# The UK and Spain tax the same plastic pack in opposite ways, so a redesign that removes one tax can leave the other

> The UK (and the Isle of Man) charge GBP 228.82 per tonne on the whole weight of any plastic packaging component under 30% recycled plastic, Spain charges EUR 0.45 per kg on the non-recycled plastic in non-reusable packaging, and the EU's EUR 0.80 per kg plastic own resource is paid by Member States, not companies.

Publisher: Strategic Packaging Insights  
Published: 2026-10-14  
Last updated: 2026-10-14  
Page: https://www.strategicpackaginginsights.com/insights/plastic-packaging-taxes-2026/

**The UK (and the Isle of Man) charge GBP 228.82 per tonne on the whole weight of any plastic packaging component under 30% recycled plastic, Spain charges EUR 0.45 per kg on the non-recycled plastic in non-reusable packaging, and the EU's EUR 0.80 per kg plastic own resource is paid by Member States, not companies.**

Plastic packaging taxes are often confused with EPR fees, but they are government levies tied to how much virgin or non-recycled plastic a pack contains, and a company selling into the UK or Spain can owe both. Strategic Packaging Insights (SPI) set the 4 tax rules in the SPI Regulation Tracker against the tax rows in the SPI EPR & Plastic Tax Calculator, HMRC's latest tax statistics and company disclosures, and priced the same packs under each one.

## Executive summary

Three charges in SPI's data put a price on plastic packaging that is not recycled: the UK Plastic Packaging Tax (mirrored by the Isle of Man), Spain's tax on non-reusable plastic packaging, and the EU plastic own resource. They share a purpose but not a design, and the difference decides which redesign saves money.

The UK tax is a switch. A component under 30% recycled plastic pays GBP 228.82 per tonne on its whole weight; at 30% it pays nothing. Spain's tax is a slope: EUR 0.45 on every kilogram of non-recycled plastic, so each certified point of recycled content lowers the bill. The EU charge is a slope too, but governments pay it, at EUR 0.80 per kilogram of plastic packaging waste that is not recycled.

The UK switch is working on volume. HMRC's statistics for 2025-26 show 2,970 thousand tonnes of plastic packaging declared, of which 1,107 thousand tonnes (37.3%) were taxable and 1,506 thousand tonnes (50.7%) met the 30% test, up from 37.6% in 2022-23 (Exhibit 3). Receipts fell 4%, to GBP 250 million, even as the rate rose.

Two changes are now dated. From 1 April 2027 pre-consumer plastic stops counting towards the UK 30% test, and chemically recycled plastic can count under a certified mass balance approach; comments on the draft rules close at 11:59pm on 21 December 2026. In the EU, COM(2025) 574 would raise the own resource to EUR 1 per kg from 2028 and end the lump-sum reductions that 17 Member States receive, including EUR 142 million a year for Spain.

For leaders, the work is per component, not per company. Group averages such as 27% at Colgate-Palmolive or 18% at Kimberly-Clark say little about which UK components pass the line (Exhibit 7). A pack sold in both markets needs two calculations, and a supplier that relies on pre-consumer scrap to reach 30% needs a plan before April 2027.

## Key findings

1. The UK Plastic Packaging Tax is GBP 228.82 per tonne from 1 April 2026, up from GBP 200 at its start on 1 April 2022, an increase of 14.4% over four April uprating rounds (GOV.UK, consulted 14 October 2026; [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)).
2. In 2025-26, 1,107 thousand tonnes of the 2,970 thousand tonnes declared were taxable (37.3%), against 1,399 thousand tonnes (40.8%) in 2022-23, and PPT receipts were GBP 250 million, 4% below 2024-25 (HMRC PPT statistics, 27 August 2026).
3. The UK taxes the whole weight of a component that is under 30% recycled plastic; Spain taxes only the non-recycled plastic inside it, at EUR 0.45 per kg (GOV.UK guidance, updated 28 August 2026; Agencia Tributaria; [PR-ES-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-001/)).
4. From 1 April 2027, pre-consumer plastic stops counting as recycled for the UK tax and chemically recycled plastic can count under certified mass balance; HMRC's draft regulations are open for comment until 21 December 2026 (HMRC, 26 November 2025 and 6 October 2026).
5. EU Member States have paid EUR 0.80 per kg of non-recycled plastic packaging waste since 1 January 2021; COM(2025) 574 would raise this to EUR 1 per kg in 2028, index it to inflation and end the 17 lump-sum reductions, and on 14 October 2026 the procedure showed "awaiting committee decision" ([PR-EU-018](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-018/)).
6. **SPI calculation:**  a converter with 1,000 tonnes of trays at 35% recycled content, 10 points of it pre-consumer, would move from no UK tax to GBP 228,820 a year from 1 April 2027 at the 2026 rate, while the same trays owe EUR 292,500 in Spain if all 35% is certified as recycled.

