Recycled content

In the UK, plastic packaging is subject to the Plastic Packaging Tax, (currently £228.82 per tonne) but packaging containing 30% or more recycled plastic is exempt. Other countries have a similar tax.

The European Union does not impose a packaging tax directly on manufacturers. Instead, Member States pay an EU levy based on the amount of non-recycled plastic packaging waste generated. This has encouraged several countries to create national plastic taxes or levies.

UK government guidance states that all plastic is assumed to be made from virgin material unless there is evidence that recycled material has been used. Therefore, the burden of proof rests on the manufacturer or importer.

1. Government currently expects businesses to keep records showing:

   • the composition of the packaging;

   • the amount of recycled plastic used;

   • supplier declarations and specifications;

   • manufacturing and traceability records;

   • any supporting certification.

   These records must be available if HMRC reviews a PPT return.

2. This process is open to errors and fraud, but there is a better way. Symphony Environmental Technologies Plc explains that if companies used d2t taggant/tracer technology (www.symphonyenvironmental.com/d2t-taggant-technology) there would be no need for all that record-keeping and administration. They would need only to have independent certification that the product had been scanned and had shown at least the required percentage of recycled content. This would be backed up by spot-checks by government inspectors.

3. The way it works is that the recycler adds the unique d2t tracer to the recyclate supplied for the manufacture of new plastic products, and a simple scan with a portable device would show whether the new product contained at least the required percentage of that recyclate. The lead time for companies to adopt this process would be no more than a month, there would be no room for fraud or error, and the cost to companies and government would be much less than the current system.