HMRC has opened a consultation on requiring third-party certification for plastic packaging that claims to contain at least 30 per cent mechanically recycled plastic, to be exempt from the Plastic Packaging Tax (PPT).

The consultation, which closes on 10 August 2026, seeks evidence from across the plastics supply chain - mechanical recyclers, packaging manufacturers, importers, waste management companies and trade bodies - on the level of fraudulent or incorrect recycled content claims, what certification would mean in practice, and how long businesses would need to prepare.

PPT, introduced on 1 April 2022, currently costs £228.82 per tonne for packaging made with less than 30 per cent recycled content. Businesses claiming the exemption must hold records showing where the material was sourced, when packaging components were made or imported, and the proportion of recycled plastic in the output. However, existing guidance does not prescribe which specific documents are required (HMRC accepts product specifications, production certificates, certificates of conformity, accreditation records and invoices, among others), but this flexibility also creates issues. Businesses are uncertain about what will pass scrutiny, and HMRC says it receives regular queries as a result.

The challenge is particularly problematic for importers. Where a UK business brings in finished plastic packaging from overseas, it may have no direct relationship with the packaging manufacturer and must rely on documentation provided through intermediaries that may vary in terms of quality and completeness. The further up the supply chain the manufacturer sits, the harder it is for an importer to conduct due diligence on the claims being made.

Industry concerns about the validity of some claims have been building since the tax launched. The British Plastics Federation (BPF) and RECOUP, an independent plastics recycling body with more than 170 members, published a report in December 2022 recommending a recycled content verification framework, citing the absence of any physical test capable of confirming recycled plastic content in a finished material. There is no way to scan a plastic bottle and determine whether it was made with 30 per cent post-consumer recyclate or not; verification depends entirely on the chain of custody. RECOUP followed this with a further report in September 2025 raising specific concerns about fraudulent claims on imported packaging, and a Westminster Hall debate in October 2023 heard similar arguments from MPs and industry witnesses calling for stronger enforcement.

HMRC says it has little hard evidence of widespread fraud. It does acknowledge, though, that the current system is difficult to police. With no standard format prescribed for evidence, documentation quality varies widely across the supply chain, and claims that fall short can go unchallenged. That is not a level playing field for businesses that comply properly.

How certification would work

Under the proposed framework, businesses would choose from accredited third-party certification schemes meeting minimum standards to be set in future legislation. HMRC is not proposing to mandate a single scheme, but any certification body used would need accreditation from UKAS (the United Kingdom Accreditation Service) or an overseas equivalent - an arrangement that gives certificates international standing and is relevant to the multi-jurisdiction supply chains from which much imported packaging originates.

Two chain-of-custody models are under consideration. The segregated model applies to packaging manufactured entirely from certified recycled material - no virgin plastic enters the process at any stage. Because what goes in is entirely certified recycled, the content of the finished product is straightforward to verify.

A secondary approach, labelled the “controlled blending model”, allows certified recycled and virgin materials to be combined during production, provided the exact proportion of each is recorded at the point of mixing. Where a manufacturer blends post-consumer recycled plastic with virgin polymer to meet the 30 per cent threshold, the certificate covers the recycled fraction and the manufacturer accounts for the rest. Under both models, the aim is the same: recycled content should be verifiable from what actually entered the production process, not reconstructed from supplier paperwork after the fact.

For businesses, the process would involve registering with a certification scheme, engaging a certification body to carry out an initial on-site audit, and - once compliant - receiving certification that must be maintained through ongoing surveillance and re-certification audits. Importers would not need to be certified themselves, but would be required to hold valid certificates from their overseas suppliers.

The proposal is modelled on a certification requirement already confirmed for chemically recycled plastic. From 1 April 2027, businesses using a mass balance approach to account for chemically recycled plastic in packaging will be required to hold equivalent certification, alongside a change restricting recycled content claims to post-consumer waste only. HMRC says it now wants to assess whether the same rationale - that independent verification is necessary to prevent fraud and maintain a level playing field - extends to mechanically recycled plastic, which currently accounts for the majority of recycled content claims under the tax.

Spain’s plastic tax, introduced on 1 January 2023, already requires a certificate from an official certifying body confirming that plastic is recycled before an exemption can apply, and is cited in the consultation document as an international reference point.

Louise Goodfellow, Policy Manager at Ecosurety, a producer compliance scheme operator, welcomed the consultation but urged HMRC to keep proportionality central to the design. “We welcome HMRC’s consultation on strengthening the evidence requirements for recycled content under the Plastic Packaging Tax,” she said. “Ensuring robust safeguards are in place to prevent fraudulent or erroneous claims is essential to maintaining a fair and credible system for all obligated businesses.

“However, it is equally important that any new certification or evidential requirements are proportionate and practical to implement as overly burdensome administrative processes risk undermining progress by discouraging the use of circular materials.

“Therefore, we encourage HMRC to work closely with industry to design a system that is robust against fraud, but not so complex or costly that it creates barriers to compliance or slows the transition to a more circular plastics economy.”

Responses can be submitted via the online form on GOV.UK or by email to indirecttaxdesign.team@hmrc.gov.uk by 10 August 2026. HMRC will also hold stakeholder meetings during the consultation period; businesses wishing to be included can contact the team at the same address.