A pallet of shampoo from Poland, a container of empty PET bottles from Turkey and a shipment of garden furniture wrapped in plastic film all have one thing in common once they reach a UK port: the plastic around them may fall under Plastic Packaging Tax. Many UK importers still treat PPT as a manufacturer’s problem. It is not. If you import plastic packaging, filled or unfilled, this Plastic Packaging Tax guide for UK importers explains when you must register, what counts, what is exempt and which records HMRC expects you to keep.
What Plastic Packaging Tax is and who pays it as an importer
Plastic Packaging Tax has applied since 1 April 2022. It is charged on finished plastic packaging components that are manufactured in the UK or imported into the UK and that contain less than 30% recycled plastic. Components with 30% or more recycled plastic are not chargeable.
GOV.UK does not distinguish between filled and unfilled imported packaging: if the item meets the definition of a plastic packaging component, it is in scope. That means the bottle around an imported product counts, not only empty bottles bought for your own filling line.
The tax is charged per tonne of chargeable plastic, and the rate changes each year on 1 April. Check the current rate on the HMRC policy paper before you budget, and factor it into your total import cost alongside duty and import VAT. A landed cost calculator for UK imports helps you see the whole picture before you place an order.
The 10-tonne threshold: two tests
You do not need to register because you import one pallet of plastic-wrapped goods. Registration is triggered by weight, using two tests set out by HMRC:
- Look-back test: you have manufactured or imported 10 tonnes or more of finished plastic packaging components in the last 12 months.
- Look-forward test: you expect to import into the UK or manufacture in the UK 10 tonnes or more of finished plastic packaging components in the next 30 days.
Once you meet either test, you must register within 30 days. HMRC can charge penalties for late registration.
Registration is done online with a Government Gateway user ID. You will need an estimate of the weight of your finished plastic packaging components, your business details and a customer reference number such as your company registration number or UTR.
What counts as a plastic packaging component
HMRC defines a packaging component as a product designed to be suitable for use in the supply chain to contain, protect, handle, present or deliver goods. Trays, protective film and yoghurt pots are typical examples. For mixed-material packaging, the rule is comparative: a component is treated as plastic if it contains more plastic by weight, including additives that form part of the plastic, than any other single substance.
In practice, importers most often miss:
- shrink and stretch film around individual retail units;
- plastic trays, clamshells and blister packs;
- bottles, caps and pumps on imported cosmetics and cleaning products;
- plastic mailing bags used to ship goods to consumers.
If you import the plastics themselves (granules or sheet for your own manufacturing), the rules differ again, and chemicals law also applies. See our guide to importing plastics and polymers under UK REACH.
Exemptions that matter for imports
The Finance Act 2021 sets out exemptions. Two are especially relevant to importers:
- Transport packaging on imported goods. No charge arises on plastic components used to deliver goods into the UK that are transport packaging, tertiary packaging, or road, rail, ship and air containers.
- Immediate packaging of licensed human medicines. Plastic components made or imported for use as the immediate packaging of a licensed human medicine are exempt. HMRC expects you to hold evidence supporting the claim, such as the licence numbers of the medicines.
An exemption does not remove the need to keep records. You must be able to show why a given product line was not taxed.
Exporting again? Deferral and credits
If you import finished plastic packaging and intend to export it within 12 months, you can defer the tax, provided your records show the intention to export before the goods are imported. If the goods are exported within that window, the liability falls away. If you have already paid PPT on components that are later exported or converted into a different chargeable component, you can claim a credit on a later return, within 2 years of the original import. Relief is only available to registered businesses. Details are on the GOV.UK page on tax relief for exported and converted components.
Returns and record-keeping
Registered businesses file PPT returns for fixed quarterly accounting periods ending in March, June, September and December, and pay by the last working day of the following month. HMRC requires records by product line, including the weight of plastic packaging, evidence of recycled content where you claim 30% or more, evidence of exemptions, and support for any deferral or credit. Records must be kept for at least 6 years from the end of the accounting period.
For imported packaging, recycled content evidence usually comes from your overseas supplier: product specifications showing recycled content, certificates of conformity, or accreditations to recognised standards. Ask for these before the goods ship. Chasing documents after a quarter has closed is the most common cause of paying tax you could have avoided.
PPT sits alongside, not instead of, your customs obligations. The same shipment still needs a correct commodity code, a customs declaration and payment of any duty and import VAT. If you move goods between the UK and the EU, our overview of PPT registration for imports into the UK and the step-by-step landed cost breakdown for UK imports show how the pieces fit together.
Checklist for UK importers
- List every product line you import and identify all plastic packaging components on it.
- Weigh or obtain the weight of plastic per unit and total it over the last 12 months.
- Forecast imports for the next 30 days against the 10-tonne threshold.
- Request recycled content evidence from suppliers for any component at or above 30%.
- Identify transport packaging and any licensed medicine packaging you treat as exempt, and document why.
- Register within 30 days of meeting a test and diarise quarterly return deadlines.
- Keep records by product line for at least 6 years.
Mini-FAQ
Do I pay Plastic Packaging Tax on packaging around goods I import?
Yes, if you are liable. GOV.UK does not distinguish between filled and unfilled imported packaging, so the packaging around imported products counts towards the threshold and can be chargeable if it contains less than 30% recycled plastic.
When do I need to register as an importer?
When you have imported or manufactured 10 tonnes or more of finished plastic packaging components in the last 12 months, or expect to in the next 30 days. You must register within 30 days of meeting either test.
Is pallet wrap on an incoming shipment taxed?
Plastic used as transport or tertiary packaging to deliver goods into the UK is exempt. Packaging on individual retail units may not qualify as transport packaging, so review each component against the GOV.UK guidance rather than applying the exemption across a whole shipment.
How long must I keep PPT records?
At least 6 years from the end of the accounting period.
Sources (gov.uk): Plastic Packaging Tax: steps to take; Work out which packaging is subject to Plastic Packaging Tax; Register for Plastic Packaging Tax; Records and accounts you must keep; Finance Act 2021, Part 2.
Disclaimer: this article is general information based on GOV.UK guidance at the time of writing and is not tax advice. Always check the current guidance before making decisions.