HMRC Announcement – Mass Balance and Pre-consumer Date Brought Forward!

On Friday 2 May, HMRC made a significant announcement about the timescales around the use of mass balance and pre-consumer material.

In the Autumn Budget 2024 the government confirmed it would allow a Mass Balance Approach for chemically recycled plastic for the purposes of the Plastic Packaging Tax.

In order to give ‘clarity and certainty’ it was confirmed this change will be implemented from April 2027, with the legislative process commencing in the Finance Bill 2025/2026. This is around 2 years earlier than first estimated (due to the aforementioned legislative requirements).

HMRC also confirmed pre-consumer waste will also no longer be accepted as a source of recycled plastic for the purposes of the tax from the same date. Many RECOUP members might remember the infamous Q13 curveball in the 2023 mass balance consultation about this!

Further detailed guidance and draft technical legislation will of course follow.

This is a hugely technical space, and feeding information to HMRC will continue to be needed to ensure progress is made. More requests for specific information will be ongoing through HMRC’s Plastic Packaging Tax Technical Working Group, which RECOUP is on, including the new monthly update meetings.

HMRC have been open and engaging throughout, and if you have relevant knowledge, please get in touch with us to feed into this process.