The Plastic Packaging Tax: Coming April 2022
Last updated: 5/2/21
Any packaging that does not contain 30% recycled plastic.
Additionally the new draft extends the scope to cover consumer used packaging as well as standard packaging, so things like cling film and zip-lock bags will also be taxed.
This has changed since we initially launched this hot topic. Previously, it is the first business to commercialise the packaging or film in the UK.
Now, the point that the tax is applied is at the last substantial modification, before the packaging or component is ready to be used or packed/filled.
Below are some specific examples:
- If you produce a bottle top ready to be placed on a bottle you will be liable to pay the tax.
- If you produce the preform for a bottle this will not be liable for the tax.
- If you are importing a barrier film that may be used in a multilayer film, you will not be liable for the tax.
The term “substantial modification”, is likely to be defined further. Right now, it is defined as a product or item that’s ready to be filled or used.
Yes, if you pay the tax and the item is exported or used for a non-packaging application, then it is possible to reclaim the tax.
Only the original tax payer will be able to reclaim. You may also be required to share various documentation and evidence from your supply chain.
If you have evidence to confirm that materials will be sold outside of the UK, you will be able to reduce the total volume of material that will be taxed.
This will require collaboration throughout the supply chain.
This is not confirmed, but the following criteria may be used to assess whether packaging contains sufficient recycled content to be exempt:
- Product specifications
- Supply contracts
- Production certificates and certificates of conformity
- Business accounting systems
- Accreditations and international standards
- Quality assurance audits
Currently this is unclear.
The wording of the current draft mentions that material must be reprocessed by a reprocessing facility but no longer specifies this must be at a separate site.
Both pre and post-consumer waste are considered as recycled materials.
Please note: the regulation has not yet been finalised & the information provided has been taken from initial consultations. Please check back regularly for more updates.