RECOUP Response to Plastic Packaging Tax Policy Papers 13 and 14 – Plus Additional Question from HMRC on how the Definition of Fuel Use Products Could be Interpreted

RECOUP have given a broad response to HMRC about the policy papers they released for comment in April stating appropriate and proportionate enforcement is needed, both from any certification operating in the system and how their activities are then checked / verified by HMRC.

Paper 13 outlines final proposals for compliance and enforcement of the Plastic Packaging Tax (PPT) Mass Balance Approach (MBA), addressing issues of inaccurate or fraudulent documentation, mismatched material tracking, and penalties for non-compliance.

Paper 14 outlines proposed minimum record-keeping requirements for businesses and certification schemes involved in chemically recycled plastic under the Plastic Packaging Tax (PPT), aiming to ensure compliance, traceability, and integrity while minimising administrative burdens.

In addition, RECOUP and the BPF have been asked about a point from Paper 12 on MBA methodology for chemically recycled material. It states ‘Fuel use output products include products that are reasonably expected to be reprocessed into fuel, and consumed fuel which provides energy for the process, sometimes referred to as auto consumption’ and we’ve been asked if members can provide more information on the different ways this definition of fuel use products could be interpreted and how these different interpretations would result in the proposed methodology not being feasible for certain technologies. It would also be good if members can provide real world examples.

If any members can help with this question, please contact Steve Morgan (steve.morgan@recoupo.org). RECOUP are members of the EPRO Chemical Recycling Working Group and will be posing this to the group. RECOUP is awaiting the next policy papers to be released by HMRC and will communicate them when they are circulated.