Consultation outcome

Plastic Packaging Tax — Potential certification for mechanically recycled plastic packaging

Updated 28 October 2026

1. Introduction

The UK’s Plastic Packaging Tax (PPT) was introduced on 1 April 2022 to encourage the use of recycled plastic in plastic packaging and increase demand for recycled material. The tax complements wider government reforms on packaging and waste, including packaging Extended Producer Responsibility, Simpler Recycling and the Deposit Return Scheme for drinks containers to help move the UK towards a circular economy and boost recycling infrastructure.

Previous consultations during the design and introduction of the PPT include:

• Plastic Packaging Tax: Call for Evidence (March 2018)  
• Plastic Packaging Tax: consultation (February 2019)   
• Plastic Packaging Tax: policy design consultation (March 2020)   
• Plastic Packaging Tax: chemical recycling and adoption of a mass balance approach (July 2023)

Businesses are required to register for PPT if they manufacture or import at least 10 tonnes of finished plastic packaging components into the UK within a 12-month period. The tax is charged on plastic packaging which contains less than 30% recycled plastic, currently at the rate of £228.82 per tonne. PPT is not chargeable where plastic packaging components contain at least 30% recycled plastic, subject to businesses holding sufficient evidence. Since PPT was introduced, businesses have raised concerns about the evidential requirements and validity of recycled content claims, particularly for imported packaging.

In response, the government launched a consultation on 18 May 2026 to gather evidence on the scale and nature of concerns about fraudulent recycled content claims.

1.1. Overview of consultation

The consultation sought views on the potential introduction of a certification requirement to verify use of mechanically recycled plastic in plastic packaging components, for the purposes of PPT, and whether this would be an effective and proportionate response to strengthen compliance and improve transparency.

Views were also sought on how businesses and the plastic packaging supply chain would be impacted if mandatory certification for mechanically recycled plastic is introduced, who the requirement should apply to, how it could operate in practice and possible timings for implementation.

During the consultation period, HMRC officials engaged with industry representatives and professional bodies to gather evidence and insights to inform the government’s decision on whether to proceed with the mandatory certification proposal for mechanically recycled plastic packaging. The government has worked closely across departments to ensure these proposals align with wider strategies on packaging and waste.

The government is grateful to all those who engaged with the consultation and contributed evidence, expertise and views. Having considered the consultation responses, the government intends to introduce mandatory certification for mechanically recycled plastic packaging. Certification will strengthen confidence in recycled content claims and help address industry concerns about unsupported or fraudulent claims by standardising evidence and requiring independent third-party verification for UK-manufactured and imported packaging. This will provide assurance that claims are genuine and consistently verified.

The change will be implemented from 1 April 2030. This will provide sufficient time to work with industry to develop detailed certification requirements that are proportionate, minimise unnecessary costs and administrative burdens, and recognise credible existing and overseas schemes. The additional lead-in time will help ensure certification is introduced in a way that works for businesses while also allowing time for the necessary certification capacity to be developed to support businesses operating domestic and international supply chains. Certification and market readiness will be revisited closer to the implementation date to ensure that sufficient capacity and practical arrangements are in place to support an orderly transition.

1.2. Overview of respondents

We received a total of 116 responses:

• 26 were from trade bodies/business representative organisations
• 83 were from businesses
• 1 was from a non-governmental organisation
• 6 were from other stakeholders including individuals and respondents whose category was not stated

2. Summary of responses

2.1. Overview of mechanically recycled plastic and PPT

Question 1: Which forms of recycling does your business currently rely on to meet the PPT recycled content threshold (mechanical, chemical, or a mix of both)? Please provide details.

A majority of respondents who answered this question said they rely primarily or exclusively on mechanical recycling to meet the tax’s recycled content threshold. Mechanical recycling was described as the most established and commercially available route, particularly for polyethylene terephthalate (PET), high-density polyethylene (HDPE), polypropylene (PP) and low-density polyethylene (LDPE) packaging.

A small number of respondents reported using chemical recycling or a combination of mechanical and chemical recycling. The use of chemical recycling was generally limited to specialist applications, including food contact packaging, flexible films and medical devices. Respondents said wider use of chemical recycling was constrained by cost, limited availability and uncertainty over mass balance arrangements.

Several respondents noted they cannot use or evidence the use of recycled plastic in their packaging to meet the threshold. Reasons included food contact, medical and other regulatory restrictions, limited availability of suitable material, difficulties establishing traceability, and insufficient evidence from overseas supply chains.

Question 2: To what extent does your business use mechanically recycled plastic in plastic packaging that is manufactured in or imported into the UK? Please indicate whether this represents a significant, moderate or small proportion of your total packaging volumes and, where possible, provide approximate percentages or tonnages.

Respondents reported substantial variation in their use of mechanically recycled plastic, reflecting differences in polymer, packaging format, sector and supply chain. Some respondents said it represented a significant proportion of the packaging they manufacture or import, particularly for PET and recycled polyethylene terephthalate (rPET) packaging containing recycled material. This was especially evident in rigid applications such as thermoformed trays and bottles. Respondents also referred to shrink film, stretch film, pallet wrap and some flexible packaging.

