Table of Contents
- Why Recycled Content Matters for EPR
- Plastic Packaging Tax Threshold
- EPR Fee Modulation and Recycled Content
- Measuring Recycled Content
- Evidence and Documentation
- Practical Considerations
- Key Takeaways
Key Takeaways
- 30% recycled content in plastic packaging exempts you from the Plastic Packaging Tax (saving £210.82/tonne).
- EPR modulated fees are expected to increasingly reward recycled content — packaging with higher recycled content may attract lower fees.
- Pre-consumer and post-consumer recycled content both count, but post-consumer is preferred under most definitions.
- You need documentary evidence of recycled content from your packaging supplier — self-declaration alone may not suffice for audits.
- The combined saving from Plastic Packaging Tax exemption plus potential EPR fee reduction can exceed £250/tonne.
Why Recycled Content Matters for EPR
Using recycled content in packaging delivers a double financial benefit under UK regulations:
- Plastic Packaging Tax exemption — packaging with 30%+ recycled content is exempt from the £210.82/tonne tax
- EPR fee modulation — packaging with higher recycled content may qualify for lower modulated fees
These are two separate regimes, but they both reward the same behaviour: using recycled material instead of virgin material. For businesses producing or importing significant volumes of plastic packaging, the financial incentive to increase recycled content is substantial.
For EPR fundamentals, see what packaging EPR is.
Plastic Packaging Tax Threshold
The Plastic Packaging Tax (PPT) applies to all plastic packaging manufactured in or imported into the UK that contains less than 30% recycled content by weight.
| Recycled Content | PPT Status | Rate |
|---|---|---|
| Less than 30% | Liable | £210.82/tonne |
| 30% or more | Exempt | £0 |
Example: A business importing 200 tonnes of PET bottles:
- With virgin PET: PPT = 200 x £210.82 = £42,164
- With 30% rPET: PPT = £0
The saving is significant. For more on the differences between PPT and EPR, see EPR vs Plastic Packaging Tax.
EPR Fee Modulation and Recycled Content
EPR fees are modulated based on recyclability and environmental impact. While the current modulation primarily focuses on material type and recyclability, future iterations are expected to more explicitly reward recycled content.
Current Position
- Packaging made from recyclable materials already attracts lower fees
- Recycled content is not yet a direct fee modifier in the current EPR fee schedule
- PackUK has indicated that recycled content may become a modulation factor
Expected Future Direction
- Packaging with higher recycled content may receive a fee discount
- The discount could scale with recycled content percentage
- This would create a direct financial incentive alongside the PPT exemption
What This Means for You
Even before explicit EPR modulation, increasing recycled content:
- Eliminates the PPT liability (£210.82/tonne saving)
- Positions your packaging favourably for future EPR fee reductions
- Supports your sustainability credentials
Measuring Recycled Content
What Counts as Recycled Content?
Under UK regulations, recycled content includes:
| Type | Definition | Counts? |
|---|---|---|
| Post-consumer | Material recovered from consumer waste streams | Yes (preferred) |
| Pre-consumer | Manufacturing scrap from third parties | Yes |
| In-house scrap | Regrind or offcuts from your own production | Varies by interpretation |
| Chemical recycling | Material recovered through chemical processes | Yes (with certification) |
| Bio-based/renewable | Material from biological sources | No (not recycled content) |
How to Calculate
Recycled content percentage = (weight of recycled material / total weight of packaging component) x 100
Example: A PET bottle weighing 22g made with 8g of recycled PET:
- Recycled content = (8 / 22) x 100 = 36.4% — exceeds the 30% threshold
By Component or By Product?
The 30% threshold is assessed per packaging component, not per product. If your bottle is 30% rPET but your cap is virgin PP, the bottle is exempt from PPT but the cap is not (caps are assessed separately).
Evidence and Documentation
What You Need
To support recycled content claims for PPT and future EPR modulation:
- Supplier declarations — written confirmation from your packaging supplier stating recycled content percentage
- Material certificates — certificates of recycled content from resin suppliers
- Chain of custody documentation — tracing recycled material from collection to final product
- Third-party certification — independent verification (e.g., by certification bodies)
- Batch records — linking specific packaging batches to recycled content evidence
HMRC Requirements for PPT
HMRC requires businesses to:
- Maintain records demonstrating recycled content claims
- Be able to evidence recycled content percentage for each component
- Retain records for at least 6 years
- Provide documentation upon request during audits
Best Practice
- Request material data sheets from packaging suppliers
- Obtain written recycled content guarantees in supply contracts
- Maintain a register of packaging components with recycled content percentages
- Audit your supply chain periodically to verify claims
Practical Considerations
Availability of Recycled Material
| Material | Recycled Supply Status |
|---|---|
| rPET (recycled PET) | Good availability; growing supply |
| rHDPE (recycled HDPE) | Good availability; established supply |
| rPP (recycled PP) | Limited but improving |
| Recycled PE film | Growing availability |
| Recycled PS | Very limited |
| Recycled PVC | Very limited |
Cost Considerations
Recycled plastic resin can be more expensive than virgin material (though the gap varies). However, the PPT saving of £210.82/tonne typically more than offsets the higher material cost:
| Factor | Virgin PET | 30% rPET |
|---|---|---|
| Resin cost premium | — | +£50-100/t |
| PPT | +£210.82/t | £0 |
| Net cost | Higher | Lower |
Quality Considerations
Modern recycled resins deliver comparable performance for most packaging applications. Key points:
- rPET is widely used for bottles, trays, and films with no quality compromise
- rHDPE performs well in bottles and containers
- Colour consistency may vary slightly — discuss with your supplier
- Food-contact approval requires specific recycling processes — ensure your recycled resin is food-grade certified if needed
Getting Started
- Audit your plastic packaging — identify components below 30% recycled content
- Discuss with your packaging supplier — what recycled content options are available?
- Calculate the financial impact — PPT saving vs any material cost premium
- Obtain evidence and documentation before making claims
- Register your compliance through DEFRA’s RPD portal
Use the EPR fee calculator and visit our pricing page for compliance tools.