Recycled plastic packaging tax exemption evidence
Before treating imported packaging as meeting the 30% recycled-plastic threshold, obtain manufacturer evidence or a robust supply-chain audit. The records must support the calculation, recycled material source and relevant production runs or imports. Agree the evidence pack before ordering with Cambridge China Bridge.
Define what the evidence must prove
The threshold is at least 30% recycled plastic by weight of the total plastic in the packaging component. Ask for a calculation showing recycled plastic weight divided by total plastic weight, with the underlying records. Do not use the weight of the packaged goods or the whole mixed-material pack as the denominator.
Our Plastic Packaging Tax guide covers scope and registration. This guide focuses on proving the recycled-content claim. For material specifications and packaging design, use our packaging sourcing guide.
Get manufacturer records or an evidence-producing audit
HMRC says imported packaging needs evidence from its manufacturer, or a robust supply-chain audit by you or a competent third party that can provide that evidence. If your goods supplier buys packaging elsewhere, ask it to identify the packaging manufacturer and obtain the records from there.
Request the production specification, recycled-material source records, material purchase documents, mixing records and production certificates relevant to your order. These are practical requests, not a mandatory document checklist. Compare the documents for consistent material descriptions, weights and batch references. Treat a generic factory certificate as a starting point for questions.
Trace the material into your shipment
HMRC requires records showing the calculation, supporting evidence of recycled material use, relevant dates, the component or production run, and the recycled plastic source. The records must accurately reflect the recycled proportion in the recycling process output. Separate evidence is required when specifications or materials change.
Build a traceability sheet linking the packaging specification revision, resin batches, production run, finished packaging batch and shipment documents. Ask the factory to explain material losses, substitutions and mixed batches. If the references do not connect, request the missing records before accepting the claim.
Check the records against factory practice
Ask an auditor to follow the claimed material from receipt and storage through mixing and production into finished packaging. Request copies or extracts of the records examined, the batches covered, discrepancies found and how they were resolved. A report describing general factory capability gives you little help with an unexplained shipment.
HMRC says due diligence checks should be carried out at least every 12 months; changes within that period require a decision on further checks. Keep details of the checks. As a practical control, ask for notification of changes to the resin supplier, formulation or packaging subcontractor, and review the evidence before approving repeat production.
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Retain a file your accounts team can use
For registered businesses, HMRC requires accounts by product line, meaning packaging components made to the same specification. Accounts must explain the return figures and records must support them. Keep accounts and records for at least 6 years from the end of the accounting period concerned.
Store the calculation, source documents, traceability sheet, audit findings and shipment references together in your own archive. Add an index connecting the file to the relevant accounting period. Keep readable originals and translations where helpful. Where evidence is incomplete, leave the claim unapproved and ask your tax adviser how to account for the shipment.
Frequently asked questions
Is a supplier declaration enough for recycled plastic tax exemption?
Check what it proves. HMRC requires manufacturer evidence or a robust supply-chain audit, with records supporting the calculation, material source and relevant packaging. Ask for the records behind a general declaration.
Must I commission a third-party recycled-content audit?
HMRC allows manufacturer evidence or a robust supply-chain audit by you or a competent third party. Choose the route that produces traceable evidence for the packaging you import.
Can I reuse recycled-content evidence for repeat orders?
Check that it covers the relevant dates and production runs. HMRC requires separate evidence when specifications or materials change. Ask for batch links rather than assuming an earlier file covers the new shipment.
How long must I keep plastic packaging tax records?
Registered businesses must keep accounts and records for at least 6 years from the end of the accounting period. Keep the supporting factory and audit documents in your own accessible archive.