February 14, 2022

Article

A new Plastic Packaging Tax (PPT) is due to be introduced from 1 April 2022. The intention is to encourage greater use of recycled plastics by taxing - at a rate of £200 per metric tonne- plastic packaging which contains less than 30% by weight of recycled plastic.

PPT will be payable by a manufacturer or importer producing/importing at least 10 tonnes of finished plastic packaging in a 12-month period. The tax does not apply solely to single use consumer packaging but will apply to plastics used for the containment, protection, handling, delivery, or presentation of goods anywhere in the supply chain from the manufacturer to the user or consumer. It also includes filled plastic package, e.g. plastic bottles containing drinks.

There are specified exemptions, e.g. for the immediate packaging of licensed human medicinal products.

Packaging components going through several processes will not be taxed at each stage, rather the business that undertakes the last substantial modification before the packing or filling process will be liable for the tax.

A component is finished when it has undergone its last substantial modification. Where the last substantial modification happens as part of the packing or filling process of the packaging, the component is finished after it has undergone the last substantial modification before that one.

However, on import, PPT will be the importer’s responsibility, including where the plastic packaging is already filled with goods on importation.

Businesses which have manufactured or imported 10 tonnes or more of finished plastic packaging in the previous 12 months (you only need to look back to 1 April 2022) or which intend to manufacture or import 10 tonnes or more of finished plastic packaging within the next 30 days, must register for PPT promptly.

Plastic packaging containing 30% or more recycled plastic is not chargeable for the tax. However, it still counts towards the 10 tonne PPT registration threshold for packaging you manufacture or import in a 12 month period, and you must still keep records of it.

It is therefore clear that the introduction of PPT will require businesses using plastic packaging to establish how PPT will apply to them. Businesses should review their circumstances, and in particular:-

1. Undertake a review of supply chains,

a) make an assessment of whether and to what extent there will be a liability to PPT

b) set up due diligence procedures to avoid any risk of being held jointly and severally liable (or secondarily liable) for any unpaid Plastic Packaging Tax if any business they trade with either:

• avoids, or evades paying Plastic Packaging Tax

• does not comply with Plastic Packaging Tax requirements

2. Create systems to ensure compliance with the new record-keeping requirements

3. Decide who will be responsible for PPT compliance, giving training as needed

Please do contact me or your usual AG contact to discuss how we may be able to help.

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