Plastic Packaging TaxCaroline Bailey
Who should register and when
You must register for Plastic Packaging Tax if you’ve manufactured or imported 10 tonnes or more of finished plastic packaging components since 1 April 2022, or if you expect to do so in the next 30 days.
The 10 tonnes of plastic packaging components can be a combination of manufactured and imported packaging.
You must register within 30 days of meeting the 10-tonne threshold. You may need to pay a penalty if you do not.
What you will need:
- your Government Gateway user ID and password — If you do not have a user ID, you can create one when you register
- a customer identification number — for UK-established businesses this could be a:
- customer reference number
- Corporation Tax unique tax reference
- the type of company you are registering
- a contact name, address, phone number and email address for each company
When packaging is considered plastic
For the purposes of Plastic Packaging Tax, plastic means a polymer material to which additives or substances may have been added.
Cellulose-based polymers that have not been chemically modified, such as viscose, will not be treated as plastic for the purpose of Plastic Packaging Tax.
Other cellulose-based materials which are chemically modified, such as cellulose acetate, will be considered plastic.
Additives include materials such as calcium or dyes. When you assess the amount of plastic in a packaging component, the additives are classed as part of the plastic.
Plastics include polymers which are:
If a plastic packaging component is made from multiple materials but contains more plastic by weight (including additives which form part of the plastic) than any other substance, it will be classed as a plastic packaging component for the purposes of the tax.
The other substances which you need to consider are:
- other metals
- paper and board
- any other substance
You will need to keep records to show what substances are in plastic packaging.
Components that contain an adhesive
When you are considering if a component contains more plastic by weight and it includes an adhesive, you need to check if the adhesive is plastic. If the adhesive does not meet the definition of plastic you must not treat it as ‘any other substance’ from the ‘other substance’ list when you are working out if the component contains more plastic.
Plastic packaging components containing 30% or more recycled plastic are not chargeable for the tax. However, they still count towards the 10-tonne threshold for packaging you manufacture or import in a 12 month period, and you must still keep records of it.
For the purposes of Plastic Packaging Tax, all plastic is assumed to be made using non-recycled (virgin) material, unless there is evidence that recycled material has been used.
Recycled plastic is plastic that has been reprocessed from recovered material by using a chemical or manufacturing process. This is so it can be used either for its original purpose or for other purposes. This does not include organic recycling.
Recovered material is pre-consumer plastic or post-consumer plastic that both:
- is no longer suitable to be used in the process from which it was generated and would otherwise have been used for energy recovery (for example, by incineration) or disposed of as waste (for example, by being sent to landfill)
- has been collected and recovered for use as a material input for a recycling or manufacturing process, instead of new primary material
Pre-consumer plastic is plastic that’s recovered from waste generated in a manufacturing process and subsequently processed by a reprocessing facility.
It does not include scrap or regrind which can be reused in the process from which it was generated after only minimal reprocessing, for example shredding and grinding.
However, where waste material is recovered and requires reprocessing involving melting and extrusion into pellets at a reprocessing facility before it can be reused, it can be treated by manufacturers as recycled plastic for any process.
Post-consumer plastic is plastic that’s generated by the end user of the product. The product can then no longer be used for its intended purpose.
The consumers are:
- commercial facilities
- industrial facilities
- institutional facilities
This includes returns of material from the distribution chain.
The reprocessing of pre-consumer plastic and post-consumer plastic can be completed either at a reprocessing site or within your own premises if you have the facilities. Examples of processes involved in reprocessing can include:
This list is not exhaustive.
Packaging subject to the tax
There are 2 types of plastic packaging subject to the tax. These are packaging designed to be suitable for:
- use in the supply chain
- single use by the consumer
If your packaging is made up of several packaging components, you must account for Plastic Packaging Tax on each component.
Individual packaging components are generally manufactured separately before being assembled into a packaging unit. Examples include:
- bottles, caps and labels are manufactured separately before being assembled to make packaging units for drinks and liquids
- trays, boxes and plastic windows are manufactured separately before being assembled to make packaging units for certain foods, such as pies and cakes
Packaging designed to be suitable for use in the supply chain
You should check whether each plastic packaging component that you manufacture, or import is subject to Plastic Packaging Tax.
A plastic packaging component is a product that’s designed to be suitable for use in the supply chain, from the manufacturer of the goods to the user or consumer. It can be used alone or in combination with other products.
If the packaging component meets the definition, it does not matter if it is produced or imported for use in the supply chain of the goods, or by a consumer or user.
It must do one or more of the following functions:
- contain the goods
- protect the goods
- handle the goods
- present the goods
- deliver the goods
Examples of packaging components include plastic:
- trays used to contain and protect food, such as a ready meal tray
- film to protect goods, such as film around raw meat
- pots designed to handle and deliver products, for example yoghurt pots
Packaging designed to be single use consumer packaging
For the purposes of Plastic Packaging Tax, single use consumer packaging is any single use product designed to be used by a consumer or domestic user in performing one or more of the following functions in respect of goods or waste:
These products would be used by the consumer rather than in the supply chain.
Examples of single use consumer packaging are:
- plastic bags
- disposable cups, plates and bowls
- gift wrapping such as ribbon and sticky tape