Plastic Packaging Tax
Is the business required to register, and is the specific finished component chargeable or supported by an exemption or recycled-content evidence under HMRC rules?
PPT evidence guide
Plastic Packaging Tax and recycled-content evidence
Treat Plastic Packaging Tax records, recycled-content claims and recyclability assessments as related but separate evidence streams.
Direct answer
HMRC requires evidence for recycled plastic content.
Businesses that manufacture or import 10 tonnes or more of finished plastic packaging components within the relevant 12-month tests may need to register for Plastic Packaging Tax. Plastic packaging components containing less than 30% recycled plastic can be chargeable, subject to the detailed rules and exemptions.
HMRC guidance states that plastic is assumed to be non-recycled unless evidence shows that recycled plastic was used. Packaging with at least 30% recycled plastic may be non-chargeable, but it still counts towards the registration threshold and records are still required.
This is a procurement and evidence guide, not tax advice. Confirm liability, calculations, exemptions and current rates directly with HMRC or a qualified adviser.
Three separate questions
Do not merge tax, recyclability and marketing claims
EPR recyclability assessment
How is the finished packaging rated under the applicable reporting-year methodology, considering the complete pack and the defined collection, sorting and reprocessing stages?
Consumer or customer statement
What wording is accurate for the exact pack, market and evidence? A “30% recycled content” statement does not establish that a pack is recyclable, and a recyclable rating does not prove recycled content.
Supplier evidence
Control recycled-content information by product line
| Exact component | Product reference, drawing or specification, manufacturing site where relevant and the definition of the finished plastic packaging component. |
|---|---|
| Recycled-content percentage | Percentage for the supplied component, the basis of calculation and whether the evidence applies to each batch, a product line or a defined period. |
| Material inputs | Virgin and recycled plastic weights or verified specification data used under the permitted method. Keep the calculation and units. |
| Source and type | Supplier declaration and any supporting certification or chain-of-custody information relevant to the claim. Confirm whether post-consumer, pre-consumer or another category is being stated. |
| Change control | How the supplier will notify a change in grade, percentage, manufacturing route or evidence status. |
| Internal record | Purchase quantities, imports or production, weights, tax treatment, supporting evidence, review and responsible person linked to the relevant accounting period. |
Procurement checks
Questions to ask before relying on a recycled-content claim
- Does the declaration identify the exact component and current specification?
- Is the percentage calculated for the finished component using a method accepted under the current HMRC guidance?
- Does the statement cover the supplied batch or product line and identify any permitted variation?
- Can the supplier provide evidence if HMRC or a customer requests substantiation?
- Is recycled plastic permitted for the intended product-contact or other regulated use?
- Are purchasing, goods-received and stock records able to link the evidence to quantities supplied?
- Will a material or supplier change trigger re-approval and updated records?
Food-contact caution: a recycled-content target does not override product-contact law or safety requirements. Use the exact supplier declaration and obtain specialist advice where the intended use is regulated.
Official sources
Use current HMRC guidance for calculations and records
- Plastic Packaging Tax: steps to take
- Check which packaging is subject to Plastic Packaging Tax
- Work out packaging weight and recycled plastic content
- Records and accounts for Plastic Packaging Tax
For the finished pack's separate recyclability assessment, use the UK EPR and RAM guide.
Request current material documentation Open the document checklist