Possibly, for mechanically recycled content—but it is not yet a requirement. HMRC’s 2026 consultation considers whether manufacturers and importers should need certification to claim the Plastic Packaging Tax (PPT) exemption for packaging containing at least 30% recycled plastic. The government has not set out a final decision or start date in the consultation. A separate certification requirement is already planned for businesses using mass balance to count chemically recycled plastic for PPT from 1 April 2027.
What certification rules apply now?
The Plastic Packaging Tax began on 1 April 2022. Qualifying plastic packaging containing at least 30% recycled plastic is exempt from the tax, and a business claiming that exemption must retain evidence to support its claim. There is no test available to verify recycled content directly in the material, so verification relies on chain-of-custody evidence showing where the recycled plastic came from and that it was included in the packaging. HMRC’s consultation on mechanically recycled plastic describes the evidence and policy questions.
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This tax evidence requirement is not a rule that every plastic package must display a recycled-content certificate. The question under consultation is whether certification should become necessary for businesses claiming the PPT exemption based on mechanically recycled plastic.
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What is HMRC considering for mechanically recycled plastic?
HMRC’s 2026 consultation asks whether UK manufacturers and importers should have to obtain certification when claiming the exemption for packaging containing at least 30% mechanically recycled plastic. It seeks evidence on the risk of inaccurate or fraudulent claims, whether certification would be effective and proportionate, which businesses would be affected, how a requirement could operate, and when it might begin. Responses are intended to inform the government’s decision; the consultation does not itself make certification mandatory or announce an implementation date. HMRC’s consultation sets out these questions.
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The scale of exemption claims helps explain why HMRC is examining evidence and verification, but it should not be mistaken for proof of wrongdoing. HMRC cites its August 2025 tax statistics: 51% of plastic packaging tonnage manufactured in or imported into the UK in 2024–25 that was recorded as not taxable was declared exempt because it contained at least 30% recycled plastic. That is a share of declarations, not a measure of proven fraud or confirmation that each claim was accurate. HMRC also says it has very little evidence to substantiate concerns about widespread fraud, while noting the practical challenge of checking large volumes of variable evidence across complex international supply chains. The consultation discusses the verification problem, and HMRC’s Plastic Packaging Tax statistics provide the tax data.
How the separate chemical-recycling rule differs
For chemically recycled plastic, the government has already set a distinct policy change: from 1 April 2027, businesses may use mass balance to attribute chemically recycled material in packaging for PPT purposes. Using mass balance is optional. If a business does not use the method, chemically recycled plastic counted through mass balance is treated as virgin plastic for the tax. To use the method, the relevant supply chain must be covered by a third-party certification scheme that meets the tax’s minimum requirements. Businesses from the chemical recycler through the packaging converter need certification for the activities they carry out. HMRC’s mass-balance policy paper and mass-balance guidance explain the route.
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Evidence and controls under mass balance
Businesses using this route need valid certificates and attribution declarations, must check their suppliers’ certification and declarations, and must retain records for six years. The guidance requires a three-month, site-level accounting period with no negative balance at any point. It also sets rules for excluding fuel from attribution in relevant processes and using site-specific conversion factors when calculating attributed recycled content. HMRC’s guidance details these controls.
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An importer that only imports finished packaging made using mass balance does not itself need certification under this route. It must, however, check that the supply chain has been certified and hold evidence from its supplier. Missing or invalid certificates or attribution declarations can mean the importer cannot use the attributed chemically recycled content on its tax return. HMRC’s importer guidance sets out these checks.
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What businesses should watch if certification is proposed
The consultation leaves important design choices open. For manufacturers, importers, packaging buyers and construction businesses handling packaged goods, the practical impact would depend on the final rules—not just on whether certification is required in principle.
- Who must be covered: UK manufacturers, importers, or both.
- What evidence qualifies: the chain-of-custody documentation and independent checks that would support a claim.
- Which schemes count: whether existing certification schemes could meet any future requirements.
- Cost and administration: the burden on businesses, particularly where supply chains extend overseas.
- Timing: the start date and any transition arrangements.
These are matters raised for consideration in the consultation, not settled features of a mechanically recycled-content certification scheme. The future proposal should also be kept separate from packaging producer-responsibility rules: those form a different compliance framework and do not, by themselves, establish recycled-content certification requirements for PPT. The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 establish that separate regime.
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