# The UK and the EU count chemically recycled plastic alike at the plant, but differently at the pack

> HMRC's draft Plastic Packaging Tax regulations of 6 October 2026 and the EU's Implementing Decision (EU) 2026/1425 both use a three-month, fuel-excluded mass balance for chemically recycled plastic, but the UK lets credits move between sites in one group by pipeline and tests each component against a 30% tax line, while the EU forbids transfers between facilities and averages whole bottles, caps and labels included, across a national market.

Publisher: Strategic Packaging Insights  
Published: 2026-10-31  
Last updated: 2026-10-31  
Page: https://www.strategicpackaginginsights.com/insights/mass-balance-chemically-recycled-plastic-uk-tax-eu-bottles/

**HMRC's draft Plastic Packaging Tax regulations of 6 October 2026 and the EU's Implementing Decision (EU) 2026/1425 both use a three-month, fuel-excluded mass balance for chemically recycled plastic, but the UK lets credits move between sites in one group by pipeline and tests each component against a 30% tax line, while the EU forbids transfers between facilities and averages whole bottles, caps and labels included, across a national market.**

For a buyer of plastic packaging sold in both markets, that means one batch of chemically recycled resin can carry one certificate and still produce two different recycled content figures. This piece sets the two counting rules side by side, works one bottle through both and shows where buyers should ask suppliers for different evidence.

## Executive summary

Chemically recycled plastic has moved from voluntary claims into two sets of public counting rules in 2026. The EU went first in law: Commission Implementing Decision (EU) 2026/1425 of 30 June 2026, published in the Official Journal on 3 July and in force from 23 July, lets chemically recycled content count toward the Single-Use Plastics Directive's bottle targets through a mass balance. The UK follows on 1 April 2027, when certified mass balance becomes available for the Plastic Packaging Tax; HMRC published the draft certification regulations on 6 October 2026, and comments close at 11:59pm on 21 December 2026.

At the level of the chemical plant the two systems are close. Both cap the accounting period at three months, both strip out plastic that ends up as fuel, and both rely on accredited third parties rather than on the regulator to audit plants (Exhibit 1). A recycler that meets the EU rules will find most of the UK draft familiar.

The split comes in three places. First, transfers: the UK draft lets a group move attributed amounts between sites linked by pipeline, which the EU decision forbids outright. Second, the unit: the UK tests each finished component, so a cap and a label are judged on their own, while the EU counts the cap, lid, label and sleeve inside one bottle figure (Exhibits 3 and 4). Third, the consequence: in the UK a shortfall costs the manufacturer or importer tax on the whole component, at GBP 236.56 per tonne from 1 April 2027, while in the EU it shows up first in a national average.

For buyers this is a paperwork question with money attached. A bottle body with 30% recycled PET passes the UK line on its own, but the same bottle contributes about 26.3% to the EU average under SPI's illustrative weights, because the cap and label dilute it (Exhibit 4, SPI calculation). A group transfer that is valid for UK tax can be invalid for an EU claim.

Leaders should do three things now: ask suppliers for recycled content per component and per bottle, with the route (mechanical or mass balance) stated; check that any mass balance certificate names the facility and states whether attributed amounts were moved between sites; and decide by 21 December 2026 whether to comment on HMRC's draft, because default dual-use factors and audit frequency are still blank.

## Key findings

1. Implementing Decision (EU) 2026/1425 was adopted on 30 June 2026, published on 3 July 2026 and entered into force on 23 July 2026, repealing the 2023 method in Decision (EU) 2023/2683 and adding mass balance for chemically recycled content (EUR-Lex; SPI rule [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)).
2. HMRC's draft Plastic Packaging Tax (Chemical Recycling Certification Schemes) Regulations 2027 were published on 6 October 2026 with a commencement date still blank; the policy start is 1 April 2027 and comments close on 21 December 2026 (GOV.UK).
3. Both texts set a three-month maximum balancing period and treat fuel outputs as zero; the UK default dual-use factors in Annex A of HMRC's reference document still read "[Data needed]" (HMRC reference document, version 0.1).
4. The EU decision bans transfers of attributed amounts between facilities and between companies (Article 7(8)); the UK draft allows them within one undertaking or group where sites are linked by a pipeline meeting an HMRC notice (draft regulation 4).
5. **SPI calculation:**  on an illustrative 20.5 gram bottle with an 18.0 gram PET body, a 2.0 gram cap and a 0.5 gram label, a body at 30% recycled PET gives an EU bottle share of 26.3%, and a body at 100% gives 87.8%.
6. HMRC's statistics show 1,506 thousand tonnes of plastic packaging relieved at 30% or more recycled content in 2025-26, out of 2,970 thousand tonnes declared, so the UK's evidence rules reach about half of declared tonnage (HMRC statistics commentary, 27 August 2026; SPI calculation).
7. **SPI analysis:**  the EU method is written for PET bottles, and the Commission's three PPWR recycled content acts were still due by 31 December 2026 on the Green Forum timeline on 31 October 2026, so neither the UK draft nor the bottle decision settles how mass balance will count for other EU packaging.