## What a plastic packaging tax is, and what it is not

An EPR fee pays for collecting and recycling packaging and goes to a producer responsibility scheme. A plastic packaging tax is a government levy, usually tied to how much virgin or non-recycled plastic a package contains, and it goes to the treasury. The same tray placed on the UK or Spanish market owes an EPR fee to PackUK or Ecoembes and a plastic tax to HMRC or the Agencia Tributaria. The [EPR fees per tonne article](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) covers the fee side; this piece covers the tax side.

The SPI Regulation Tracker holds 79 rules, of which 4 are tax rules: the UK Plastic Packaging Tax ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)), Spain's tax on non-reusable plastic packaging ([PR-ES-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-001/)), the EU plastic own resource ([PR-EU-017](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-017/)) and the proposed increase to it ([PR-EU-018](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-018/)). The SPI EPR & Plastic Tax Calculator holds 216 rate rows, among them tax rows for the UK, the Isle of Man and Spain, kept next to the EPR rates for the same markets. Coverage is growing, so this is not a complete list of every such tax worldwide.

Three questions decide the cost: what is weighed, how recycled content counts, and who is liable. The answers differ in every case below.

## United Kingdom: GBP 228.82 per tonne, with a 30% cliff edge

The UK Plastic Packaging Tax sits in Part 2 of the Finance Act 2021 and has applied since 1 April 2022. GOV.UK states: "The new rate for Plastic Packaging Tax from 1 April 2026 is £228.82 per tonne." Section 47 makes a finished component chargeable when its recycled plastic is less than 30% of the plastic in it, and section 45 now sets the rate as substituted by the Finance Act 2026 (legislation.gov.uk, consulted 14 October 2026; [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). The rate is uprated each April (Exhibit 2).

The 2026 step is GBP 5.13 per tonne, or 2.3%, against GBP 10.82 (5.4%) in 2023. Over four rounds the rate has risen 14.4%.

**What is taxed.**  A plastic packaging component is a product designed to be suitable for use in the supply chain, alone or with other products. A component made of several materials is plastic if it "contains more plastic by weight (including additives which form part of the plastic) than any other substance", with plastic measured against each other substance in turn. Tax is charged on each finished component and on the whole component, not only its plastic: GOV.UK's own example says the tax "is due on the entire 10g packaging component" (GOV.UK guidance, updated 28 August 2026).

**Who registers and pays.**  A business must register if it expects to import into or manufacture in the UK 10 tonnes or more of finished plastic packaging components in the next 30 days, or has done so in the last 12 months, and must notify HMRC within 30 days (Finance Act 2021, sections 55 and 56). The tax falls on the UK manufacturer or importer. Section 70 lets a supplier adjust payment under an existing contract when the tax applies, and section 59 lets HMRC impose secondary or joint and several liability on business customers in some cases ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)).

**What is out.**  GOV.UK lists four exemptions: immediate packaging of licensed human medicines, packaging permanently set aside for non-packaging use, transport packaging used to import goods, and packaging used in aircraft, ship and rail goods stores. It treats long-term storage packaging, packaging integral to the goods and packaging reused for presentation as excluded rather than exempt (GOV.UK exemptions page, consulted 14 October 2026).

**Penalties.**  Section 80 sets a GBP 500 fixed penalty plus GBP 40 for each further day a failure to meet a relevant requirement continues, such as records or statements; HMRC normally has four years to assess (Finance Act 2021, section 80 and Schedule 14).

## What HMRC's data show about the 30% line

HMRC's fourth annual statistics release, published on 27 August 2026, covers 2025-26 and splits every declared tonne by outcome (Exhibit 3). It counts 5,142 registered businesses as of 13 August 2026.

Three things stand out. Taxable tonnage fell 20.9% between 2022-23 and 2025-26 while declared tonnage fell 13.5%, so the taxable base shrank faster than the market. Tonnage at 30% or more recycled content rose 16.7% over the same period. And receipts fell from GBP 261 million in 2024-25 to GBP 250 million in 2025-26, a 4% drop, while the rate rose 2.7% (HMRC PPT statistics).

