The UK’s Plastic Packaging Tax can apply to packaging manufactured domestically or imported, including packaging already filled with goods. This guide explains the component-level test, the 30% recycled-content threshold, exemptions and the changes taking effect in April 2027.
The UK’s Plastic Packaging Tax (PPT) applies to finished plastic packaging components containing less than 30% recycled plastic.
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The rules affect UK packaging manufacturers and businesses importing packaging or packaged goods into the country. International suppliers may also need to provide the specifications and evidence their UK customers require to determine their tax position.
The central question is not simply whether a product contains plastic. HM Revenue & Customs (HMRC), the UK tax authority, assesses individual finished packaging components according to their material composition, weight, intended use and recycled content. The way packaging is manufactured or imported can also determine when the tax becomes chargeable and which business is responsible.
PPT is separate from the UK’s extended producer responsibility regime, packaging-waste reporting requirements and restrictions on certain single-use plastic products. A business may therefore have obligations under more than one regime.
UK Plastic Packaging Tax at a glance
| Test | What businesses need to know |
| Where does it apply? | Finished plastic packaging components manufactured in or imported into the UK |
| Who may be liable? | Usually the UK manufacturer or the business responsible for the import |
| Registration threshold | 10 metric tonnes in the previous 12 months or expected in the next 30 days |
| Recycled-content threshold | Components containing at least 30% recycled plastic are not chargeable |
| Tax rate | £228.82 per metric tonne from 1 April 2026 |
| Assessment basis | Each finished packaging component is assessed separately |
| Imported filled packaging | Included unless an exemption or exclusion applies |
| Next major change | New rules for chemically recycled and pre-consumer plastic from 1 April 2027 |
Information checked 22 September 2026. Monetary figures are in pounds sterling. Businesses should confirm the current rules and rate through HMRC’s Plastic Packaging Tax guidance.
The current rate is £228.82 per metric tonne of chargeable packaging manufactured in or imported into the UK from 1 April 2026.
Which businesses must register for PPT?
A business must register if it:
- expects to manufacture in the UK or import into the UK 10 metric tonnes or more of finished plastic packaging components in the next 30 days; or
- has manufactured or imported at least 10 metric tonnes during the previous 12 months.
The threshold can comprise a combination of packaging manufactured in the UK and packaging imported into the country.
Registration may be required even if all the packaging contains at least 30% recycled plastic and no tax is payable. Some exempt packaging also counts towards the threshold.
Businesses must register within 30 days of becoming liable. The tax is due on chargeable packaging from the date the business becomes liable to register.
For imports, responsibility depends on the circumstances of the transaction. The importer is generally the consignee named in the import documentation unless it can show that it is acting for another party controlling the import. Businesses using Incoterms should establish which party is responsible for accounting for PPT.
This is particularly relevant to international suppliers selling into the UK. Contracts and import arrangements should identify the responsible party, while suppliers should be prepared to provide reliable packaging data.
What counts as plastic packaging?
For PPT purposes, HMRC defines plastic as a polymer material to which additives or other substances may have been added.
The definition includes biodegradable, compostable and oxo-degradable plastics. Describing a material as bio-based, biodegradable or compostable does not, by itself, place it outside the tax.
Cellulose-based materials require closer examination. Unmodified cellulose-based polymers, such as viscose, are not treated as plastic, while chemically modified materials, such as cellulose acetate, are. Additives including calcium and dyes form part of the plastic when the component’s material composition is assessed.
PPT broadly covers packaging that is:
- designed to contain, protect, handle, present or deliver goods through the supply chain; or
- designed for single use by a consumer to perform those functions in relation to goods or waste.
Potential examples include bottles, caps, food trays, pots, flexible pouches, protective film, shrink wrap, carrier bags and disposable cups, plates and bowls.
The treatment ultimately depends on the individual component and its intended function.
How are multi-material packs treated?
A packaging component does not have to be made entirely from plastic to fall within PPT.
A component is treated as plastic packaging when plastic, including additives that form part of the plastic, weighs more than any other single material in that component. Plastic is compared with each other material separately, not with all the non-plastic materials combined.
For example, a 10g carton containing 4g of plastic, 3g of aluminium and 3g of cardboard is treated as a plastic packaging component because plastic is the heaviest individual material.