## Two rulebooks written in the same year

The UK and EU rules answer the same question: when a used plastic is broken down chemically and mixed with fossil feedstock in a cracker or reactor, how much of the output can be called recycled? Because the molecules cannot be traced, both use mass balance, which allocates recycled inputs to outputs on paper and then audits the books. The Commission's decision says so in recital 8: mass balance is needed because the proportions of the eligible material in the outputs are generally not known.

The legal homes differ. In the UK the rule sits inside a tax. Section 47 of the Finance Act 2021 makes a finished plastic packaging component chargeable when its recycled plastic is under 30% of its plastic, and sections 49A and 49B, inserted by the Finance Act 2026 with effect from 18 March 2026 for specified purposes, let chemically recycled plastic count as attributed recycled plastic through a mass balance process (legislation.gov.uk; SPI rule [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). The draft 2027 regulations fill in the conditions.

In the EU the rule sits inside a target that binds governments. Article 6(5) of Directive (EU) 2019/904 requires Member States to ensure that PET beverage bottles contain at least 25% recycled plastic from 2025, and that all bottles listed in Part F of its Annex contain at least 30% from 2030, each as an average across the national market (SPI rule [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)). Decision 2026/1425 sets how that average is calculated, checked and reported.

The timing has been close. HMRC first consulted on chemical recycling and mass balance in July 2023 and confirmed the approach in a policy paper on 26 November 2025. Member States' representatives in the Waste Technical Adaptation Committee backed the bottle method in February 2026, according to the Commission's press release of 30 June 2026 and S&P Global's report of 9 February 2026 (Exhibit 2).

SPI's news report of 30 October covered HMRC's separate decision on [certification for mechanically recycled plastic from 1 April 2030](https://www.strategicpackaginginsights.com/news/uk-plastic-packaging-tax-recycled-certification-2030/). That outcome says the mechanical approach aligns with the treatment of chemically recycled plastic and the use of a mass balance approach, but it does not say that mass balance will be allowed for mechanical recycling. This piece stays with the chemical route, where the rules are already drafted in both jurisdictions.

## Where the two methods agree

**The period.**  HMRC's draft regulation 3 defines the balancing period as the three months starting with the day a certified person is granted a certificate, followed by successive three-month periods. Article 7(7) of the EU decision sets three months as the maximum period for mass balance accounting and lets a positive balance be carried into the next period. A recycler can therefore run one quarterly ledger for both, provided its UK periods start on its UK certificate date.

**The fuel rule.**  Both texts exclude plastic that ends up as fuel. The EU decision gives fuels and losses a dual-use factor of 0 in Article 7(5)(c), and recital 24 describes the approach as fuel-use excluded, linked to the definition of recycling in Article 3(17) of the Waste Framework Directive. HMRC's reference document applies what it calls the fuel-excluded attribution method, under which fuel-use products get a factor of 0 and non-fuel products a factor of 1 (Exhibit 6).

**The allocation.**  The EU decision requires, in Article 7(5)(a), that the relative share of eligible material in each output equals its share in the input, before the dual-use factors are applied. HMRC's draft regulation 3 sets out its own formula, with a conversion factor shown only as an image in the accessible version, and requires the share of consumed fuel to which recovered material is attributed to match the share of qualifying input in the mixture. SPI has not yet confirmed whether the UK formula is fully proportional for non-fuel outputs, because the conversion factor is not in the accessible text.

**The auditor.**  Neither government runs certification. The EU decision relies on accredited conformity assessment bodies under Regulation (EC) No 765/2008, with annual facility-level audits for plants that process non-polymer material and every three years for small and medium-sized enterprises (Article 8(5) and (9)). HMRC's draft regulation 8 requires schemes to use certification bodies accredited by a body that is a full member of Global Accreditation Cooperation Incorporated and meets standards set by HMRC.

