Plastic Packaging Tax: How to Prove Your 30% Recycled Content

The UK Plastic Packaging Tax (PPT) applies at £217.85 per tonne to plastic packaging that does not contain at least 30% recycled plastic. For a business placing 200 tonnes of plastic packaging on the UK market annually, meeting the 30% threshold is worth over £43,000 per year in avoided tax. But meeting the threshold is only half the battle — you also need to prove it.

What counts as recycled content?

HMRC accepts both pre-consumer and post-consumer recycled plastic towards the 30% threshold:

• Post-consumer recycled (PCR): Plastic recovered from household or commercial waste streams after the product has been used by an end consumer. This is the most common form of recycled content and carries the clearest environmental benefit.
• Pre-consumer recycled: Plastic waste generated during the manufacturing process that is reprocessed and reintroduced into production. However, this does not include in-house regrind — scrap material that is reused within the same manufacturing process without ever leaving the factory does not count.

Chemical recycling is also accepted, provided the output is used to produce new plastic packaging. The 30% threshold is calculated by weight as a proportion of the total plastic content of each packaging component.

What evidence do you need?

HMRC does not prescribe a single form of evidence, but you must be able to demonstrate a clear chain of custody showing the recycled content in your packaging. In practice, this means:

• Supplier declarations: A written statement from your packaging supplier confirming the percentage of recycled content in each product. This should specify whether the recycled content is PCR or pre-consumer, the type of polymer, and the percentage by weight.
• Certificates of recycled content: Many packaging manufacturers can provide formal certificates, particularly if they hold certifications such as EuCertPlast, RecyClass, or ISCC PLUS (for mass-balance approaches). These carry more weight with HMRC than informal declarations.
• Purchase records and batch traceability: Documentation showing the purchase of recycled resin or pellets, linked to specific production batches of your packaging. This creates the traceability chain that HMRC may request during an audit.
• Technical data sheets: Product specifications from your supplier that include the recycled content percentage as a standard data point.

Common pitfalls

• Assuming your supplier meets the threshold without checking. Request explicit confirmation and documentation for every packaging line.
• Confusing in-house regrind with recycled content. Material that never leaves your factory floor does not count towards the 30%.
• Applying the 30% threshold across your entire portfolio rather than per component. Each individual packaging component must meet the threshold independently.
• Failing to update evidence when suppliers change or reformulate products. A certificate from last year may not reflect this year’s actual recycled content.
• Relying on verbal assurances. If HMRC audits your PPT returns, you will need documentary evidence, not a phone call.

What to do if you cannot meet 30%

If your current packaging does not meet the 30% recycled content threshold and you are paying the tax, consider the following:

• Switch to packaging with certified recycled content. The FuturePack directory lists suppliers of recycled-content packaging across multiple material types and formats.
• Reformulate with your existing supplier. Many suppliers can increase the recycled content of existing products if the customer requests it.
• Consider alternative materials. Some applications may be better served by paper, board, or other materials that are not subject to the PPT at all.
• Factor the tax into your cost-benefit analysis. For some packaging lines, it may be cheaper to pay the tax than to reformulate. But remember that pEPR eco-modulated fees add a further cost layer that may tip the balance.