A 10g component containing 2g of plastic, 5g of aluminium and 3g of cardboard is not treated as plastic because aluminium is heavier. A component containing 5g of plastic and 5g of cardboard also fails this test because plastic does not weigh more than the other material.
This distinction is important for converters developing paper-plastic, foil-plastic and other multi-material structures.
Why must each component be assessed separately?
PPT applies to each individual finished packaging component rather than to an assembled pack as a whole.
A drinks product, for example, may have separate bottle, cap and label components. A food product may include a tray, box and plastic window. Each component can have a different PPT treatment.
The point at which a component becomes finished is also important because it helps determine when the tax becomes chargeable and which business is responsible.
A component is normally finished when it has undergone its last substantial modification. HMRC defines a substantial modification as a manufacturing process that changes the component’s shape, structure, thickness or weight.
Some processes are specifically not treated as substantial modifications. These include blowing a packaging component from a preform, cutting, labelling and sealing.
This means businesses need to examine the sequence of manufacturing operations rather than simply assuming that the company completing or filling the pack will be responsible for PPT. HMRC provides specific examples showing how responsibility can fall on an earlier manufacturer in the supply chain.
What about packaging imported already filled with goods?
Imported filled packaging is an important part of the regime for international businesses.
When plastic packaging is imported into the UK already filled with goods, HMRC treats the packaging components as finished. PPT is therefore chargeable on each relevant component, with the importer generally responsible unless the rules establish that another party controls the import.
The rules can consequently affect businesses importing finished food, beverages, cosmetics, household products and other packaged goods, not only companies importing empty packaging.
An overseas manufacturer may not be the party directly liable for the UK tax. However, the UK importer may depend on that manufacturer for evidence of component weights, material composition and recycled content.
How does the 30% recycled-plastic test work?
A finished plastic packaging component containing at least 30% recycled plastic is not chargeable to PPT.
The percentage is calculated by dividing the weight of recycled plastic by the total weight of all plastic in the component. It is not calculated against the total weight of the assembled pack or all materials in the component.
For example, a component containing 2g of recycled plastic and 2g of virgin plastic has 50% recycled-plastic content and meets the threshold.
If the threshold is not met, PPT is charged on the entire weight of the packaging component, not only on its virgin-plastic content.
A 10g component containing 1g of recycled plastic, 4g of virgin plastic, 2g of aluminium and 3g of cardboard contains 20% recycled plastic. Tax is therefore due on the component’s full 10g weight.
Components meeting the 30% threshold are normally still included when determining whether a business must register.
What evidence is needed for recycled content?
HMRC assumes plastic is made from virgin material unless there is sufficient evidence that recycled plastic was used.
Businesses relying on the 30% threshold need records showing how the percentage was calculated and supporting the source and use of the recycled material.
Evidence may include:
- production specifications;
- contracts;
- production certificates and certificates of conformity;
- accounting and production records;
- relevant accreditations and traceability standards; and
- quality-assurance or third-party audits.
Records should identify the component or product line, the period covered, the source of the recycled plastic and the calculation used.
For imported packaging, evidence may come from the packaging manufacturer or from a robust supply-chain audit conducted by the importer or a competent third party.
Businesses must also carry out checks that are reasonable and proportionate to their circumstances and supply chain. The nature and frequency of those checks should reflect the risks involved.
A new assessment should be made when the specification or materials used in a component change.
Which packaging is exempt or excluded?
HMRC distinguishes between packaging that is exempt from PPT and products that are excluded from its scope. The distinction matters because some exempt packaging still counts towards the registration threshold.
The four exempt categories cover plastic packaging:
- used for the immediate packaging of licensed human medicines;
- permanently recorded as set aside for a non-packaging use;
- used as transport packaging to import multiple goods safely into the UK; and
- used as stores on international aircraft, ships and rail journeys.
Immediate packaging for licensed human medicines and packaging set aside for non-packaging uses still count towards the 10-tonne threshold. Qualifying import transport packaging and international stores do not.
Excluded products include items designed primarily for long-term storage, components that are integral parts of goods and products designed primarily to be reused for presenting goods.
Long-term storage
A plastic product can be excluded when long-term storage is its primary function and that function is more important than its packaging function.
HMRC examples include toolboxes, first-aid boxes and cases for earbuds.
