Plastic Packaging Tax: £228.82 a tonne, the tests and the bill

Plastic Packaging Tax is created by Part 2 of the Finance Act 2021, has been in force since 1 April 2022 and is run by HMRC.

Its purpose is written into the test that decides the charge: a component escapes the tax only if at least 30% of its plastic is recycled.

The tax works per component, not per pack: HMRC’s guidance treats a bottle, its cap and its label as separate components, each with its own weight and recycled share.

A multi-material component is plastic only if plastic is the heaviest substance by weight; where it is, the whole component is weighed.

HMRC’s own example is a 10-gram component with 4 grams of plastic and 6 grams of other materials, none heavier than the plastic: all 10 grams count.

Biodegradable and compostable polymers count as plastic.

Glass, metal, paper and wood packaging sits outside the tax, though not outside packaging EPR, which covers every material.

Section 45(1) charges tax at £228.82 per metric tonne of chargeable components of a single specification.

Section 104 of the Finance Act 2026 substituted that figure for £223.69, for components produced in, or imported into, the UK on or after 1 April 2026.

Section 45(2) charges part of a tonne proportionately.

The rate follows the date of production or import, not the date of the return, so a January to March 2026 return filed in April still uses £223.69.

Cite the revised section 45, not the Act as enacted: the enacted text prints a superseded rate, and section 104 on its own is the amending provision, not the charging one.

The rate has changed every 1 April since 2023, so a 2027/28 budget should not assume £228.82 will hold.

£223.69 is the superseded rate still most often quoted.

The test that applies today is section 47(1)(a): a finished component is chargeable if its recycled plastic, measured by weight, is less than 30% of the total plastic in it.

A component at exactly 30% is not chargeable.

The percentage is of the plastic, not of the component: 2 grams recycled and 2 grams virgin among 6 grams of aluminium and card is 50% recycled, not 20%.

When the charge applies it falls on the whole component.

Section 47(2) reverses the burden: a component is taken to fall below 30% unless it is shown that it does not.

With no evidence, a component with 40% recycled content is taxed as if it had none.

HMRC’s records guidance says the evidence must show how the percentage was worked out, prove recycled plastic was used, tie it to dates and a product line, and confirm the source; a new specification needs new evidence.

Scrap and regrind put straight back into the process after minimal reprocessing are not recycled plastic, and until 31 March 2027 reprocessed pre-consumer waste can be.

Section 105 of the Finance Act 2026 lets attributed recycled plastic count towards the 30% test: plastic to which recovered material has been attributed under a chemical recycling certification scheme using a mass balance process.

Section 106 removes pre-consumer plastic from the definition of recycled plastic.

Section 107 brought section 105 into force at Royal Assent only for making regulations; the rest of it, and all of section 106, come into force on 1 April 2027.

For many converters the second change is the bigger one: a component that clears 30% today on pre-consumer recyclate can become chargeable with nothing about it changed.

The checklist before April is to identify every line whose 30% depends on pre-consumer content, and to check any mass balance claim against the scheme rules once they are made.

Regulation 33 of the Plastic Packaging Tax (General) Regulations 2022 makes a return due no later than the last working day of the month after the accounting period ends.

HMRC’s return guidance says returns are made four times a year, and weights go on the return in kilograms, rounded down.

Errors are corrected within four years of the original due date (regulation 35).

A late return may bring an HMRC estimate and penalties, and late payment carries interest.

Accounts and records are kept for at least six years from the end of the accounting period, product line by product line.

Plastic Packaging Tax need not be shown on invoices; if a manufacturer raises its price to cover it, VAT is charged on the whole new price.

Most Plastic Packaging Tax errors come from an out-of-date rate, a misread of the 30% test, or an assumption that someone else in the chain is paying.

Four mistakes cost money most often: taking the percentage of the whole component instead of the plastic; relying on a supplier’s word without evidence that covers the specification and dates; leaving recycled lines out of the 10-tonne count; and forgetting the packaging around imports.

Each answer names the section that settles it.

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