SPI analysis

These overlaps matter because recyclers already sell into both markets. A plant that runs quarterly fuel-excluded accounts under an accredited scheme has most of the machinery both regimes ask for. The differences in the next section decide whether the same ledger produces the same claim.

## Where they split: transfers, the unit and the feedstock

**Transfers between sites.**  This is the sharpest difference. Article 7(8) of the EU decision requires mass balance accounting for each facility and says attributed amounts cannot move between facilities or companies. HMRC's draft regulation 4 allows an attribution under a receiving process if the transferring and receiving processes are run by the same undertaking or a group undertaking, and the sites are connected by a pipeline meeting requirements in an HMRC notice. Draft regulation 3 also treats every mass balance process on a single site as one process, and defines a site as the whole area under a certified person's control, with areas separated only by a road, railway or inland waterway counted as one.

**The unit measured.**  The UK tax is charged component by component. HMRC's guidance on packaging in and out of scope lists bottle tops or caps and labels among plastic packaging, and says the lids of yoghurt and soup pots are separate packaging components in their own right. The EU decision defines a beverage bottle as including its cap, lid, label and sleeve, if any, and counts every plastic part in both the plastic weight and the recycled weight (Article 1(3); SPI rule [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) on tethered caps).

**The feedstock.**  The EU decision counts only plastic that was post-consumer waste, and recital 15 excludes plastic and waste from manufacturing, testing, storage and transfers before a product reaches the market. In the UK, pre-consumer plastic stops counting as recycled plastic from 1 April 2027 under HMRC's policy paper of 26 November 2025. Section 49A of the Finance Act 2021 defines qualifying input material as recovered material or material to which recovered material was attributed under an earlier mass balance process; SPI has not yet confirmed how the April 2027 removal of pre-consumer plastic applies to feedstock entering a UK mass balance process.

**Origin.**  The EU decision counts recycled plastic recycled in the EU now, and from 21 November 2027 also post-consumer plastic recycled in countries covered by the OECD decision; other third countries count only under EU agreements or arrangements (Article 1(1); recitals 18 and 19). The Commission's press release refers to material from the Union and EEA countries in the first phase. HMRC's draft regulations do not set an origin rule for chemically recycled feedstock, and SPI found none in the accessible text.

## One bottle, two answers

The difference in units is easiest to see on a single bottle. SPI used an illustrative half-litre PET drinks bottle: an 18.0 gram PET body, a 2.0 gram HDPE cap and a 0.5 gram plastic label, 20.5 grams of plastic in all. These are SPI assumptions, not a company's figures. Only the body contains recycled PET.

Under the EU method, the bottle's recycled share is the recycled weight over all plastic weight. A body at 30% recycled PET holds 5.4 grams of recycled plastic, which is 26.3% of 20.5 grams, by SPI's calculation. The same bottle sits above the 25% PET figure for 2025 but below 30% (Exhibit 4). A body at 100% recycled PET gives 87.8%, because the cap and label stay virgin.

Under the UK tax, the same bottle is three tests, not one. The body at 30% passes on its own. The cap and label, at 0% recycled, are chargeable components for whichever registered business manufactures or imports them. SPI has not yet confirmed whether HMRC treats every beverage bottle cap and label as a separate component in practice; HMRC's guidance gives examples rather than a full method, and says it does not list all packaging.

For a line of 100 million such bottles a year, the caps weigh 200 tonnes and the labels 50 tonnes. At GBP 236.56 per tonne from 1 April 2027, that is GBP 47,312 on the caps and GBP 11,828 on the labels, GBP 59,140 in all, by SPI's calculation (Exhibit 5). The 1,800 tonnes of bodies pay nothing at 30%. If the bodies slipped to 29%, they would pay GBP 425,808, because the UK tax falls on the whole weight below the line.

SPI analysis

The two methods push buyers in different directions. The EU method rewards recycled content in the cap and label, because every gram counts toward the bottle. The UK tax rewards getting each component over 30% and gives no credit for headroom above it. A buyer optimising for one regime can leave money on the table in the other.

In practice: ALDI UK.

ALDI UK said in April 2024 that its own-label soft drinks and bottled water in England and Wales were moving to 100% recycled PET bottles, excluding cap and label, saving about 10,000 tonnes of virgin plastic a year (SPI Packaging Buyers Database, ALDI UK profile). The exclusion is the point: for the UK tax, a 100% recycled body clears the line by 70 points, while the caps and labels are tested separately. Under the EU method, a bottle described this way would count below 100%, at 87.8% on SPI's illustrative weights. ALDI UK sells in the UK, so the EU figure is shown only to illustrate the counting rule.