Some reported moderate use concentrated in particular product lines rather than across their whole portfolio. They said the proportion used depends on customer specifications, technical performance, material availability, price and restrictions associated with particular applications, including food contact requirements.

Overall, responses indicated substantial use of mechanically recycled plastic in packaging, although the extent of use differed considerably between businesses, polymers, packaging formats and applications.

Government response

The government notes that mechanical recycling is currently the main source of recycled plastic used in packaging, although use varies considerably by polymer, packaging format and sector. The government also recognises that the use of mechanically recycled plastic can be constrained by factors including material availability, technical performance, regulatory requirements and wider supply chain considerations.

2.2. Assessment of the potential problem and supporting evidence

Question 3: Without disclosing any specific business information or details, are you able to provide any general insight that supports the concerns raised around the prevalence of fraudulent claims or the number of businesses involved, including where these concerns come from, meaning UK manufactured or imported plastic packaging?

Respondents could not quantify the prevalence of fraudulent claims or the number of businesses involved. Some respondents said they had no direct evidence of fraud. Several respondents also noted that incomplete or inconsistent evidence should not automatically be treated as deliberate non-compliance by a business, as evidential shortcomings can arise from complex supply chains, differing reporting practices or limitations in the information available.

However, a majority of respondents raised concerns about fraud or about unsupported or potentially inaccurate recycled plastic content claims. Examples included evidence that could not be linked to a product or batch, certificates that did not demonstrate the content of the packaging concerned, double counting, and virgin or pre-consumer material being presented as post-consumer recyclate. Several respondents also noted that unsubstantiated or insufficiently evidenced claims could leave compliant businesses at a competitive disadvantage.

Concerns were more commonly raised in relation to imported packaging and packaging with complex overseas supply chains, where businesses may have limited visibility beyond their direct supplier and face differing standards and chain of custody practices. This reflects the pattern of concerns reported by respondents rather than evidence that unsupported claims are inherently more prevalent in imported packaging. Concerns about UK-manufactured packaging were raised less often and generally related to the classification of production scrap or internal regrind and product-level traceability.

Question 4: For importers of plastic packaging, what documentation do you currently use to evidence recycled plastic in packaging and are there types of evidence that are difficult to obtain or verify from overseas suppliers?

A majority of respondents who answered this question said importers use supplier or manufacturer declarations, technical data sheets, product specifications, invoices, bills of materials and certificates of conformity. Several respondents also referred to transaction or scope certificates, testing results, audit reports and production or mass-balance records.

A majority of respondents reported difficulties obtaining complete and verifiable evidence from overseas suppliers. Examples included inconsistent or unavailable documentation, documentation written in another language or based on different definitions and calculation methods. Respondents also highlighted limited visibility beyond direct suppliers and difficulty linking evidence to a specific product, component, batch or shipment. A few respondents noted that obtaining reliable evidence was easier where established supplier relationships, recognised assurance arrangements and effective traceability systems were already in place.

Respondents generally considered that clearer minimum evidence requirements, stronger chain of custody (records showing how recycled material moves through the supply chain) controls and recognition of credible international schemes could improve assurance while avoiding unnecessary duplication.

Question 5: For UK manufacturers of plastic packaging, what documentation do you currently use to evidence recycled plastic in packaging and are there types of evidence that are difficult to obtain?

Most respondents who answered this question said UK manufacturers use supplier declarations, certificates, technical specifications, invoices, purchase records and other commercial documentation. Some also referred to third-party schemes and internal production, traceability and quality management systems.

Respondents described using batch records, stock controls, production records and input-output calculations to show how recycled material is received, processed and incorporated into finished packaging. These systems were generally considered most effective where the evidence could be linked to the relevant product or production run.

The main difficulty noted by respondents was establishing a complete and reliable chain of custody between recycled feedstock and the final packaging claim, particularly where material passes through several processors or businesses.One respondent stated, “Our feedstock is sourced from approximately 50 suppliers, and the source and composition of material can change over time.” Supplier declarations were widely used, but some respondents considered them insufficient without supporting traceability or independent assurance. Commercial sensitivity and evidence from international supply chains created further challenges.

Question 6: Do you know what other countries require evidence of recycled plastic content for tax, regulatory, or environmental purposes? If yes, please describe the approach, whether it includes certification, standardised documentation, or alternative assurance methods and your views on this approach.

Spain was the most frequently cited tax example, with respondents referring to third-party certification and EN 15343, the European standard for plastics recycling traceability and assessment of recycled content. Respondents also referred to requirements or developing approaches in the EU and to schemes and standards used in other markets, including RecyClass, EuCertPlast, Global Recycled Standard (GRS), Recycled Claim Standard (RCS), Forest Stewardship Council (FSC), International Organization for Standardization and ISO-based systems.

A majority of respondents saw an international trend towards more standardised assurance of recycled content. They noted that any UK framework should recognise credible equivalent overseas schemes and remain aligned, where appropriate, with international standards and the EU Packaging and Packaging Waste Regulation.

Respondents noted that certification can improve consistency, traceability and confidence, whilst also highlighting that it may be costly or burdensome and does not by itself prove the physical content of a product. Some respondents supported a phased implementation, mutual recognition and effective oversight so that certification provides genuine assurance rather than an additional documentary burden.

