The UK government is considering mandatory third-party certification for mechanically recycled plastic used to meet the Plastic Packaging Tax’s 30% recycled-content threshold, with potential implications for overseas suppliers.
Packaging manufacturers and businesses importing packaging into the UK could face new certification requirements when using mechanically recycled plastic to demonstrate that their packaging is not chargeable to Plastic Packaging Tax (PPT).
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HM Revenue & Customs (HMRC), the UK’s tax authority, closed a consultation on the proposal on 10 August 2026. It examined whether independent certification should become a condition for demonstrating that packaging contains at least 30% recycled plastic. The proposal remains subject to a government decision.
The implications could extend beyond tax reporting. Recyclers, polymer suppliers and converters could face additional audit and documentation requirements, while UK importers could need certification from overseas suppliers.
The proposal concerns the evidence used to demonstrate mechanically recycled content for PPT purposes. It would not create a blanket certification requirement for every plastic packaging product placed on the UK market.
Why HMRC is considering certification
PPT applies to finished plastic packaging components manufactured in or imported into the UK that contain less than 30% recycled plastic, subject to exclusions, reliefs and exemptions. From 1 April 2026, the tax rate is £228.82 per tonne.
Packaging containing at least 30% recycled plastic is not chargeable to the tax. Businesses must still retain evidence supporting their claims and include such packaging when assessing whether they meet the PPT registration threshold.
Businesses can currently substantiate recycled-content claims using documents such as product specifications, production certificates, audit reports and invoices. There is no mandatory certification framework for mechanically recycled plastic under PPT.
That flexibility can create uncertainty over what evidence is sufficient. Importers may face particular challenges when information comes from suppliers several stages removed from the recycling process.
Industry organisations have called for stronger verification. A 2022 report from the British Plastics Federation and RECOUP recommended a framework for verifying recycled content. RECOUP subsequently raised concerns about inaccurate or fraudulent claims involving imported packaging.
HMRC’s consultation nevertheless states that it holds very little evidence substantiating concerns about widespread fraud. It therefore sought further evidence on the scale and nature of the problem and whether mandatory certification would be a proportionate response.
The potential impact is substantial. HMRC’s latest statistics show that 2.97 million tonnes of plastic packaging were declared in the 2025–26 financial year. Of this, 1.506 million tonnes were reported as containing at least 30% recycled plastic. That represents approximately 51% of total declared tonnage and was the largest category of packaging reported as relieved or exempt from PPT.
How recycled content could be verified
The proposed system would use independent certification schemes meeting minimum requirements set out in legislation. Businesses could choose a qualifying scheme, with existing schemes potentially recognised where they meet those standards.
Certification would focus on chain of custody: documenting where recycled plastic originated, how it moved through the supply chain and how it was incorporated into finished packaging components. Independent certification bodies would audit businesses’ records and processes.
The consultation identifies two chain-of-custody models for mechanically recycled plastic.
Under a segregated model, certified recycled material remains separate from non-certified material throughout production.
A controlled blending model would allow certified recycled plastic to be mixed with virgin plastic, provided the quantities and proportions are known and controlled.
For converters, controlled blending could accommodate formulations that combine recycled and virgin polymers to achieve particular processing or performance characteristics. Records would need to demonstrate the recycled proportion attributed to the resulting packaging component.
Verification would therefore depend heavily on traceability. HMRC’s consultation says there is currently no test available to verify recycled plastic content in a material, making reliable supply-chain and production records central to the proposed approach.
What could change for international packaging suppliers?
Under the proposed approach, certification would cover businesses from the recycler through to manufacture of the finished packaging component. UK importers would need valid certification demonstrating that overseas suppliers met the relevant requirements.
This could make access to supplier documentation a more important part of purchasing decisions. An importer may have a direct relationship with a packaging manufacturer but limited visibility of the recycler or polymer producer further upstream.
If certification becomes mandatory, buyers could introduce more formal verification requirements into supplier contracts and procurement processes. Overseas packaging manufacturers could therefore face certification demands from UK customers even where they have no direct PPT liability.
Companies already using recycled-content certification schemes may have systems they can build on. Those schemes would still need to meet any future UK requirements, however.
Suppliers without certification could face audit fees, additional administration and changes to record-keeping. HMRC sought views on likely costs, whether businesses would pass those costs on to customers and how implementation arrangements could reduce the burden.
The issue also extends to packaging imported into the UK already filled with goods. Companies importing finished products can have PPT obligations even when they did not manufacture or purchase the packaging directly.
For those businesses, obtaining the necessary evidence may require coordination with product suppliers as well as packaging manufacturers.
How the proposal fits with confirmed 2027 changes
The mechanical-recycling proposal sits alongside separate changes to the treatment of chemically recycled plastic.
From 1 April 2027, businesses will be permitted to use a mass balance approach to account for chemically recycled plastic under PPT. This approach tracks recycled inputs through production and allocates the resulting recycled content to outputs under specified accounting rules.
Businesses using the approach will need certification that meets HMRC’s minimum requirements. HMRC published those requirements on 28 August 2026.
From the same date, pre-consumer plastic waste will cease to qualify as recycled content for PPT purposes. Only reprocessed post-consumer plastic waste will qualify under the revised definition.
These confirmed changes should be distinguished from the proposed certification requirement for mechanically recycled plastic, which remains under consideration and has no established implementation date.
For businesses supplying packaging made using different recycling processes, that distinction matters when planning certification, record-keeping and customer communications.
What packaging businesses should watch next
The next policy milestone is the government’s response to the mechanical-recycling consultation.
Businesses will need clarity on whether certification will proceed, what minimum standards would apply, how existing schemes would qualify and how much preparation time would be available.
In the meantime, manufacturers, converters, recyclers and importers can review how they document recycled content and identify gaps in evidence across their supply chains.
International suppliers can assess which UK customers require PPT evidence and whether their documentation can trace recycled material through the relevant recycling and manufacturing stages. Such reviews would support existing compliance requirements while helping businesses prepare for a possible change.
For packaging suppliers and buyers, the key issue is whether mandatory certification would provide more consistent verification and how the resulting costs and administrative requirements would be distributed across the supply chain.
The government’s decision will determine how far those requirements extend through the international packaging supply chains serving the UK market.