In practice: Danone.

Danone reports that evian and Volvic bottles already use 100% recycled PET, according to its profile in the SPI Packaging Buyers Database, which places Europe at 36% of the group's 2025 sales. Those brands sit far above the 25% PET average for 2025 under [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/), and their caps also fall under the tethering rule in [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/), which SPI's [Ledger on tethered caps](https://www.strategicpackaginginsights.com/insights/tethered-caps-two-years-single-use-plastics-directive/) covers. Whether the published figure includes caps and labels is not stated in the profile, and SPI has not yet confirmed it.

## The dual-use factor: the number that decides the yield

Most chemical recycling routes send used plastic through pyrolysis or a similar process, producing an oil or gas that is then cracked alongside fossil feedstock. Some of that output becomes polymer precursors, some becomes fuel, and some can go either way. The dual-use factor decides how much of a mixed output can carry recycled credit.

HMRC's reference document, version 0.1 dated September 2026 and published on 6 October, sorts outputs into three classes. It says output products are classified as fuel-use, non-fuel or dual-use products. For a steam-crackable dual-use product, the plant sets its maximum acceptable boiling point, reads the product's boiling range against it and takes the crackable share as the factor. For heavy or solid outputs, it must evidence the share that stays on a technically feasible recycling route.

The EU decision is stricter on solids. Under Article 7(5)(c), solid dual-use outputs get a factor of 0, and liquid or gaseous dual-use outputs count only for the share the operator can prove stays on the recycling route. Recital 24 gives the reason: solid outputs such as char are not expected to become high-value non-fuel products at scale.

The UK defaults matter more than they look. HMRC's consultation page says the default values will be confirmed before the final legislation and reference document are published, and Annex A of version 0.1 contains only placeholders. Until the defaults are set, no UK buyer can be sure how much attributable plastic a given plant will be able to sell per tonne of feedstock (Exhibit 10).

## Certificates, audits and the paper trail

Both systems end in a certificate that travels down the supply chain, and both make the buyer part of the chain of custody.

In the UK, draft regulation 13 requires a certified person to obtain supplier attribution declarations and certificates, to carry out appropriate due diligence on what suppliers send and to report suspected supplier non-compliance to the scheme operator. If a supplier's certificate is later suspended or withdrawn, that event is disregarded for a buyer that complied. Draft regulation 15 requires a public, searchable database of certified persons, products and certificate numbers, updated within one week of any issue, suspension or withdrawal.

In the EU, Article 8 of the decision has Member States check reported data on a risk basis and recognise certificates issued in other Member States. Certificates are valid for one year, or three years for small and medium-sized enterprises, and converters pass them downstream with batch declarations (Article 8(9) and (10); SPI rule [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)).

HMRC is explicit that much of the operating detail is still to come. Its consultation page says the notices are generally expected to reflect relevant industry and ISO standards.

> "The draft Regulations also provide for further operational detail to be specified in notices published at a later date."

***HM Revenue and Customs** , [draft legislation consultation](https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach), 6 October 2026*

SPI analysis

The open notices cover audit timing, the evidence behind dual-use factors and the pipeline test for group transfers. Those are the three points where a UK certificate and an EU certificate are most likely to differ, so a buyer that wants one supplier certificate to serve both markets should read the notices when they appear, not only the regulations.

## How much UK tonnage the evidence rules reach

The UK change lands on a large base. HMRC's statistics commentary, updated on 27 August 2026, records 2,970 thousand tonnes of plastic packaging declared in 2025-26, of which 1,580 thousand tonnes were made in the UK and 1,390 thousand tonnes imported. Of the total, 1,506 thousand tonnes were relieved at 30% or more recycled content and 1,107 thousand tonnes were taxable, with accrued receipts of GBP 250 million and 5,142 registered businesses at 13 August 2026 (Exhibit 8).

HMRC does not publish how much of the relieved tonnage relies on chemically recycled plastic, and before April 2027 no attributed plastic can count. HMRC's policy paper of 26 November 2025 says the combined measure is expected to have a negligible impact on the Exchequer. Read with the statistics, that suggests HMRC does not expect mass balance to move large tonnages across the line in the first years; SPI has not yet confirmed any HMRC estimate of attributed tonnage.

