Your packaging passes the 30% recycled content test today. In April 2027 the same packaging, from the same supplier, made to the same specification, can fail it. Nothing about the product changes. What changes is which kind of recycled plastic HMRC will let you count towards Plastic Packaging Tax.
TL;DR: From 1 April 2027, pre-consumer plastic waste stops counting towards the 30% recycled content test for Plastic Packaging Tax. Only post-consumer material will qualify. Packaging that passes today can become taxable at £228.82 per tonne without any change to the product. Chemically recycled plastic gets a new mass balance route.
Two Plastic Packaging Tax Changes Land on 1 April 2027
Two changes to Plastic Packaging Tax take effect on 1 April 2027. Pre-consumer plastic waste stops counting as recycled plastic, so only post-consumer material will carry you to the 30% threshold. At the same time, chemically recycled plastic gains a formal route in through mass balance accounting, which lets recycled feedstock be attributed to finished packaging even where it has been physically blended with virgin polymer.
The second change is why HMRC is consulting now. Draft regulations were published on 6 October 2026 and the consultation closes at 11.59pm on 21 December 2026 (GOV.UK, 2026).
The pre-consumer change needs no consultation. It is already legislated, and HMRC guidance now states that "pre-consumer plastic waste will not be accepted as a source of recycled plastic for the purpose of Plastic Packaging Tax from 1 April 2027" (HMRC, 2026).
Which Plastic Counts as Pre-Consumer?
Pre-consumer plastic is waste generated during a manufacturing process that is then recovered and sent to a reprocessing facility so it can be used as a raw material. Post-consumer plastic is material the end user discards once the product can no longer be used for its intended purpose (HMRC, 2026).
The distinction clients get wrong sits one layer below that. Scrap that goes straight back into your own production line has never counted. HMRC already excludes material that "would normally be re-used in a manufacturing process to avoid it becoming plastic waste", and treats shredding and grinding as minimal reprocessing rather than recycling. In-house regrind fails the test today and will still fail it in 2027.
What changes is the middle category. Offcuts, trim and purge material sold on to a reprocessor, pelletised, and bought back as feedstock currently counts as recycled plastic. From April 2027 it will not.
Who Is Affected by the Pre-Consumer Change?
Any business that manufactures or imports 10 tonnes or more of finished plastic packaging components in a 12-month period, and leans on reprocessed pre-consumer material to clear 30%. HMRC had 5,142 businesses registered for the tax as at 13 August 2026, up from 4,927 a year earlier (HMRC, 2026).
Importers are exposed even though they generate no scrap themselves. The figure you declare comes from your supplier's certification, so if their feedstock is pre-consumer, your declaration changes in April 2027 while your purchase order stays identical. What we see most often is an importer who has never asked what kind of recycled content sits behind the 30% on a supplier spec sheet. It is the gap that caught importers when Vaping Products Duty arrived: the liability lands on whoever brings the goods in, not whoever made them.
Registration is unaffected. Packaging that meets the threshold still counts towards the 10-tonne test and still has to be reported on your return.
How Much Could Losing the 30% Threshold Cost?
The rate is £228.82 per tonne from 1 April 2026, up from £223.69 in 2025-26, and it applies to the full weight of the component rather than the virgin portion. Receipts fell 4% to £250 million last year, from £261 million (HMRC, 2026).
Take a business importing 400 tonnes of plastic packaging a year at 32% recycled content, of which 10 percentage points come from reprocessed pre-consumer material. Strip that out and the component sits at 22%, under the threshold, and the whole 400 tonnes becomes chargeable. That is 400 multiplied by £228.82, or £91,528 a year on packaging that was tax-free the quarter before.
Plenty of businesses sit close to the line. HMRC received declarations covering 2.970 million tonnes in 2025-26, of which 1.506 million tonnes (51%) met the 30% threshold and 1.107 million tonnes (37%) was taxable (HMRC, 2026). The rate has increased at every annual uprating so far, and the next one would normally be confirmed at the Autumn Budget on 28 October.
Mass Balance: The New Route for Chemically Recycled Plastic
Mass balance lets you attribute recycled feedstock to finished packaging even where recycled and virgin material have been physically mixed in production and the recycled content cannot be identified in the final product. From April 2027 it is the only way chemically recycled plastic will count towards the 30% test.
The regime sits in new sections 49A and 49B of the Finance Act 2021, inserted by the Finance Act 2026, with the conditions in the draft regulations (GOV.UK, 2026). Your supply chain has to be covered by a certification scheme whose certification bodies are accredited by a member of the Global Accreditation Cooperation. Attribution runs off a conversion factor built from material withdrawn, fuel consumed and qualifying input material, and certified businesses must keep declarations, certificates and supporting evidence for at least six years.
This is a route, not a quick fix. Certification needs a supply chain behind it, which puts it alongside the evidence trails now expected under UK sustainability reporting.
What Should You Do Before April 2027?
Start with the declarations you have already filed. You need to know, product line by product line, how much of your recycled content is post-consumer, because that is the figure that survives into April 2027.
Four things worth doing over the next two quarters:
- Ask every packaging supplier to split their recycled content figure into pre-consumer and post-consumer, in writing.
- Re-run the 30% test on each component using post-consumer content only, and list anything that drops below the line.
- Price the exposure at £228.82 per tonne so it lands in your 2027 budget rather than on a Q1 return.
- Ask your reprocessor whether they are pursuing chemical recycling certification, and for a date.
When we reviewed a client's packaging declarations this year, two of eleven product lines sat between 30% and 34% recycled content. Both are now on a watch list. One question clients always ask is whether the supplier will sort it out for them, and the answer is no, because the person who signs the return carries the penalty.
Frequently Asked Questions
Does in-house regrind count towards the 30% test today?
No. HMRC excludes material that would normally be re-used in a manufacturing process to avoid becoming waste, and counts shredding and grinding as minimal reprocessing rather than recycling. Regrind fed straight back into your line has never qualified. The April 2027 change affects pre-consumer waste that leaves your site, gets reprocessed into raw material, and comes back as feedstock.
Do I still have to register if all my packaging meets the 30% threshold?
Yes. The 10-tonne registration threshold counts all finished plastic packaging components you manufacture or import in a 12-month period, whether or not they are chargeable. You register within 30 days of crossing it and file quarterly returns showing the exempt tonnage (HMRC, 2026).
What are the penalties for getting recycled content wrong?
A late quarterly return costs £100, rising to £200, £300 and £400 for further late returns inside 12 months. Failing to register when you should have is a failure-to-notify penalty, charged as a percentage of potential lost revenue between 0% and 100% depending on behaviour (HMRC, 2026). An understated recycled content figure is an inaccuracy, which is why the supplier evidence matters.
Will the mass balance rules definitely start on 1 April 2027?
The start date and the enabling provisions are legislated. What is still open is the detail in the regulations, which HMRC is consulting on until 21 December 2026, plus the operational notices that follow. If you are relying on chemically recycled plastic to hit 30%, read the draft now rather than waiting for the final text.
Does this affect goods I sell into the EU?
No. Plastic Packaging Tax applies to packaging manufactured in or imported into the UK, so EU sales do not change your PPT position. Separate EU rules do apply to parcels, covered in our note on the EU's €2 parcel handling fee.
If you manufacture or import plastic packaging and you are not sure how much of your recycled content is post-consumer, get in touch. We can work through your current declarations line by line, model the 2027 position at the new rate, and tell you which product lines need a different supplier conversation. Our advisory and tax services cover UK indirect tax for manufacturing and import businesses.