Government response

The government recognises the practical challenges businesses face in obtaining and verifying evidence of recycled plastic content, particularly through complex international supply chains. Having considered the responses, the government is of the view that certification requirements will improve confidence in recycled content claims and support a level playing field for compliant businesses. The government will continue to work with industry to develop a proportionate approach that recognises credible existing schemes while minimising unnecessary administrative burdens.

Question 7: To what extent does the use of third-party certification in other sectors provide a useful model for introducing mandatory certification of mechanically recycled plastic content in packaging? Please explain your reasoning and outline any risks, challenges, or benefits you foresee.

A majority of respondents who answered this question considered third-party certification in other sectors a useful model. Forestry certification was the most frequently cited example, alongside ISO standards, existing recycled plastic schemes and approaches used in agriculture and biofuels. For example, one respondent highlighted forestry and biofuel schemes where documentary chain of custody is supported by physical and mass-balance checks. They suggested that a PPT certification scheme should similarly link documentation to verified material at defined points, rather than simply confirm that records or a certificate exist.

A majority of respondents agreed that independent certification could improve traceability, consistency and confidence in recycled content claims and help reduce fraud or greenwashing. However, some respondents noted that certification should demonstrate compliance and the movement of material through the supply chain, rather than merely confirm that a business holds a certificate.

A majority of respondents highlighted costs, administration, auditor capacity and the difficulty of requiring full chain of custody certification across complex international supply chains. Others noted that no single existing scheme is suitable for every polymer, packaging format or supply chain. Overall, respondents considered that third-party certification offers a useful model if it is proportionate, supported by robust evidence and allows multiple credible or equivalent assurance routes.

Question 8: Do you agree that mandating certification and standardising the evidential requirements could provide more certainty for businesses when seeking to claim an exemption from PPT when using mechanically recycled plastic? Please explain your reasoning.

Most respondents who answered this question agreed that standardising evidential requirements could provide greater certainty when businesses seek to demonstrate that packaging contains at least 30% recycled plastic and is therefore not chargeable to the tax. Clearer rules could reduce uncertainty about what HMRC will accept, limit inconsistent interpretations and help businesses understand the due diligence required to support a claim.

Respondents’ support was generally subject to certification being designed and implemented in a proportionate and practical way. They said certification should be practical, affordable and internationally workable, and that credible existing UK and overseas schemes should be recognised. Several said a prescribed certificate should provide a sufficient route to demonstrate compliance, rather than become an additional document layered on top of existing evidence.

Respondents also noted that certification must be linked to the underlying recycled material and the relevant product, component, batch, transaction, site or period. Some supported physical, analytical or digital verification where feasible. Others noted that fixed fees and administration could outweigh the value of the exemption for small and medium-sized enterprises (SMEs) and low-volume products. Several respondents preferred clearer guidance, standardised evidence and risk-based checks to universal mandatory certification.

Government response

The government recognises the potential benefits of greater consistency, traceability and certainty, as well as the limits of certification where underlying evidence is weak or cannot be linked to the relevant packaging claim.

The government also acknowledges concerns about affordability, auditor capacity, complex international supply chains and requirements that could duplicate existing audits, certification, supplier documentation, customs procedures or other assurance processes. Equally important is giving businesses sufficient time to prepare for any new requirements and ensuring that the arrangements are proportionate and deliverable in practice.

In developing the approach, the government will work closely with industry to consider the recognition of credible existing and equivalent overseas schemes that provide an equivalent level of assurance, and how assurance can be linked to the relevant material and PPT claim. Consideration will also be given to how the requirements can be made proportionate for smaller businesses and low-volume products, while maintaining robust and consistent evidence standards.

Question 9: For importers of plastic packaging, what challenges do you face when obtaining evidence of recycled plastic content?

Most respondents who answered this question said importers face difficulty obtaining complete, consistent and verifiable evidence from overseas suppliers. They noted that limited visibility beyond direct suppliers was a recurring concern, particularly where packaging passes through several intermediaries.

Respondents highlighted challenges arising from differing terminology, calculation methods, document formats and levels of detail, as well as supporting documentation being provided in different languages. They also reported uncertainty about the classification of recycled plastic and difficulty linking general supplier-level or site-level evidence to a specific product, component, batch, stock-keeping unit (SKU) or shipment.

Other challenges identified included commercial confidentiality, limited influence over overseas suppliers and lack of familiarity with UK rules, and the cost of gathering and checking evidence across large product portfolios. Some respondents considered that recognised international schemes, standardised declarations and clearer evidence requirements would reduce uncertainty. Some also noted that where verification costs are disproportionate, businesses may pay the tax or decline to claim recycled content that is already present.

Question 10: For UK manufacturers of plastic packaging, what challenges do you face when obtaining evidence of recycled plastic content?

Most respondents said UK manufacturers can obtain evidence through supplier declarations, specifications, invoices, purchase records, certificates and internal quality or production systems. Some reported fewer difficulties where established suppliers, controlled inputs and effective traceability arrangements were in place.