**SPI calculation:**  1,107 thousand taxable tonnes at the 2025-26 rate of GBP 223.69 gives about GBP 248 million, and 1,194 thousand tonnes at GBP 217.85 gives about GBP 260 million, close to the GBP 250 million and GBP 261 million HMRC reports. Among components that were either taxed or met the 30% test, the share meeting it rose from 48.0% in 2022-23 to 57.6% in 2025-26.

SPI analysis

The tax raises less each year because more tonnage clears the line, not because the rate is falling. That makes the definition of recycled plastic, which changes on 1 April 2027, the variable most likely to move both business costs and receipts.

**Why 30% is a cliff edge.**  The threshold works as a switch (Exhibit 4). A component at 29% recycled content is taxed on its full weight, and one at 30% is not taxed at all.

SPI analysis

For packaging close to the line, the evidence behind each component matters as much as the rate. Section 49 presumes plastic is not recycled unless shown otherwise, so a supply that sits at 28% to 32% recycled content can switch a customer's whole UK tax line on or off with one resin batch.

## Isle of Man: the same tax, kept at the same rate

The Isle of Man applies its own plastic packaging tax, which its Treasury describes as "an indirect tax applied to plastic packaging components produced in, or imported into, the Island". Its 3 March 2026 notice says: "From 1 April 2026, the rate of plastic packaging tax will increase from £223.69 per tonne to £228.82 per tonne." Under the 1979 Customs and Excise Agreement the UK and the Isle of Man are treated as one territory for VAT, customs and most excise duties (Isle of Man Government, consulted 14 October 2026).

Section 76 of the Finance Act 2021 links the two: a component that has borne an equal or higher Manx charge is not treated as imported into the UK, and a lower Manx charge is credited against UK tax. HMRC tells Island businesses to register with Isle of Man Customs and Excise rather than HMRC. The calculator row FEE-IM-001 records the same 30% test, and planning for it follows [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/).

## Spain: EUR 0.45 per kg of non-recycled plastic

Spain's special tax on non-reusable plastic packaging is set by Chapter I of Title VII of Law 7/2022 of 8 April, articles 67 to 83, and has applied since 1 January 2023 (BOE-A-2022-5809; [PR-ES-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-001/)). The Agencia Tributaria states: "El tipo impositivo aplicable es de 0,45 euros por kilogramo de plástico no reciclado" (the applicable rate is EUR 0.45 per kilogram of non-recycled plastic). EUR 0.45 per kg is EUR 450 per tonne.

**What is taxed.**  The tax base is "la cantidad de plástico no reciclado, expresada en kilogramos", and a product with several materials "solo tributa por el plástico no reciclado que contiene", only on the non-recycled plastic it contains (Agencia Tributaria, consulted 14 October 2026). The scope covers non-reusable packaging, empty or filled, semi-finished plastic products intended for packaging such as preforms and thermoplastic sheets, and plastic closures. The taxable events are manufacture, import and intra-EU acquisition.

**How it is collected.**  Manufacturers register each establishment and file form 592 for every period, including nil periods. Importers declare net kilograms of non-recycled plastic on the customs declaration and need not register. Intra-EU acquirers register once non-recycled plastic exceeds 5 kg in a calendar month (Agencia Tributaria, liquidación y pago).

**What is out.**  Exemptions cover certified recycled plastic; imports or intra-EU acquisitions where non-recycled plastic does not exceed 5 kg a month; and packaging for medicines, medical devices, special medical foods, hospital infant formula and hazardous healthcare waste, with silage rolls also out. Exempt uses depend on the buyer's prior declaration ([PR-ES-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-001/)).

**How recycled content is proved.**  Recycled plastic must be "certificada por entidad debidamente acreditada", certified by a duly accredited entity; a manufacturer's own declaration was accepted only in the first 12 months. False or incorrect certification is fined at 50% of the unpaid tax with a minimum of EUR 1,000, and misuse of an exemption declaration at 150% (Agencia Tributaria, consulted 14 October 2026).

Unlike the UK, Spain has no cliff edge. Every percentage point of certified recycled content lowers the bill in proportion: EUR 45 per tonne of plastic for each 10 points.

## Worked examples, country by country

Exhibit 5 prices the same packs under each national tax, each in its own currency; nothing is converted or added across currencies.

**Example A.**  One million trays of 25 g weigh 25 tonnes. At 20% recycled plastic each tray is below 30%, so the UK taxes the whole 25 tonnes: 25 x 228.82 = GBP 5,720.50. Spain taxes the 20,000 kg that is not recycled: 20,000 x 0.45 = EUR 9,000. At 30% (Example B) Spain charges EUR 7,875 and at 50% (Example C) EUR 5,625, while the UK charges nothing in both.