For imports, the lack of an origin rule in the UK draft is notable. An importer whose overseas supplier holds a mass balance certificate will still need a certificate from a scheme meeting HMRC's minimum standards, and HMRC's outcome on mechanical recycling says it will consider how overseas accreditation and recognised standards may be taken into account. SPI has not yet confirmed whether any existing international scheme will be recognised for the 2027 chemical route.

## A framework: four buyer positions

The two regimes create four practical positions for a packaging buyer, depending on where the pack is sold and which recycling route supplies it. SPI built them from the rules in Exhibits 1 to 7; they describe exposure, not compliance status (Exhibit 9).

**Position A**  is the most common today. Most UK claims rely on mechanical recycling, as HMRC's consultation outcome of 28 October 2026 records, and recycled PET bottles are the clearest case. The buyer's job is to hold part-level data, because the UK needs it per component and the EU per bottle.

**Position B**  is where mass balance makes the biggest difference in the UK, because flexible films and food-contact trays have little mechanical food-grade supply. SPI's [Ledger on PPWR recycled content targets](https://www.strategicpackaginginsights.com/insights/ppwr-recycled-content-targets-2030-2040/) set out why non-PET food packs depend on chemical recycling in the EU too.

In practice: Mondelez.

Mondelez UK said on 16 May 2025 that Cadbury sharing bars made and sold in the UK and Ireland would use wrappers with 80% certified recycled plastic, allocated by mass balance under ISCC from advanced recycling, about 600 tonnes of recycled plastic a year across about 300 million bars (SPI Packaging Buyers Database, Mondelez profile). For the UK tax, those wrappers are a Position B case: from 1 April 2027 they can count only if the chain is certified under a scheme meeting HMRC's minimum standards. SPI has not yet confirmed whether the existing certification will meet those standards.

**Position C**  applies to EU bottlers buying chemically recycled PET. The facility rule means a certificate must tie the attributed amount to the plant where the mass balance ran, and the buyer cannot rely on credits pooled across a group's plants.

**Position D**  is the one to watch. A recycler with two linked plants in the UK could, under draft regulation 4, move attributed amounts from one to the other for UK tax purposes. If that material were also sold into an EU bottle, the transfer would not be valid under Article 7(8) of the EU decision. Buyers in this position need certificates that state whether any transfer took place.

## Scenarios: what one batch of feedstock is worth under the UK tax

The value of mass balance to a UK buyer depends on how much attributable plastic a plant can produce per tonne of waste input, and that depends on yield and the dual-use factor. SPI modelled 1,000 tonnes of post-consumer feedstock in one balancing period under three sets of assumptions (Exhibit 10).

The spread is wide: the high case supports about 71% more component tonnage than the low case, by SPI's calculation, from the same feedstock. That is why the default dual-use factors are the most important open number in the UK draft. Under the EU decision, the same plant would face a factor of 0 on any solid dual-use output and no transfer between facilities, so its EU attributable tonnage would tend to be equal to or lower than its UK figure on the same accounts, subject to the UK conversion factor SPI has not yet confirmed.

The UK figures assume the components sit exactly at 30%. A converter that targets 35% to keep a safety margin can cover only 1,600 tonnes of components with the base case's 560 tonnes, by SPI's calculation, so the tax kept off falls to GBP 378,496. The margin is a cost of the cliff design.

SPI analysis

The scenario shows why buyers should ask for attributed tonnage, not only a percentage. A certificate that says 30% recycled tells a buyer whether a component passes the UK line; it does not tell the buyer how secure that pass is if the default factors are set lower than the plant assumed.

## What the Commission still has to decide

The bottle decision is not the end of the EU story. Article 7 of Regulation (EU) 2025/40, the PPWR, sets recycled content floors for plastic packaging from 2030, and its counting rules are still being written. The Green Forum timeline lists three acts due on 31 December 2026: an Article 7(8) implementing act on the methodology for calculating and checking recycled content, an Article 7(9) delegated act on sustainability criteria for plastic recycling technologies, and an Article 7(10) implementing act on the equivalence of rules in third countries. LexisNexis reported that the Commission opened consultations on the three acts on 18 August 2026, closing on 16 September 2026.

Recital 32 of Decision 2026/1425 says the Commission should consider aligning the bottle method with the provisions of Article 7(8) of the PPWR, where appropriate. Recital 33 points the other way: it says the PPWR method should reflect that Regulation's own legal basis and objectives, and that the bottle method should apply only to its own product category. Article 2(1) of the decision calculates the share for PET bottles, and the Commission's press release describes bottles made mainly of PET.

