The UK’s Plastic Packaging Tax has been shaped by five formal public consultations since 2018, and a Plastic Packaging Tax consultation is open now: HMRC is asking, from 18 May to 10 August 2026, whether businesses should be required to hold third-party certification to prove their mechanically recycled content claims.1GOV.UK. Plastic Packaging Tax Potential Certification for Mechanically Recycled Plastic Packaging Anyone who manufactures or imports plastic packaging can respond, and past consultations show these responses genuinely change the rules that end up in law.
The Consultation Open Right Now
The current consultation looks at mechanically recycled plastic packaging and asks whether mandatory certification would be a proportionate way to verify recycled content claims. It runs from 18 May to 10 August 2026 and includes specific questions on whether such a scheme would be workable and which standards HMRC should recognise.1GOV.UK. Plastic Packaging Tax Potential Certification for Mechanically Recycled Plastic Packaging
This matters because certification, if introduced, will change what documentary evidence you need to hold to claim the 30% recycled content exemption. At the moment, HMRC accepts a mix of production specifications, supplier certificates of conformity, accounting records, international accreditations, quality assurance audits, and Environment Agency accreditation for reprocessors.2GOV.UK. Records and Accounts You Must Keep for Plastic Packaging Tax A mandatory certification requirement would narrow that flexibility. It would also add cost, which is one of the reasons HMRC is seeking views before deciding.
The consultation sits alongside a broader effort. When the government confirmed at Budget 2024 that a mass balance approach would be available for chemically recycled plastic from April 2027, it committed to consulting separately on mandatory certification requirements to support that approach.3GOV.UK. Plastic Packaging Tax Chemical Recycling and Adoption of a Mass Balance Approach The 2026 mechanical recycling consultation appears to be part of that wider certification work.
How to Respond
Consultation documents are published on GOV.UK. They set out the proposed changes, then ask a structured list of questions. Most consultations accept responses through an online portal or by email to a dedicated address listed in the document. Submit before the closing date. Late responses are typically not considered.
Before writing anything, gather data on your own operations that speaks directly to the questions HMRC is asking. For the certification consultation, that means understanding what documentation you already hold to prove recycled content, what a mandatory scheme would cost you to maintain, and whether your suppliers, including any overseas, could comply. Responses grounded in specific figures and operational realities carry far more weight than general objections.
After a consultation closes, the government enters a review phase that can last several months. It then publishes a formal response summarising the feedback and explaining which proposals it will take forward, modify, or drop. The consultation process follows the UK Government Code of Practice, which recommends that consultations stay open for at least 12 weeks.
What Recent Consultations Have Already Changed
The July 2023 consultation on chemical recycling and mass balance produced three policy shifts that businesses need to plan for now, even where the changes take effect in 2027.
Mass Balance From April 2027
The government confirmed that businesses will be able to use a mass balance approach to calculate recycled content in chemically recycled plastic for PPT purposes.3GOV.UK. Plastic Packaging Tax Chemical Recycling and Adoption of a Mass Balance Approach Mass balance tracks recycled and virgin inputs through a production process and allocates them to specific outputs, even when the materials mix physically during manufacture. That is the only way to make chemical recycling work under the tax, because recycled feedstock blends with virgin material at the molecular level and cannot be physically traced through the output. To use mass balance, businesses will need certification from a PPT-compliant standard.
Pre-Consumer Waste No Longer Counts
Alongside the shift to mass balance, the government announced that pre-consumer waste, meaning defective products, production scrap, and manufacturing offcuts, will no longer count toward the 30% recycled content threshold.3GOV.UK. Plastic Packaging Tax Chemical Recycling and Adoption of a Mass Balance Approach Only post-consumer recycled content will qualify. If your current recycled content figures rely in part on factory scrap, you will need to raise your post-consumer input to keep the exemption once this change takes effect.
Medical Packaging Exemption Retained
The government decided not to remove the exemption for packaging used with licensed human medicines, but made clear its long-term intention is to phase it out once chemically recycled plastic becomes widely available.3GOV.UK. Plastic Packaging Tax Chemical Recycling and Adoption of a Mass Balance Approach Pharmaceutical packaging businesses should treat this as borrowed time rather than a permanent carve-out.
The Full Consultation Timeline
Five formal consultations have taken place so far.1GOV.UK. Plastic Packaging Tax Potential Certification for Mechanically Recycled Plastic Packaging
- March 2018, call for evidence: an open question about whether a tax on plastic packaging would change business behaviour and encourage recycled content.
- February 2019, initial consultation: proposed the 30% recycled content threshold, the 10-tonne registration limit, and the basic structure of the charge.
- March 2020, policy design consultation: refined how to classify multi-material components, which party in the supply chain bears liability, and how exemptions would work.
- July 2023, chemical recycling and mass balance: asked whether chemically recycled plastic should count toward the 30% threshold and whether mass balance could track that recycled content through complex manufacturing.
- May to August 2026, mechanical recycling certification: the current open consultation on whether third-party certification should be mandatory.
The 2019 and 2020 rounds produced the core rules that became Part 2 of the Finance Act 2021. The 2023 round produced the mass balance commitment and the pre-consumer waste exclusion. Each round has changed the law in ways that respondents’ evidence helped shape.
What the Tax Actually Charges
Responses are stronger when grounded in how the tax works, so the essentials are worth knowing before you write. The tax applies to plastic packaging components produced in or imported into the UK that contain less than 30% recycled plastic. A component counts as plastic packaging if it is predominantly plastic by weight and is designed to contain, protect, handle, or deliver goods.4HM Revenue & Customs. Introduction of Plastic Packaging Tax From April 2022 The rate from April 2026 is £228.82 per tonne, set in statute and uprated annually with CPI inflation.5Legislation.gov.uk. Finance Act 2021 – Charging of Plastic Packaging Tax
You must register if you have manufactured or imported 10 tonnes or more of finished plastic packaging components in the past 12 months, or expect to hit that threshold in the next 30 days.6GOV.UK. Plastic Packaging Tax Steps To Take Four categories of packaging sit outside the tax entirely: immediate packaging for licensed human medicines, transport packaging on imports (pallets, crates, pallet wrap, retaining straps), stores carried on international aircraft, ships, or rail vehicles, and components permanently set aside for a non-packaging use.7GOV.UK. Check Which Packaging Is Not Subject to Plastic Packaging Tax The current consultation does not touch registration or the rate. It focuses squarely on how recycled content is proved.