Plastic Packing Manufacturers and importers
Manufacturers and importers of plastic packaging having less than 30% recycled plastic content will be subject to the UK’s Plastic Packaging Tax (“PPT”), which will be levied at a rate of £200 per metric tonne if specified criteria are fulfilled.
When packaging is considered plastic
Plastic is defined as a polymer material to which additives or substances have been added for the purposes of the Plastic Packaging Tax.
This excludes cellulose-based polymers that have not been chemically altered.
Materials like calcium and dyes are examples of additives. The additives are classified as part of the plastic when calculating the quantity of plastic in a packaging component.
Plastics include polymers which are:
If a plastic packaging component is constructed of many materials but includes more plastic (including additives that are part of the plastic) by weight than any other item. For tax reasons, it will be classified as a plastic packaging component.
Other substances you should consider:
- Other Materials
- Paper and board
- Any other substance
You will need to keep records to show what substances are in plastic packaging.
The tax does not apply to plastic packaging components that comprise 30% or more recycled plastic. They do, however, count against the 10-tonne threshold for packaging you make or import in a calendar year, and you must keep track of it.
All plastic is deemed to be manufactured from virgin (non-recycled) material for the purposes of the Plastic Packing Tax. Unless documentation of the utilisation of recycled materials can be found.
Plastic that has been reprocessed from recovered material through a chemical or industrial process is known as recycled plastic. This allows it to be utilised for its intended function as well as for additional reasons. Organic recycling is not included in this.
The recovered material is pre-consumer plastic or post-consumer plastic. To be considered as recovered material, the plastic must have both:
- Been collected and recovered for use as a material input for a recycling or manufacturing process, instead of new primary material
- Otherwise been used for energy recovery or disposed of as waste, for example, by being sent to a landfill or for incineration.
Pre-consumer plastic is plastic that is recovered from waste generated in a manufacturing process and subsequently processed in a repossessing facility.
It does not include plastic that is reused, or capable of being reused, in the same process from which it was generated or recovered. This is often known as scrap or regrind.
Waste material factored into the production process to be ground or melted before being reused in the same process. To make the same or similar products is not classed as recycled material for the purpose of the tax.
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 pre-processing of pre-consumer and post-consumer plastic can be completed either at a reprocessing site or within your own premises if you have the facilities. Examples of processing involved in reprocessing can include:
- Grinding, unless the plastic is reused in the same manufacturing process in which it was generated as scrap from which it was recovered, to make the same or similar products or packaging components (sometimes called `regrind or `scrap`) – this is not classed as pre-consumer plastic the purposes of the tax
Packaging subject to 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. Example include:
- bottles, caps and labels are manufactured separately before being assembled to make packaging unit 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 try
- 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 purpose 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 wrappings such as ribbon and sticky tape