Some respondents said evidence quality varies and can be generic, incomplete or inconsistent. They indicated that manufacturers sometimes need to seek further information from suppliers, review supporting chain of custody records or undertake technical assessments, testing or audits before determining whether the evidence is sufficient to support a recycled content claim.

Several respondents advised that difficulties can arise when tracing material through recyclers, processors and businesses, or reconciling purchases with production outputs, losses, additives, internal scrap and recycled content calculations. Several UK manufacturers highlighted that they have a dependency on international supply chains and face similar challenges to importers, including limited upstream visibility, commercial sensitivity and differing standards. Respondents generally supported recognition of existing production control and traceability systems where these provide sufficient assurance.

Question 11: For importers of plastic packaging, do you foresee any barriers to implementing mandatory certification for mechanically recycled plastic packaging? Please provide specific examples or evidence of any barrier that may arise.

Most respondents who answered this question identified significant practical barriers for importers. These included limited visibility beyond direct suppliers, difficulties obtaining chain of custody information, inconsistent international documentation, language barriers, limited supplier leverage and uncertainty about whether a certificate relates to the product or shipment being imported.

Some respondents also highlighted limited availability of suitable certification schemes in some countries and for some polymers or packaging formats. A majority of respondents raised concerns that audit and transaction certificate fees, segregation requirements, systems change and managing evidence across large product portfolios could add costs. Respondents also noted that overseas suppliers may need significant time to understand the requirements, obtain certification, complete audits and adapt their systems and documentation, which could cause delays. Ten respondents raised concerns that a UK-specific model could reduce supplier choice or disadvantage importers if credible overseas arrangements were not recognised.

Several respondents also noted that importers may have limited ability to require overseas suppliers to adopt particular certification schemes or obtain certification solely to supply the UK market.

Question 12: For UK manufacturers of plastic packaging, do you foresee any barriers to implementing mandatory certification for mechanically recycled plastic packaging?Please provide specific examples or evidence of any barrier that may arise.

Most respondents who answered this question supported the objective of stronger assurance but identified barriers for UK manufacturers including audit and certification fees, additional administration, staffing and system costs, supplier engagement, evidence management and possible disruption to existing production and quality processes.

Respondents noted that the impact was expected to vary by business size, the complexity of the supply chain and the systems already in place. Businesses using recognised certification or mature traceability arrangements generally expected fewer changes, while SMEs, low-volume manufacturers and specialist or regulated packaging businesses were considered more exposed to disproportionate fixed costs.

Respondents also raised concerns about certification and auditor capacity, international alignment and duplication of existing audits. Specific concerns were raised with respect to food contact packaging and other regulated applications where there are technical constraints that certification cannot resolve.

Question 13: Do you currently use certification to support your claims for an exemption from PPT? If so, please provide any details of the costs, benefits and any drawbacks of doing so, including any associated burdens on your business.

Current practice among respondents was mixed. Some respondents said they rely on supplier declarations, specifications, certificates of conformity and internal traceability or due-diligence systems rather than formal third-party certification for the purposes of the tax. Others already use recognised schemes or accredited supplier certificates, particularly where their customers require independent assurance.

Respondents using certification schemes identified benefits, including improved traceability, stronger assurance, customer confidence and a more consistent way to demonstrate compliance. Some considered certification a logical extension of systems they already operate.

Drawbacks highlighted included fees, audits, transaction-certificate administration, supplier management, limited scheme coverage and uncertainty about what HMRC will accept. Some respondents said certification would provide greater value if it were accepted as sufficient evidence for PPT purposes and reduced duplicative documentation and checks, rather than adding to existing requirements.

Government response

The government recognises that businesses currently use a range of commercial documentation, internal traceability systems and certification arrangements. The consultation highlighted the importance of ensuring that the evidence can provide the appropriate level of assurance and be linked to the specific recycled content claim.

The government acknowledges concerns about certification costs, administration, supplier access and duplication. As the detailed framework is developed, the government will consider how existing assurance arrangements that meet the relevant requirements may be recognised and how requirements can be designed to provide robust assurance while remaining proportionate for different participants in the supply chain.

2.3. Business impact

Question 14: If certification for mechanically recycled plastic packaging were to be introduced, should it apply to all businesses claiming exemption from PPT to ensure a level playing field of evidential requirements? Please explain your reasoning for any suggestions provided.

Most respondents who answered this question, particularly recyclers, manufacturers, compliance schemes and trade associations, favoured equivalent assurance requirements for all businesses claiming exemption from the tax. They considered that businesses making equivalent recycled content claims should meet equivalent minimum standards, whether the packaging is manufactured in the UK or imported.

A majority of respondents said consistent requirements could improve confidence, reduce opportunities for fraudulent claims and protect compliant businesses from unfair competition. Several respondents mentioned that imported and domestic packaging should be subject to comparable assurance so that certification does not increase rather than reduce competitive disadvantage.

However, support was often conditional on proportionality. Respondents said that duties should reflect each participant’s role, control and access to evidence.

Question 15: Do you have any alternative suggestions, outside of certification, that could provide a robust and more efficient way of ensuring all recycled content claims are true and accurate?

