Recycled plastic packaging: prepare for April 2027
From April 2027, pre-consumer recycled plastic will no longer count for Plastic Packaging Tax. Review packaging that relies on factory waste, separate it from post-consumer material and obtain evidence linked to your orders before approving replacement specifications. Factory evidence can be checked in China by Cambridge China Bridge.
Find specifications that depend on factory waste
Start with packaging currently described as recycled, containing factory offcuts or using recovered production material. Ask the supplier to separate virgin, pre-consumer and post-consumer inputs in its material declaration. Flag specifications that rely on pre-consumer material to reach the recycled-content threshold.
Our Plastic Packaging Tax guide covers the threshold, registration and tax basics. This review should produce a working list of affected components, their suppliers, current material sources and the person responsible for approving a replacement.
Distinguish scrap reuse from reprocessing
HMRC excludes routine scrap reuse after minimal reprocessing, including shredding and grinding. Reprocessing can happen on site; sending material elsewhere is not the defining test. Factory waste that qualified before the change will still lose eligibility from April 2027.
Ask the factory to describe the route from waste to usable raw material. Request process records and photographs showing what actually happens between collection and reuse. Treat descriptions such as clean scrap, regrind or recycled pellets as prompts for investigation rather than proof.
Build an evidence file for the actual order
HMRC requires separate evidence when packaging specifications or materials change. Create a file for each revised specification, retaining the previous version so that old and new production can be distinguished.
Request the material supplier’s identity, waste origin, reprocessing records, resin purchase documents, batch references and the factory’s input records. Connect these to the packaging production run and shipment. Ask the supplier to explain gaps or mixed sources before relying on its declaration.
Rewrite each affected component specification
Assess packaging components separately, including bottles, caps and labels. Rewrite the specification to distinguish total recycled content from post-consumer content, identify the approved material source and require your approval before substitution. A recycled-content statement for the whole packaging set can conceal a component that needs attention.
Trial replacement material against your existing acceptance criteria: sealing, strength, appearance, odour and fit with packing equipment. Use our packaging sourcing guide for the wider specification work and our plastic film and sheet guide when reviewing film.
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Control the change through purchasing and shipment
Map open orders, repeat orders and packaging stock against expected UK import dates around April 2027. Ask suppliers to identify which material version each shipment will contain. Avoid assuming that an earlier purchase order makes factory waste acceptable after the change.
Before releasing an order, approve the revised sample, specification and supporting evidence together. If the source remains unclear, budget without relying on that recycled-content claim. Cambridge China Bridge’s staff in China can ask factories for the process records and check that the agreed packaging is being used.
Frequently asked questions
Will factory scrap count as recycled plastic after April 2027?
Pre-consumer factory waste will no longer count for Plastic Packaging Tax. Ask the supplier to distinguish it from post-consumer material in each packaging specification.
Does grinding factory offcuts make them eligible?
No. Ask for the actual process records rather than accepting a regrind label.
Can recycling inside the factory qualify before the change?
Yes, qualifying reprocessing can take place on site. Location alone does not establish eligibility, and pre-consumer material loses eligibility from April 2027.
What should I ask my packaging supplier for now?
Ask for a revised material declaration, waste origin, reprocessing records and batch links to your order. Approve replacement samples and require approval before material substitutions.