial Reality

The current PPT rate sits at £228.82 per tonne for plastic packaging that doesn't meet the 30% recycled content threshold. For a mid-sized manufacturer placing 500 tonnes of packaging on the market each year, for example, that's a potential £114,410 annual liability if certification falls through.

And here's the catch: under the proposed rules, packaging without valid recycled plastic evidence from a third-party certifier would be treated as taxable by default. No certificate, no exemption. The burden of proof shifts decisively to the business making the claim.

Who's Affected and How

• Manufacturers will need to secure certified recyclate from suppliers and maintain robust records.
• Importers face arguably the toughest task. They must source equivalent overseas certification and translate it into HMRC-acceptable evidence.
• Recyclers may need to invest in accredited certification themselves, or risk losing customers to competitors who have.

If your supply chain crosses borders, expect a fresh wave of plastic packaging compliance due diligence requests from your customers in the coming months.

How to Prepare Before 10 August 2026

The consultation is your opportunity to shape the final rules. Here are five practical next steps:

1. Map your current evidence trail. Where does your recycled plastic evidence come from, and would it meet the new requirements?
2. Talk to your suppliers. Ask whether they're already certified for mechanically recycled plastic, and by whom.
3. Model the cost of non-compliance. Quantify your exposure at £228.82 per tonne.
4. Talk to your sector. Your trade associations are likely to be working on this – join the discussions to gain more insight, perspective and to help shape your response.
5. Submit a response to the HMRC consultation. Officials want to hear from businesses across the supply chain, particularly on the segregated versus controlled blending question.

For wider context, see our guidance on Plastic Packaging Tax compliance and EPR compliance for packaging producers.

How ERP UK Can Help

We've spent years helping businesses navigate PPT, EPR compliance and the wider packaging regulatory landscape. Our team can support you with evidence gathering, supplier engagement and assessment of impact.

Recycled content certification doesn't have to be a burden. Handled well, it's a competitive advantage, proof that your sustainability claims stand up to scrutiny.

Get in touch with ERP UK to start your PPT 2026 readiness review. The deadline will come around faster than you think.

 References

HM Revenue & Customs (2026). Plastic Packaging Tax: potential certification for mechanically recycled plastic packaging. Consultation opened 18 May 2026, closes 10 August 2026. Available at: https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging

HM Revenue & Customs. Check if you need to register for Plastic Packaging Tax. GOV.UK guidance on the 30% recycled content threshold and scope. Available at: https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax

HM Revenue & Customs (2022). Introduction of Plastic Packaging Tax from 1 April 2022. Policy paper. Available at: https://www.gov.uk/government/publications/introduction-of-plastic-packaging-tax-from-april-2022

United Kingdom Accreditation Service (UKAS). International recognition and the GACI multilateral recognition arrangement. Available at: https://www.ukas.com/about-us/international-recognition/

HM Revenue & Customs (2023). Plastic Packaging Tax: chemical recycling and adoption of a mass balance approach. Confirmed implementation from 1 April 2027. Available at: https://www.gov.uk/government/consultations/plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach

HM Revenue & Customs. Plastic Packaging Tax rates. The 2025-26 rate of £228.82 per tonne applies to plastic packaging containing less than 30% recycled content. Available at: https://www.gov.uk/guidance/plastic-packaging-tax-what-you-need-to-do

Contact us today:

Telephone: +44 (0)20 3142 6452

E-mail: uk@erp-recycling.org

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