Some respondents suggested alternatives to mandatory certification, including standardised supplier declarations, minimum data requirements, batch-level records, audited chain of custody evidence, material-flow or mass-balance records and clearer due diligence requirements. They considered that stronger evidence requirements, supported by targeted and risk-based compliance activity, could provide assurance without the need for mandatory certification.

Other respondents suggested that these measures could complement, rather than replace, certification by strengthening traceability and confidence in recycled-content claims.

Question 16: Taking into account the risks and challenges associated with the current evidence requirements, do you support the introduction of mandatory certification for mechanically recycled plastic packaging? Please explain your answer and provide reasoning.

Overall views reflected qualified support rather than unconditional agreement. A majority of respondents supported stronger assurance and considered that certification could improve confidence, traceability and consistency, reduce unsupported claims and create a fairer competitive environment for businesses investing in genuine recycled content.

Support was commonly conditional on the framework being proportionate, affordable and internationally workable. Respondents who supported certification generally favoured recognition of credible existing schemes, proportionate requirements for importers and SMEs, robust enforcement and sufficient transition period.

Several opposed mandatory certification on the grounds of cost, duplication or doubt that document-based certification would prove physical recycled content. These respondents preferred clearer existing evidence rules, targeted enforcement or risk-based approaches. Across the range of views, many respondents mentioned that stronger assurance should not discourage the use of recycled plastic or impose disproportionate burdens on compliant businesses.

Question 17: If not addressed elsewhere in your responses, please outline how mandatory certification for mechanically recycled plastic might affect your business if introduced. Please include detail on potential administrative burdens, operational adjustments and cost implications.

A majority of respondents anticipated additional administration and cost. Expected activities included supplier mapping and engagement, contract changes, linking evidence to the relevant product, new systems, staff training, audit preparation, keeping records and ongoing monitoring.

Impacts were expected to vary significantly. SMEs, importers, businesses that handle low volumes of plastic packaging and those with complex international supply chains expected greater challenges. Certification and audit costs were a particular concern for businesses handling small volumes or making occasional exemption claims, where these costs could be disproportionate to qualifying for the PPT exemption.

Respondents also identified potential benefits, including clearer evidence expectations, improved confidence and better protection for compliant businesses. Suggested mitigations included recognising existing schemes, using risk-based or group certification, publishing templates and guidance, and ensuring sufficient audit capacity before implementation.

Question 18: If the proposed certification requirement were to be introduced, to what extent would this affect your pricing for customers, for example, would you pass on the cost of gaining certification to the customer, or would it reduce your costs if it enabled you to claim an exemption from PPT where applicable?

A majority of respondents expected at least some certification, audit, administration and systems costs to be passed through supply chains and reflected in customer prices. Others said they might absorb costs temporarily or would have limited ability to pass them on, particularly in competitive or low-margin markets.

Several respondents did not expect the value of the recycled content exemption to fully offset certification and ongoing compliance costs. Fixed costs were considered particularly important for low-volume products.

Respondents were generally unable to provide a reliable indication of how this will affect pricing because the detailed framework, audit frequency and evidential requirements were not yet known.

Government response 

The government recognises that mandatory certification will increase costs and administrative requirements for some businesses, particularly SMEs, businesses making occasional or low-volume exemption claims, and those operating complex international supply chains, where they are not already certified. The government also recognises the importance of ensuring that any new requirements are proportionate and do not discourage the use of recycled plastic.

However, the consultation demonstrated broad support for strengthening assurance arrangements and improving confidence in recycled content claims. The government considers that there is a strong case for a more consistent evidential standard that supports a level playing field for businesses claiming the exemption and helps maintain confidence in the integrity of the tax.

Having weighed these considerations, the government intends to introduce mandatory certification for mechanically recycled plastic from 1 April 2030. The lead-in time will allow businesses to prepare for the new requirements and enable certification capacity to develop. On balance, the government considers that the benefits of stronger and more consistent assurance outweigh the additional costs and administrative burdens associated with certification.

The government will continue to work with industry and certification providers to develop the detailed framework, taking account of consultation feedback on proportionality, practical implementation and opportunities to minimise unnecessary costs and administrative burdens while maintaining robust assurance standards.

2.4. How certification would potentially operate

Question 19: Do you have any suggestions for the minimum requirements that should be included for audits? Please explain your reasoning for any suggestions provided.

Some respondents said audits should verify material provenance, chain of custody and the basis of the recycled content calculation. Suggested evidence included supplier declarations, invoices, purchase and stock records, material specifications, batch and production records, input-output calculations, certificate dates and validity, and records linking material to the relevant component or product.

Respondents also highlighted controls against double counting, the treatment of production losses and internal scrap, document retention, management of non-conformities and clear audit reports setting out scope, findings and limitations. Several said an audit should confirm the accuracy of the claim rather than simply the existence of documentation or a certificate. For example, one respondent stated, “Audits should focus on demonstrable due diligence and traceability rather than excessive documentation requirements.”

Some respondents favoured proportionate, risk-based requirements, with audit depth and frequency reflecting the complexity of the supply chain, compliance history, the role of the business and the difficulty of verifying imported evidence. Some supported initial site visits, sampling, targeted testing or unannounced checks, while others noted concerns about destructive or universal testing. Respondents also suggested alignment with recognised standards and existing schemes so that equivalent audits are not duplicated.