The exclusion does not normally apply to packaging intended to be discarded after its contents have been consumed or have perished. Bottles, yoghurt pots, resealable food packs and ready-meal trays can therefore remain within scope.
Integral parts of goods
A plastic component may be excluded where the goods cannot reasonably be used or consumed without it and the component is expected to be discarded with or after the goods.
HMRC examples include water-filter cartridges, printer and toner cartridges and inhalers.
Simply attaching a plastic component to a product does not make it an integral part of the goods. Removable protective film, for example, can still constitute taxable packaging.
Transport packaging
The transport-packaging exemption depends on how the packaging is used, not simply on its design.
It can cover plastic crates, pallets, transport containers, reusable mail sacks, pallet wrap and retaining straps when used to import multiple goods safely into the UK.
It does not cover ordinary sales packaging around imported goods. It also does not apply to transport packaging used for UK exports or to intermediate bulk containers used to transport commodities in bulk.
What changes on 1 April 2027?
Two important changes to recycled-content calculations will take effect on 1 April 2027.
Mass balance for chemically recycled plastic
From 1 April 2027, businesses wanting to account for chemically recycled plastic in their PPT return will have to use a mass-balance approach.
Mass balance is a chain-of-custody method used when recycled and virgin feedstocks are processed together and the recycled input cannot be physically traced into a particular output.
The approach is optional in the sense that businesses do not have to claim chemically recycled plastic as recycled content. However, if they want to make that claim through mass balance, they must meet the applicable certification and supply-chain requirements. HMRC says the attributed chemically recycled plastic must be covered by a third-party certification scheme meeting its minimum requirements.
HMRC is due to publish more detailed guidance in early 2027.
Removal of pre-consumer plastic
Pre-consumer plastic waste will cease to qualify as a source of recycled content for PPT from 1 April 2027.
Until 31 March 2027, qualifying pre-consumer waste that is recovered and reprocessed can count as recycled plastic. Material returned to a manufacturing process after only minimal processing, such as shredding or grinding, is already excluded from the definition.
Manufacturers currently relying on qualifying pre-consumer waste should therefore identify affected product lines and recalculate their recycled content before the change takes effect.
A practical PPT assessment
Packaging manufacturers, converters, importers and brand owners can assess each component using the following sequence:
- Is it packaging? Check its intended function and use.
- Is it plastic for PPT purposes? Determine whether plastic weighs more than every other individual material.
- Is it a finished component? Identify the last substantial modification and the responsible business.
- Was it manufactured in or imported into the UK? Include packaging imported already filled with goods.
- Does it contain at least 30% recycled plastic? Calculate the percentage against the component’s total plastic weight.
- Can the calculation be evidenced? Connect specifications and supply-chain evidence to the relevant component and period.
- Does an exemption or exclusion apply? Consider both the component’s design and how it is used.
- Does it count towards the registration threshold? Do not assume every exempt component can be omitted.
- Will the April 2027 rules change the result? Review chemically recycled and pre-consumer material separately.
What records should businesses keep?
Registered businesses must keep PPT accounts and supporting records for at least six years from the end of the relevant accounting period. The records must support the figures reported to HMRC and be maintained by product line.
PPT compliance can therefore extend well beyond a company’s tax department. Product specifications, bills of materials, supplier documentation, recycled-content evidence, production records and import documentation can all contribute to the assessment.
The international supply chain is particularly important. A UK importer may depend on an overseas manufacturer for the evidence needed to establish the composition and recycled content of a finished component.
What should packaging companies do now?
Companies supplying packaging or packaged goods to the UK should begin with a component-level review.
They should identify which components are finished in the UK or imported, establish their material weights and recycled content, consider HMRC’s exemptions and exclusions, determine the responsible manufacturer or importer and retain evidence supporting each conclusion.
Businesses should also review their supply-chain information before April 2027, particularly where recycled-content calculations rely on pre-consumer waste or chemically recycled plastic.
PPT is not simply a question of whether a pack contains plastic. For manufacturers, converters, importers and brand owners, the outcome depends on the individual component, its materials, its function, its recycled content and the evidence supporting the assessment.
This article provides general information and does not constitute tax or legal advice. Businesses should consult the latest HMRC guidance before making compliance decisions.