**Example D.**  GOV.UK's own example carton (4 g plastic, 3 g aluminium, 3 g cardboard) is a plastic component because plastic is its heaviest substance. One million of them weigh 10 tonnes, all taxed in the UK: GBP 2,288.20. Spain taxes the 4 tonnes of plastic only: EUR 1,800.

**Example E.**  In GOV.UK's second example (5 g plastic, 5 g cardboard) plastic is not heavier than the board, so the UK tax is zero. Spain still taxes the 5 tonnes of plastic: EUR 2,250.

SPI analysis

A redesign that adds board to tip a pack out of the UK tax can leave its Spanish bill unchanged, and a move from 20% to 30% recycled content cuts the UK bill by 100% but the Spanish bill by 12.5%.

## Four designs of plastic charge

The charges in SPI's data fall into four designs, set by two questions: who pays, and how recycled content counts (Exhibit 6). The design tells a packaging team which lever works.

**Switch.**  The UK design rewards the last few points of recycled content enormously and the rest not at all. A component at 29% and one at 0% pay the same; one at 30% pays nothing.

**Slope.**  Spain rewards each point equally, but only certified points; without the certificate chain, recycled resin is taxed as if it were virgin.

**Budget charge.**  The EU resource gives governments a fiscal reason to raise recycling, through national taxes, EPR fees or other tools, which Recital 7 of the 2020 Decision leaves to each Member State ([PR-EU-017](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-017/)).

**Product levy.**  Germany's Einwegkunststofffondsgesetz charges producers of products such as to-go food containers, cups and lightweight bags an annual levy into a fund that reimburses municipalities; the ordinance's explanatory part estimated revenue of up to EUR 436 million a year ([PR-DE-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-002/)). It is not a recycled-content tax, and the tracker classes it as EPR.

## How company disclosures sit against the UK line

The UK test is per component, but most companies report recycled content as a group or global average. Exhibit 7 sets the published figures in SPI's Buyers Database against the 30% line.

In practice: Mondelez.

Mondelez UK said on 16 May 2025 that Cadbury sharing-bar wrappers use 80% certified recycled material, allocated by a mass balance approach under ISCC rules, covering about 300 million bars a year on forecast 2026 sales and about 600 tonnes of post-consumer plastic. Its release says: "The new 80% certified recycled packaging has been sourced using advanced recycling technology." Whether those wrappers count as recycled for the UK tax depends on certification under the 2027 rules; SPI has not confirmed their tax treatment.

In practice: McDonald's.

McDonald's 1,507 UK restaurants use plastic cups made from 100% recycled material, according to its Purpose & Impact Report 2024-2025 and its 2025 restaurant count (SPI Packaging Buyers Database). On those cups the UK test is met by a wide margin, so the 1 April 2027 change matters only if any of that content is pre-consumer, which the report does not split.

In practice: Colgate-Palmolive.

Colgate-Palmolive reports 27% post-consumer recycled content across its packaging in 2025 (2025 Sustainability & Social Impact Report, 30 June 2026). A group average three points short of 30% says nothing about any single UK component; some will pass and some will not.

In practice: Tesco.

Tesco encouraged suppliers to use at least 30% recycled content in rigid plastic packaging where safe and feasible, published no progress figure, and is now retiring its voluntary packaging targets into a single 2035 commitment (SPI Packaging Buyers Database, Tesco profile). The 30% guidance matches the UK tax threshold.

## The tax on top of the EPR fee

Inside one currency the two charges can be added, which shows how much of the plastic bill each one carries (Exhibit 8). The UK figures use PackUK's illustrative Year 2 plastic fees, which are illustrative until PackUK confirms them in November 2026 ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)). The Spanish figures use Ecoembes 2026 rates from the calculator.

SPI analysis

In Spain the tax is the larger part of the plastic bill for rigid bottles and the smaller part for trays and film, because Ecoembes prices flexible plastic at 4.6 times its PET bottle line while the tax is flat. Recycled content pays twice in Spain: Ecoembes bonuses of up to 7.72% for some rigid plastics and a smaller base for the tax. In the UK, a tonne at 30% recycled content drops the GBP 228.82 tax entirely but keeps its EPR fee.

## Scenarios: the April 2027 change, one currency at a time

HMRC announced two changes in a policy paper on 26 November 2025, both from 1 April 2027. Pre-consumer plastic, recovered from manufacturing waste, stops counting towards the 30% threshold, and chemically recycled plastic can count under a certified mass balance approach. HMRC puts the Exchequer impact of the combined measure as negligible in every year to 2030-31.