For the 30% all-bottle average from 2030, which covers HDPE and other non-PET bottles, SPI has not yet confirmed which counting method will apply. SPI's [Ledger on recycled content pledges](https://www.strategicpackaginginsights.com/insights/recycled-content-pledge-gap/) compared brand targets with these legal floors, and Ledger 17 modelled how a late Article 7(8) act could move the PPWR start date. Neither is repeated here.

## Industry reaction

> "The fuel-excluded attribution method prevents recycled material associated with output products that are fuel, or are used to produce fuel, from being attributed to other outputs from the same process."

***HM Revenue and Customs** , [Dual-use factors for refinery and petrochemical output products](https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach/dual-use-factors-for-refinery-and-petrochemical-output-products), version 0.1, published 6 October 2026*

The sentence places the UK draft in the same family as the EU decision, which recital 24 calls fuel-use excluded. The difference lies in the factors for dual-use outputs, not in the principle.

> "Attributed amounts shall not be transferred between different facilities of a company or between different companies."

***European Commission** , Implementing Decision (EU) 2026/1425, Article 7(8), [Official Journal](https://eur-lex.europa.eu/eli/dec_impl/2026/1425/oj/eng/pdf), 3 July 2026*

The ERP compliance scheme summarised the same rule for its members in March 2026: mass balance runs at facility level, and allocated amounts cannot move between sites.

> "In these cases, chemical recycling can complement mechanical recycling."

***European Commission** , [press release IP/26/1467](https://ec.europa.eu/commission/presscorner/detail/en/ip_26_1467), 30 June 2026*

The cases the release refers to are waste streams that mechanical recycling cannot process well, such as plastics with food residues, additives or mixed materials. The release also says the method can apply to any recycling technology.

Reaction from industry has been mixed. S&P Global reported on 9 February 2026 that Chemical Recycling Europe welcomed the decision as a common approach, while a refiner involved in chemical recycling said the rules would in effect exclude oil refineries from contributing, and warned against copying them into the PPWR. In the UK, SPI has not yet found published trade body responses to the draft 2027 regulations, which remain open for comment.

## What leaders should do now

1. **Procurement leads, by 31 January 2027:**  ask every plastic packaging supplier for recycled content per component and per bottle, split by route (mechanical, mass balance, pre-consumer), so the same data serves the UK component test and the EU bottle figure.
2. **Tax and finance teams, by 21 December 2026:**  decide whether to respond to HMRC's draft, with a view on default dual-use factors, audit frequency and the pipeline test for group transfers, and model the 2027 to 2028 exposure at GBP 236.56 per tonne.
3. **Supplier quality teams, before 1 April 2027:**  require mass balance certificates to name the facility, the balancing period and whether any attributed amount was moved between sites, and check each UK certificate number against the scheme's public database once it exists.
4. **Packaging engineers, at the next redesign:**  test whether adding recycled content to caps and labels raises the EU bottle figure enough to matter, and whether each UK component clears 30% with a margin, using the method in Exhibits 4 and 5.
5. **Category managers for flexible films, by mid-2027:**  for any pack relying on mass balance to pass the UK line, hold a fallback: post-consumer mechanical content, a margin above 30% or a budget for the tax.
6. **Sustainability teams, at each reporting cycle:**  stop quoting one recycled content number for packs sold in both markets; publish the basis (per component or per bottle, caps and labels in or out) next to the figure.
7. **Boards, in the first quarter of 2027:**  review the Commission's PPWR Article 7(8) and 7(9) acts once adopted, and test whether planned 2030 recycled content still counts under them.

This is business guidance on preparing evidence, not legal or tax advice. Check specific obligations with counsel.

## Questions for your board

- Which of our packs rely on chemically recycled plastic to pass the UK 30% line or to support an EU bottle claim, and how many tonnes is that?
- Do our recycled content figures include caps and labels, and do we report them per component or per pack?
- Are any of our mass balance credits moved between plants, and would that be valid for an EU bottle claim?
- How much UK tax would we pay from April 2027 if HMRC's default dual-use factors came in lower than our suppliers assume?
- Which of our suppliers hold certificates that could meet HMRC's minimum standards, and which would need a new scheme?
- Who owns the response to HMRC's draft and to the Commission's PPWR acts?

