PPT was introduced in April 2022 to encourage businesses to use recycled plastic in plastic packaging manufactured in or imported into the UK. PPT is not chargeable on plastic packaging containing 30% or more recycled plastic.  

In a consultation document published in May 2026, the government said that UK businesses and trade organisations had "raised concerns about the validity of some recycled plastic claims, especially for imported packaging". The government welcomed feedback on the scale of the problem and whether mandatory certification would be an effective and proportionate response to it.  

In its response to the consultation (ICAEW Representation 53/26), ICAEW has expressed support for the objective of ensuring that recycled-content claims are accurate and that compliant businesses are not undercut by unsupported claims. However, ICAEW is not yet persuaded that a universal mandatory certification requirement is the proportionate response. 

ICAEW members report that PPT compliance is already disproportionately costly relative to the liability – in some cases the cost of compliance exceeds the tax itself. If the combined cost of using recycled plastic and demonstrating eligibility for relief exceeds the cost of simply paying PPT, businesses may choose not to use recycled plastic, undermining the policy’s purpose. Before adding a new mandate, the government should make better use of existing data and obligations alongside more targeted compliance on imports, where the government's concerns are focused. 

If the government decides to continue with a certification requirement, ICAEW recommends that it: 

• builds on a competitive market of accredited schemes and bodies; 
• aligns with and follows the framework being developed for chemically recycled plastic; and
• allows a realistic lead-in time that does not clash with the other PPT changes planned for April 2027, including allowing businesses to use a mass balance approach to account for chemically recycled plastic used to make plastic packaging for the purposes of PPT.