Question 20: In what circumstances and at what frequency should a certification scheme check the quality of audits conducted by certification bodies? Please provide reasons for your response.

Respondents proposed a range of routine oversight frequencies. Several supported annual surveillance or review, while others favoured less frequent checks for certification bodies with a strong record. Suggested methods included desktop reviews of sampled audit files, reviews of certification decisions and corrective actions, performance reviews and occasional witnessed audits.

There was broad support for additional scrutiny where risk indicators arise. Examples included complaints, repeated non-conformities, inconsistent decisions, weak audit evidence, unusual certification activity, suspected fraud, significant changes in scope or an increase in the risk presented by the supply chain.

Some respondents said oversight should align with existing accreditation arrangements and recognised standards to support competence, impartiality and consistency without duplicating assessments. The overall preference was for proportionate oversight combining routine sampling with targeted intervention where concerns arise.

Question 21: Acknowledging there are administrative burdens and costs associated with the certification process and audits, is there anything the government could do to minimise these? Please explain any suggestions fully.

Some respondents requested recognition of credible existing UK and international schemes, standards and chain of custody arrangements.

Respondents requested early guidance setting out definitions, acceptable evidence, audit expectations and reporting requirements. Some respondents suggested practical tools including worked examples for different operator types and public registers or lists of recognised schemes, certification bodies and accreditation bodies.

Some respondents supported proportionate or risk-based implementation, including fewer intensive checks for compliant businesses, simplified or group routes for SMEs, remote audits where appropriate, multi-site certification and transitional recognition of existing evidence. Other suggestions included digital reporting, reuse of data across Plastic Packaging Tax and Extended Producer Responsibility, pilots, and financial support such as grants, vouchers or subsidised initial audits.

Question 22: Do you agree that certification bodies conducting audits under a certification scheme should be accredited by a recognised accreditation body? If not, can you suggest an alternative method that would ensure standards are consistently maintained?

Most respondents who answered this question supported accreditation by a recognised accreditation body.

A majority of respondents also mentioned that equivalent overseas accreditation should be recognised where it provides comparable assurance. They mentioned that a UK-only approach could restrict capacity, duplicate existing oversight and create barriers for international supply chains. Respondents said accreditation should cover the relevant certification activity, rather than rely on unrelated general accreditation.

A small minority opposed formal accreditation because of cost and complexity or suggested alternatives such as standard evidence requirements, manufacturer responsibility and risk-based checks. Several supporters also mentioned that accreditation alone would not prove the accuracy of underlying records and should be accompanied by effective surveillance, complaints processes, enforcement and sufficient technically competent audit capacity.

Government response

The government agrees that certification must provide robust assurance that recycled content claims are accurate, traceable and supported by reliable evidence. It also agrees that certification bodies should be competent, independent and subject to appropriate accreditation and oversight by UKAS or an overseas equivalent.

The government recognises concerns about the potential for duplicate audits and certification requirements, particularly for businesses already participating in established assurance schemes or operating across multiple markets. While it is important that businesses claiming the PPT exemption are subject to a consistent assurance framework, the government will consider how existing assurance arrangements, recognised standards and overseas accreditation may be taken into account where they provide equivalent assurance.

The government agrees that there is not a compelling case to require all members of a supply chain to use the same certification scheme, provided all schemes meet the minimum agreed standards. This approach aligns with the treatment of chemically recycled plastic and the use of an MBA. Rather than introducing a single UK scheme, the government will introduce a set of minimum requirements that different schemes can adopt. This is to allow flexibility in scheme selection, while still ensuring consistency, credibility and traceability across the supply chain. It will also reduce the administrative burden and cost to businesses of having to be part of more than one scheme because they are part of several different supply chains.

The detailed framework, including audit scope and frequency, oversight arrangements, recognition processes and transitional arrangements, will be developed through further engagement with industry, certification providers and accreditation bodies. This will include consideration of proportionate, risk-based approaches that minimise unnecessary administrative burdens while maintaining confidence in recycled content claims and the integrity of the tax.

2.5. Timing

Question 23: Do you agree with the government’s proposal on implementing mandatory certification for mechanically recycled plastic? Please provide reasoning for your response.

A majority of respondents expressed a mixed or conditional view, depending on how the certification framework would be designed and implemented. Most supported improving confidence in recycled content claims, strengthening traceability, reducing unsupported claims and creating more consistent evidential requirements.

Respondents who supported the proposal said certification could create a more level playing field and provide greater certainty for businesses investing in genuine recycled content supply chains. However, a majority of respondents made their support conditional on proportionality, affordability, international recognition, practical evidence routes for importers and SMEs, and clear guidance issued well before implementation.

Fifteen respondents opposed the proposal, nine of which were SMEs. The respondents represented a mix of manufacturers, importers, recyclers, distributors and trade bodies. Their concerns focused on cost, administration, duplication and whether a universal certification requirement would address weaknesses in the underlying evidence. Most of these respondents supported stronger assurance in principle but questioned whether a universal certification requirement was the most proportionate way of achieving it. They generally focused on cost, administration, duplication and doubts that certification would resolve weaknesses in underlying evidence. Some respondents favoured clearer existing evidence requirements or targeted enforcement instead. Across all positions, respondents noted that the final framework should recognise credible existing arrangements and avoid disadvantaging compliant businesses. One respondent stated, “Mandatory certification adds cost, complexity and duplication without solving the underlying issue.”