## What to watch

- **21 Nov 2026:**  EU exports of plastic waste to non-OECD countries become prohibited until 21 May 2029, per recital 17 of Decision 2026/1425, keeping more feedstock inside the EU.
- **21 Dec 2026:**  comments close at 11:59pm on HMRC's draft Chemical Recycling Certification Schemes Regulations 2027 and the dual-use factor document.
- **31 Dec 2026:**  the Commission's PPWR Article 7(8), 7(9) and 7(10) acts fall due on the Green Forum timeline.
- **No date set:**  HMRC notices on audit timing, dual-use factor evidence and the pipeline test, and confirmed default dual-use factors.
- **1 Apr 2027:**  UK certified mass balance starts, pre-consumer plastic stops counting and the tax rises to GBP 236.56 per tonne.
- **21 Nov 2027:**  EU bottle method starts counting recycled plastic from OECD-decision countries.
- **1 Jan 2030:**  Commission review of Decision 2026/1425 due at the latest; the 30% all-bottle average applies from 2030.
- **1 Apr 2030:**  UK certification becomes mandatory for mechanically recycled plastic.

## Methodology

- **Data used:**  SPI rules [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/) and [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/), with [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) and SPI's United Kingdom jurisdiction record; the SPI Packaging Buyers Database profiles for ALDI UK, Danone and Mondelez; HMRC's draft regulations, consultation page, dual-use factor document, policy paper, consultation outcome, statistics and scope guidance; the Budget 2026 rates annex; the Official Journal text of Decision (EU) 2026/1425; the Commission press release and Green Forum timeline; consulted 14 to 31 October 2026.
- **UK text:**  the draft regulations were read in HMRC's accessible version. The conversion factor in draft regulation 3 and the formula in draft regulation 5 appear only as images there, so SPI has not yet confirmed their terms. The draft does not state a rule on negative balances or on feedstock origin in the text SPI read.
- **EU text:**  Decision 2026/1425 was read in the Official Journal PDF and the adopted act. The five-year record rule is taken from SPI rule [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/), and SPI has not yet confirmed it against every annex of the decision.
- **Calculations:**  bottle weights, yields and dual-use factors are SPI assumptions for illustration. Shares are recycled grams over plastic grams; tax is tonnes times GBP 236.56. All are by SPI's calculation and in GBP only.
- **Cut-off:**  31 October 2026.
- **Limitations:**  this is SPI's reading of draft and official texts, not legal or tax advice. SPI does not test, audit or certify packaging, recycled content or schemes. Check with counsel before relying on any treatment.

