Call for input – Plastic Packaging Tax

IOM3 is seeking views on the proposed introduction of mandatory certification for the Plastic Packaging Tax.

The UK Government has launched a consultation exploring the potential introduction of a mandatory certification requirement for mechanically recycled plastic in packaging. It's specifically looking for input on the prevalence of fraud, impacts on businesses to which this requirement would apply, how it should operate in practice and potential timelines for implementation.

The Plastic Packaging Tax is not chargeable on plastic packaging containing 30% or more recycled plastic. There is no test available to verify recycled plastic content in a material, so verification depends on chain of custody evidence showing the source and inclusion of recycled plastic. The guidance stipulates what evidence is required, but it does not prescribe what documents a business must hold. Concerns have been raised around the validity of some recycled plastic claims and the enforcement of the tax on imported plastic packaging.

The government has previously announced that mandatory certification will be introduced for chemically recycled plastic when using a mass balance approach. In addition, pre-consumer waste will no longer be classified as recycled plastic for the purposes of the tax, and only reprocessed post-consumer plastic waste will be accepted. These changes will take effect from 1 April 2027.

This consultation explores mandating certification for mechanically recycled plastic in packaging. As well as asking for general insight that supports the concerns raised around the prevalence of fraudulent claims, key questions include:

• Do you agree that mandating certification and standardising the evidence required could provide more certainty for businesses, and do you foresee any barriers to implementation or have alternative suggestions?
• What documentation is currently used, what challenges do UK manufacturers face when obtaining evidence, and what other countries require evidence of recycled content?
• Can you provide examples of successful third-party certification models in other sectors?
• How should the scheme work? E.g. minimum requirements for audit, frequency of scheme checks, timeline for implementation.
• How could the government minimise data and cost burdens if it is implemented and help businesses to prepare?

IOM3 is seeking input from members to develop its response. If you’re able to contribute, please contact Head of Policy at [email protected]

Read the full consultation and list of questions