HMRC Mass Balance Allowance Working Group Meeting 25 March – Request for Technical Input

Steve Morgan attended the HMRC Mass Balance Allowance Working Group meeting on 25 March, and technical and specialist input requirements are now building across different subject areas. This is around how mass balance can be structured and operate for the purposes of the Plastic Packaging Tax, whilst assessing the impact and guiding how the phasing out of pre-consumer material can be approached. RECOUP is currently reviewing its input into this process, and if you think you can provide input into these areas on an ongoing basis, please contact Steve (steve.morgan@recoup.org).

To provide context around this, three discussion papers were circulated ahead of the previous (February) meeting which HMRC requested feedback on:

– Definition of chemical recycling
– Minimum requirements for the certification of chemically recycled plastic accounted for using a MBA
– Removal of pre-consumer waste from the definition of recycled plastic

Thank you to those members who provided information.

A few days ahead of this week’s meeting HMRC shared two further discussion papers for the meeting, which required specialist technical and operational knowledge:

– Discussion Paper 04 – Measurement Methods for a Mass Balance Approach (MBA)
– Discussion Paper 05 – Certification bodies and Accreditation

HMRC have requested feedback on these and if you have input please send to Steve by Friday 11 April.

In terms of the outcome of the meeting this week, the key points and questions relating to discussion papers 4 and 5 are outlined as follows:

Discussion Paper 4
• HMRC would like to use mass and kg as measurements wherever possible, not to use other units unless necessary, and use measurements throughout the supply chain. Are these points appropriate?
• Lower Heating Value (LHV) is about fuel allowance.
• Is there an accepted method in certification to demonstrate how process losses are accounted for?
• HMRC want to push for as much simplification in the Plastic Packaging Tax as possible, including use of more regularly used terms as much as possible when communicating technical information.

Discussion Paper 5
• A new ISO standard, 13662 for ‘Chain of custody – Mass balance – Requirements and guidelines’ is being developed.
• There will be very specific requirements for mass balance certification to meet legislative requirements for the Plastic Packaging Tax.
• No existing certification schemes currently meet requirements as they allow free allocation and group level mass balance.
• Any scheme will need to include all the required features, and those features will be stated in law.