## Sources

1. HM Revenue and Customs, Draft Plastic Packaging Tax (Chemical Recycling Certification Schemes) Regulations 2027, accessible version, 6 October 2026, [https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach/draft-legislation-accessible-version](https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach/draft-legislation-accessible-version), consulted 2026-10-31.
2. HM Revenue and Customs, Draft legislation: Plastic packaging tax, chemical recycling and adoption of a mass balance approach, 6 October 2026, [https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach](https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach), consulted 2026-10-31.
3. HM Revenue and Customs, Dual-use factors for refinery and petrochemical output products, version 0.1, published 6 October 2026, [https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach/dual-use-factors-for-refinery-and-petrochemical-output-products](https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach/dual-use-factors-for-refinery-and-petrochemical-output-products), consulted 2026-10-31.
4. HM Revenue and Customs, Plastic Packaging Tax: mass balance approach and removal of pre-consumer plastic, policy paper, 26 November 2025, [https://www.gov.uk/government/publications/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic](https://www.gov.uk/government/publications/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic), consulted 2026-10-31.
5. HM Revenue and Customs, Plastic Packaging Tax: potential certification for mechanically recycled plastic packaging, consultation outcome, 28 October 2026, [https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging/outcome/plastic-packaging-tax-potential-certification-for-mechanically-recycled-plastic-packaging](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging/outcome/plastic-packaging-tax-potential-certification-for-mechanically-recycled-plastic-packaging), consulted 2026-10-31.
6. HM Treasury and HM Revenue and Customs, Budget 2026 overview of tax legislation and rates, Annex A: rates and allowances, 28 October 2026, [https://www.gov.uk/government/publications/budget-2026-overview-of-tax-legislation-and-rates-ootlar/annex-a-rates-and-allowances](https://www.gov.uk/government/publications/budget-2026-overview-of-tax-legislation-and-rates-ootlar/annex-a-rates-and-allowances), consulted 2026-10-31.
7. legislation.gov.uk, Finance Act 2021, section 49A, [https://www.legislation.gov.uk/ukpga/2021/26/section/49A](https://www.legislation.gov.uk/ukpga/2021/26/section/49A), consulted 2026-10-31.
8. legislation.gov.uk, Finance Act 2021, Part 2 (Plastic packaging tax), [https://www.legislation.gov.uk/ukpga/2021/26/part/2](https://www.legislation.gov.uk/ukpga/2021/26/part/2), consulted 2026-10-14.
9. HM Revenue and Customs, Plastic Packaging Tax (PPT) statistics commentary, updated 27 August 2026, [https://www.gov.uk/government/statistics/plastic-packaging-tax-ppt-statistics/plastic-packaging-tax-ppt-statistics-commentary](https://www.gov.uk/government/statistics/plastic-packaging-tax-ppt-statistics/plastic-packaging-tax-ppt-statistics-commentary), consulted 2026-10-31.
10. HM Revenue and Customs, Packaging in and out of scope of Plastic Packaging Tax, [https://www.gov.uk/government/publications/examples-of-packaging-in-and-out-of-scope-of-plastic-packaging-tax/packaging-in-and-out-of-scope-of-plastic-packaging-tax](https://www.gov.uk/government/publications/examples-of-packaging-in-and-out-of-scope-of-plastic-packaging-tax/packaging-in-and-out-of-scope-of-plastic-packaging-tax), consulted 2026-10-31.
11. European Commission, Implementing Decision (EU) 2026/1425 of 30 June 2026 on calculating, checking and reporting recycled plastic content in single-use plastic beverage bottles, OJ L, 3 July 2026, [https://eur-lex.europa.eu/eli/dec_impl/2026/1425/oj/eng/pdf](https://eur-lex.europa.eu/eli/dec_impl/2026/1425/oj/eng/pdf), consulted 2026-10-31.
12. Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment, Article 6(5) and Annex Part F, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0904](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0904), consulted 2026-10-14.
13. European Commission, Commission clarifies rules on plastic bottles recycling, press release IP/26/1467, 30 June 2026, [https://ec.europa.eu/commission/presscorner/detail/en/ip_26_1467](https://ec.europa.eu/commission/presscorner/detail/en/ip_26_1467), consulted 2026-10-31.
14. European Commission Green Forum, Packaging and Packaging Waste Regulation implementation, [https://green-forum.ec.europa.eu/green-business/packaging-and-packaging-waste-regulation-implementation_en](https://green-forum.ec.europa.eu/green-business/packaging-and-packaging-waste-regulation-implementation_en), consulted 2026-10-31.
15. LexisNexis, Commission opens consultations on supplemental rules governing plastic packaging recycling, 18 August 2026, [https://www.lexisnexis.co.uk/legal/news/commission-opens-consultations-on-supplemental-rules-governing-plastic-packaging-recycling](https://www.lexisnexis.co.uk/legal/news/commission-opens-consultations-on-supplemental-rules-governing-plastic-packaging-recycling), consulted 2026-10-31.
16. S&P Global Commodity Insights, EU approves targets for chemical recycling content for plastic bottles, 9 February 2026, [https://www.spglobal.com/energy/en/news-research/latest-news/chemicals/020926-eu-approves-targets-for-chemical-recycling-content-for-plastic-bottles](https://www.spglobal.com/energy/en/news-research/latest-news/chemicals/020926-eu-approves-targets-for-chemical-recycling-content-for-plastic-bottles), trade press, paraphrased, consulted 2026-10-31.
17. ERP, SUPD: Implementing act clarifies recycled content calculation for PET bottles, 11 March 2026, [https://erp-recycling.org/news-and-events/2026/03/supd-implementing-act-clarifies-recycled-content-calculation-for-pet-bottles/](https://erp-recycling.org/news-and-events/2026/03/supd-implementing-act-clarifies-recycled-content-calculation-for-pet-bottles/), consulted 2026-10-31.
18. SPI Regulation Tracker, PR-GB-001 (UK Plastic Packaging Tax) and PR-EU-016 (EU single-use plastic bottle recycled content), /data/packaging-regulation-tracker/united-kingdom/pr-gb-001/ and /data/packaging-regulation-tracker/european-union/pr-eu-016/, record data as of 14 October 2026, consulted 2026-10-31.
19. SPI Packaging Buyers Database, ALDI UK, Danone and Mondelez profiles, /data/packaging-buyers-database/, profile data as of 14 October 2026, consulted 2026-10-31.
20. SPI News, HMRC will require certified mechanically recycled plastic for Plastic Packaging Tax from April 2030; pre-consumer scrap stops counting in 2027, 30 October 2026, /news/uk-plastic-packaging-tax-recycled-certification-2030/, consulted 2026-10-31.