Question 24: If the government were to proceed with mandating certification for mechanically recycled plastic, when do you think this change could be implemented from? Please include views on the time required for businesses to comply with the proposed change, providing specific examples or evidence where possible.

Views ranged from immediate implementation to implementation in 2035.

Among the 68 respondents who expressed a view on timing, 15 favoured implementation within 12 months and 23 favoured implementation within 12 to 24 months. The remaining respondents favoured a longer lead-in time, with 19 suggesting 2 to 3 years or implementation in 2028 or 2029, and 11 suggesting 2030 or later.

Respondents also proposed April as the preferred month for implementation.

Respondents said businesses would need time to review supply chains, engage suppliers, obtain certification, update contracts and internal systems, train staff and manage existing stock. Longer lead times were particularly associated with international supply chains, limited scheme availability and the need to build certification and auditor capacity.

A recurring theme was that implementation should not be rushed or retrospective.

Overall, the responses supported a managed transition, with the readiness of businesses and the certification market considered alongside any fixed date.

Government response

The government recognises that stronger assurance for mechanically recycled plastic packaging would increase confidence in recycled content claims, improve traceability and consistency, and support a level playing field.

The government recognises cost, administrative and duplication concerns, particularly for SMEs and international supply chains. Requirements should be proportionate, consider the recognition of credible UK and overseas schemes, ensure sufficient capacity and allow time to prepare.

Having considered the consultation responses, the government intends to implement mandatory certification for mechanically recycled plastic packaging from 1 April 2030. The government will work closely with industry to develop the detailed requirements to ensure they are proportionate and deliverable in practice. Certification and market readiness will be revisited closer to the implementation date to ensure that sufficient capacity and practical arrangements are in place to support an orderly transition.

Question 25: What steps could the government take to help businesses prepare for the implementation of a mandatory certification requirement for mechanically recycled plastic? We welcome suggestions that address practical implementation, industry readiness, and transitional support.

A majority of respondents noted the need for early certainty on the certification framework, acceptable evidence and recognised schemes. They considered that detailed requirements would need to be published well before implementation so businesses can map supply chains, engage suppliers, revise contracts and adapt systems.

Tax advisers, compliance schemes, trade associations and larger businesses highlighted the importance of publishing recognised schemes, evidence requirements and practical guidance well in advance of implementation. Requested support included guidance written in plain English, worked examples for importers and regulated sectors, standard declarations and evidence templates, webinars, training, digital portals or registers, and published lists of recognised schemes, providers and accreditation bodies. Respondents also requested clear information for overseas suppliers and role-specific guidance explaining what each participant in the supply chain must hold or provide.

Some respondents supported pilots, industry working groups, phased implementation and soft-landing arrangements. Some suggested transitional recognition of existing evidence, protections for businesses that have reasonably relied on credible evidence and carried out checks in good faith, as well as targeted support for SMEs. Respondents consistently linked successful implementation to sufficient certification and audit capacity and to avoiding duplication with existing packaging and environmental reporting.

Government response

The government recognises that businesses need clarity sufficiently in advance to engage suppliers, update systems and obtain appropriate assurance.

The government will continue to work with industry ahead of 1 April 2030. This engagement will inform future guidance, communications and implementation planning, including consideration of practical examples, recognised assurance arrangements, certification capacity, and measures to minimise unnecessary burdens. Specific support measures will be confirmed through the detailed design process and are not determined by this response document.

3. Assessment of impacts

Question 26: Do you have any comments on the assessment of impacts in the Tax Impact Assessment?

A majority of respondents who answered this question considered that the Tax Impact Assessment should provide a fuller assessment of the costs, benefits and risks across different business types, supply chains, packaging formats and sectors.

SMEs, importers, businesses operating complex international supply chains, and respondents from some regulated sectors considered that the assessment may understate certification and audit fees, supplier engagement, evidence gathering, record keeping, staff time, system changes and ongoing compliance costs. They also highlighted the cumulative interaction with Extended Producer Responsibility and the EU Packaging and Packaging Waste Regulation.

Wider risks identified included certification capacity, reduced availability of certified recyclate, supplier withdrawal, costs being passed to customers and businesses choosing virgin plastic or paying the tax where certification is uneconomic. Respondents also identified potential benefits, including stronger traceability, reduced unsupported claims, fairer competition, improved confidence and support for legitimate recycled material and domestic recycling investment.

Overall, respondents asked government to compare the additional assurance delivered by mandatory certification with the full implementation cost and the cost of the current system. They also asked for the assessment to reflect impacts on public bodies, enforcement resources, material availability, and international operability.

Government response

The government recognises concerns that the costs and wider impacts of mandatory certification may vary significantly across different sectors and supply chains, and that these impacts may be greater for SMEs, importers, businesses handling small volumes of plastic packaging or making occasional exemption claims and those managing complex international supply chains.

