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UK: Plastic Packaging Tax comes into force on April 1

Manufacturers need to check if they are liable for the Plastic Packaging Tax (PPT). From the date manufacturers become liable for the tax, they have 30 days to register.

As reported by take-e-way on September 22, 2021, the "Plastic Packaging Tax" (PPT) will come into force on 01.04.2022. However, the information is subject to change until legislation is passed by Parliament. They will be updated on an ongoing basis.

Manufacturers must check if they are liable for PPT. From the date manufacturers become liable for tax, they have 30 days to register. No one is required to file a PPT tax return or pay the tax until July 2022 but may need to register before then. There is no information yet on penalties or enforcement for non-compliance.

Regarding our Sept. 22, 2021 report on the upcoming Plastic Packaging Tax for companies with more than 10 tons of primary, secondary or transit packaging in a year that contains less than 30% recycled content, there is a new update from HMRC (the UK's tax, payment and customs authority) that should provide clarity on the tax, including details on packaging both in and out of scope.

 

Packaging in and out of scope of Plastic Packaging Tax

Plastic packaging designed for use in the supply chain

This is packaging designed to be used in the supply chain from the manufacturer to the user or consumer. It is used for the containment, protection, handling, delivery, or presentation of goods.

If the packaging component meets this 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.

Examples of items of this type, that are subject to the tax, include:

  • bottles designed for single use (even if they can be refilled and reused)
  • bottle tops or caps
  • labels designed to present the goods and describe the contents of a product

 

Plastic packaging designed as single use consumer packaging

This is packaging designed to be used once by a consumer or domestic user in containing any item or waste.

Examples of items covered by this category of products, that are subject to the tax, include:

  • plastic bags including:
  • carrier bags
  • food bags (such as sandwich bags)

 

Plastic packaging where the primary function is for storage

Examples of items of this type, that are subject to the tax, include:

  • single use bottles, such as for:
  • soft drinks
  • disposable pots and tubs, such as:
  • yoghurt pots

 

Plastic packaging that is an integral part of the goods

Examples of items of this type, that are subject to the tax, include:

  • ready meal trays
  • pots for ‘food on the go’

 

Plastic packaging to be reused primarily for presentation

Examples of items of this type, that are subject to the tax, include:

  • crates for food, such as those for fruit and vegetables
  • single use meal trays, such as those used on aeroplanes and in schools

 

Plastic packaging permanently set aside for a non-packaging use

Examples of items of this type, that are subject to the tax, include:

  • ready meal oven trays
  • microwave food pouches

 

Transport packaging

Examples of items used to import goods into the UK that are subject to the tax are:

  • crates that act as primary or secondary packaging, and are used for transporting goods into the UK for delivery to a consumer or supplier (this includes items such as fruit and vegetables)
  • transport packaging:
  • used to transport goods within the UK
  • manufactured in the UK
  • imported into the UK as goods in their own right
  • used to import a single good into the UK
  • large containers used to import alcohol to be bottled

 

The full list by HMRC with examples can be found here.

HMRC is hosting another round of PPT webinars, providing an opportunity to hear first-hand about the tax and ask questions directly to HMRC staff. Registrations are open here.

If you would like to know more about this topic, please contact Ramona Brunner via international@take-e-way.de or +49/40/750687-117.

For more information on our international compliance services related to the placing on the market of electronic equipment, batteries/rechargeable batteries and packaged products or packaging, please click here: https://www.take-e-way.com/international-compliance/

Sebastian Siebert
Contact

Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

beratung@take-e-way.de

Christoph Brellinger
Contact

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

presse@take-e-way.de

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