RECOUP criticises enforcement of Plastic Packaging Tax

The tax came into effect in April 2022 and is currently applied at a cost of £217.85 per tonne for plastic packaging placed on the UK market that is not claimed to contain 30% recycled content. The plastics charity said that there have been “a number of issues” and “unintended consequences” since PPT came into effect two years ago.

Principally, it expressed concern that claims of recycled content are not being sufficiently verified or enforced, particularly for packaging (filled and unfilled) that is imported into the UK.

RECOUP said that it has seen examples of inaccurate claims made in an attempt to meet the recycled content requirement. Some claims are reportedly not technically possible or make use of the term “pre-consumer” material when it might not use any recycled content.

While there are currently calls to increase the tax, the charity said that without proper enforcement these changes will lead to further false claims and a loss of revenue for HMRC.

Steve Morgan, head of policy and infrastructure at RECOUP, said: “An incentive to include recycled content, even if it has to be a tax, is a force for good as long as it’s properly enforced. However, the UK imports around half the plastic packaging it places onto the market, and this includes packaging with claims of recycled content.

“Lack of enforcement is increasingly making the UK recyclers commercially unviable due to having to compete with cheap imports of virgin packaging and packaging with recycled content from countries with significantly lower cost base and greater access to material.

If these false claims, particularly from imported material continue, we could see a collapse of the plastic packaging recycling system in the UK as we know it, and urgent action is needed.”

Additional calls in position statement

RECOUP suggested that the situation represents an opportunity to align with extended producer responsibility for packaging (pEPR) through the inclusion of recycled content as part of the eco-modulation framework.

The charity also called for “an urgent review and overhaul” of the Packaging Recovery Note (PRN) system to provide “a more stable, commercially supportive and modulated PRN” for plastic packaging formats where targeted funding is needed the most.