The government will update the impact assessment as the detailed framework is developed and more information becomes available on certification scope, audit frequency, scheme recognition and implementation requirements. This work will consider both costs and benefits, including the administrative burdens and costs passed through the supply chain, certification capacity, interaction with other packaging reforms, effects on recycled material use and the potential benefits of stronger confidence, reduced unsupported claims and fairer competition.

Having considered the consultation evidence, the government is of the view that stronger assurance is justified but will continue to work with stakeholders to ensure the framework is proportionate and minimises unnecessary costs and admin burdens.

4. Next steps

The government has considered the consultation responses and intends to introduce mandatory certification for mechanically recycled plastic packaging from 1 April 2030. The government considers that this implementation date provides sufficient time to develop a practical and proportionate framework, while allowing businesses, certification providers and wider supply chains to prepare for the change.

This change will also align with previously announced changes for chemically recycled plastic. Mandatory certification for most chemically recycled plastic is planned to be introduced alongside the introduction of a MBA from 1 April 2027. Pre-consumer waste will also no longer be classified as a source of recycled plastic for PPT purposes. Certification supports this change by providing independently certified evidence from a third-party certification body of the source of recycled material used in chemically recycled plastic packaging.

Ahead of implementation, the government will continue to engage with businesses, trade associations, certification providers, representative bodies and other stakeholders to develop the detailed design of the certification framework. This will build on the approach taken to the introduction of a MBA, where detailed engagement with stakeholders helped inform the changes due to take effect. This work will consider issues raised during the consultation, including the recognition of credible existing assurance arrangements and equivalent overseas schemes, audit and accreditation requirements, evidential standards, certification capacity, and measures to minimise unnecessary costs and duplication.

The government will also use the evidence provided through the consultation to inform further policy development, implementation planning and the assessment of impacts. This will include consideration of costs and benefits for different business types, interactions with other packaging reforms, the operation of domestic and international supply chains, and the potential effects on the use of recycled plastic.

As the detailed framework is developed, the government will consider the guidance, communications and other support needed to help businesses prepare for implementation. Specific design features and support measures will be confirmed through the detailed policy development process.

The government is grateful to all those who responded to the consultation and contributed evidence and views which have informed its decision.

Annex: List of stakeholders consulted

The government is grateful to the individuals, importers, manufacturers and organisations that submitted the 116 responses to the consultation.

A Plastic Planet

Acorn Labels Ltd

AG Barr plc

Arla Foods Ltd

Association of British HealthTech Industries (ABHI)

Association of Manufacturers of Domestic Appliances (AMDEA)

AVA: The Vending & Automated Retail Association

Aylesbury Granulation

Azets

B. Braun

Bantam Materials UK Ltd / Prevented Ocean Plastic

Bayer Plc

Beiersdorf AG

Beyondly

Beyondly Global Ltd

Biffa Group (including Biffa Polymers, EsterPET and ny )

Bonzo Band Limited

British Aerosol Manufacturers’ Association

British In Vitro Diagnostics Association (BIVDA)

British Plastics Federation

British Retail Consortium (BRC)

British Soft Drinks Association (BSDA)

Carlsberg Britvic

Carlton Packaging

Cedo Ltd

Centre for Economic Transition Expertise (CETEx) at the London School of Economics (LSE)

Charpak Ltd

Chartered Institution of Wastes Management

Chemical Industries Association (CIA)

Cirrus Plastics

Clean Globe UK Co. Ltd

Confederation of British Industry (CBI)

Croydex

Danish Crown Ltd

Derby Plastics

Ecosurety

Emmi UK Limited

Environmental Services Association

Enva

Fishy Filaments Ltd (trading as 0rCA®)

Food & Drink Federation (FDF)

George at Asda

INEOS O&P UK

Institute of Chartered Accountants in England and Wales (ICAEW)

Institute of Materials, Minerals and Mining (IOM3)

ISCC System GmbH

Kordis Limited

Lancaster University Management School - UKRI-Plastic Packaging in People’s Lives project

MCO Consultancy/Scanpack Ltd

Menzies LLP

Metal Packaging Manufacturers Association (MPMA)

Multivac UK Ltd

Nestlé

Orean Personal Care

Pack IDS Ltd

Polystar Plastics Ltd

Premier Foods

ProAmpac

Provision Trade Federation (PTF)

Q Medical Technologies Ltd

RECOUP

REDcert GmbH

Recycled plastics uk

Richmond Containers CTP Ltd

Roberts Mart & Co Ltd

SCS Standards and Assurance Systems

Sekisui Jushi Strapping BV

Shellworks

Sustainable Materials Innovation Hub, University of Manchester

Symphony Environmental Technologies Plc

Tesco

The Chartered Institute of Taxation

The Compost Bag Company Ltd

The Foodservice Packaging Association (FPA)

The Industry Council for Packaging & the Environment (INCPEN)

The National Farmers’ Union

Tosca Services UK Ltd

UK Steel (a trading name of EEF Limited / Make UK)

United Kingdom Accreditation Service (UKAS)

United Kingdom Lubricants Association Ltd (UKLA)

Valpak

Veolia UK

Viridor

West London Waste Authority (WLWA)

The government also received 22 responses from individuals who responded in a private capacity and wished their responses to be confidential.