HMRC Plastic Packaging Tax Mass Balance Approach Meeting Update

On 11 November RECOUP attended the HMRC Mass Balance Approach (MBA) Technical Working Group. Notes from the meeting below

• Considering the current consultation on the draft regulations and reference document to use MBA to provide evidence of recycled content which closes on 21 December, it was recognised more detail is needed on ‘dual use’ to avoid it being used for ‘free allocation’, and more information will come when the guidance is published. On 28 August two sets of preliminary guidance was published – note preliminary guidance is not the final guidance. HMRC can circulate draft final guidance within the controlled PPT TWG for input.
• HMRC currently working on dual use factors document and will be published alongside the secondary legislation.
• It was communicated it would be useful for HMRC to provide practical examples of how to apply MBA. HMRC are looking for scenario examples and would appreciate examples from businesses.
• ISCC published their draft Fuel Use Excluded add on document on 10 November which can be found on their Public Consultation – ISCC System
• HMRC looking to assess the level to take up of using MBA from April 2027 and would like to hear from businesses intending to use it.
• HMRC asked what else they can do to support businesses intending to use MBA.
• HMRC are looking at a holding a webinar to communicate and have dialogue around the final guidance and to estimate attendance they would like to know which businesses would be interested in attending.
• There was an update on use of certification for mechanical recycling provided – mandatory certification will be required to claim recycled content from 1 April 2030. It was questioned whether the 2030 date could be brought forward, but a balance is needed as there was responses from businesses and certification schemes to the consultation earlier this year that they needed time to implement it. Voluntary use of certification is an option for businesses, and they would like to assess interest in businesses doing this ahead of 2030.

If you would like anything clarified or more information please contact Steve Morgan (steve.morgan@recoup.org).