Guidance

Guidance for certification scheme operators

Published 28 August 2026

1. Who should read this guidance

You should read this guidance if both of the following apply:

• you operate, or are looking to establish, a certification scheme
• you want businesses to be certified under your scheme to use a mass balance approach for Plastic Packaging Tax purposes

To do this, you must:

• set certification requirements that meet the minimum requirements
• approve and oversee accredited certification bodies
• have effective processes for investigating and responding to non-compliance
• keep mandatory records
• run an electronic register
• support HMRC verification activity

2. Setting the certification requirements and overseeing the certification bodies

The certification scheme you operate will set the requirements that businesses must meet. It is optional to create a scheme that meets the Plastic Packaging Tax requirements.

Certification bodies will assess businesses against the requirements you set and make certification decisions. Certification bodies must also be accredited by signatories to the Global Accreditation Cooperation Incorporated Multilateral Recognition Arrangement. In the UK, this is the United Kingdom Accreditation Service.

It is your responsibility to make sure that the certification bodies assessing businesses meet these requirements.

3. What investigation and enforcement powers certification scheme operators need

You must have procedures to investigate a business where there is evidence that they’re not meeting the requirements.

This evidence can come from:

• HMRC
• certification bodies
• other certified businesses
• other credible sources

You should tell HMRC about any information which may lead to a business losing certification.

To protect the integrity of the certification system, you must have and use powers to conduct investigations.

You must also develop risk indicators and provide guidance on how to conduct risk assessments.

3.1 What investigation and audit activities should certification bodies in your scheme do

You must require certification bodies to:

• assess business management processes as part of certification and annual audits
• operate a risk-based approach to ongoing monitoring
• investigate suspected non-compliance

Read the other documents in this guidance to learn more about what certification bodies have to do.

4. How to deal with non-compliance

If a business does not meet the requirements, you must be able to:

• require businesses to take corrective actions
• suspend certifications
• withdraw certifications
• reinstate certifications

You must decide what the conditions for re-certification are when a business has their certification suspended or withdrawn for:

• not complying with the minimum requirements
• fraud

5. What records you need to keep

You must keep records on:

• certified businesses
• certification decisions
• certificates issued
• audit reports and audit results
• surveillance audit reports
• investigation outcomes
• accreditation information
• electronic register information

You must keep these records in writing (including in electronic form) for 6 years.

5.1 Providing a register of certified businesses

You must provide an electronic register that HMRC and businesses can use from 1 April 2027. This is an electronic system that holds information about a business’ certification status.

The electronic register must include:

• the full name of each certified business
• business addresses
• certificate numbers
• what products are covered by the certification
• copies of certificates

You must update the register as soon as possible following decisions and audits. This should include details of any certification:

• suspensions
• withdrawals

This will make sure HMRC and other users can verify a business’ current certification status.

You must keep these records in writing (including in electronic form) for 6 years.

6. What information HMRC may ask for

You must keep records and processes so HMRC can check evidence supporting Plastic Packaging Tax exemption claims.

We may ask you for:

• certification status
• certificates issued
• audit outcomes
• suspension or withdrawal decisions

HMRC may also ask you to confirm if an attribution declaration or certificate is genuine.