Exhibits 9 and 10 apply the change to one supply line: a converter placing 1,000 tonnes of PET tray components a year. The mixes are SPI assumptions; the rates are published.

**SPI calculation:**  1,000 tonnes x GBP 228.82 = GBP 228,820 a year. The base case sits exactly on the line, so any drift in the post-consumer share would tip it into the high case.

SPI analysis

The April 2027 change does not touch the Spanish tax, so a converter supplying both markets faces a cliff in one and a slope in the other. In Spain the question is whether every recycled kilogram carries an accredited certificate; in the UK it is whether enough of it is post-consumer.

**The draft regulations.**  On 6 October 2026 HMRC published the draft Plastic Packaging Tax (Chemical Recycling Certification Schemes) Regulations 2027 for technical consultation, closing at 11:59pm on 21 December 2026. They are made under sections 49, 49A and 49B of the Finance Act 2021, as amended by the Finance Act 2026, and their coming-into-force date is still blank (Exhibit 11). A separate HMRC consultation, open from 18 May to 10 August 2026, asked about third-party certification for mechanically recycled plastic, with no start date set ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)).

## The EU plastic own resource: EUR 0.80 per kg, paid by governments

Since 1 January 2021, each EU Member State has paid into the EU budget a uniform call rate on "the weight of plastic packaging waste generated" minus the weight recycled. Council Decision (EU, Euratom) 2020/2053 states: "The uniform call rate shall be EUR 0,80 per kilogram" (EUR-Lex; [PR-EU-017](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-017/)). That is EUR 800 per tonne of non-recycled plastic packaging waste. Member States pay monthly on forecasts, corrected once final data reach Eurostat in July of year N+2. Article 2(2) grants annual lump-sum reductions, in 2020 prices, to 17 Member States (Exhibit 12).

**The proposed change.**  Commission proposal COM(2025) 574 of 16 July 2025 would set the rate at EUR 1 per kilogram in 2028 prices, update it with the EU GDP deflator, measure the base under Regulation (EU) 2025/40 rather than the repealed Directive 94/62/EC, and discontinue the lump-sum reductions (EUR-Lex; [PR-EU-018](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-018/)). The procedure file, consulted 14 October 2026, shows "awaiting committee decision", with the Committee on Budgets responsible and no Council activity recorded.

**SPI calculation:**  for a hypothetical Member State with 100,000 tonnes of non-recycled plastic packaging waste, the contribution is EUR 80 million at EUR 0.80 per kg and EUR 100 million at EUR 1, a rise of 25% before inflation indexing. A country with a reduction loses it as well; Spain's is EUR 142 million a year in 2020 prices. The tonnage is illustrative.

## Industry reaction

> "Figure 3 shows that taxable plastic packaging has consistently made up a minority share of total plastic packaging."

***HM Revenue and Customs** , official statistics, [Plastic Packaging Tax statistics commentary](https://www.gov.uk/government/statistics/plastic-packaging-tax-ppt-statistics/plastic-packaging-tax-ppt-statistics-commentary), 27 August 2026*

The same release puts 2025-26 receipts at GBP 250 million, 4% below 2024-25, without giving a cause.

> "will help to create the right fiscal conditions for investment in the emerging chemical recycling sector"

***HM Revenue and Customs** , policy paper, [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), 26 November 2025*

HMRC says businesses can keep using pre-consumer material after 1 April 2027, but it will no longer count towards the 30% threshold.

> "However, inflation has significantly reduced the real value of the revenue from this own resource."

***European Commission** , explanatory memorandum, [COM(2025) 574 final](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52025PC0574), 16 July 2025*

That is the Commission's case for moving from EUR 0.80 to EUR 1 per kg; the same text says the lump-sum reductions "will be discontinued".

> "is required to keep its Plastic Packaging Tax rate aligned with the UK rate"

***Isle of Man Government** , Treasury notice, [Plastic packaging tax rate to increase from 1 April 2026](https://www.gov.im/news/2026/mar/03/plastic-packaging-tax-rate-to-increase-from-1-april-2026/), 3 March 2026*

Any UK rate set for April 2027 is therefore the best guide to the next Manx figure.

## Charges that are not plastic packaging taxes in SPI's data

**Italy.**  The SPI Regulation Tracker holds no Italian plastic tax rule, and Italy appears in SPI's data through CONAI's EPR fees and its EUR 184.048 million lump-sum reduction. Trade press, including Argus Media and Plastics News, reports that Italy's tax on single-use plastic products has been postponed to 2027; SPI has not confirmed this in an official source, so it is not in the tracker, the calculator or this article's tables.

**EPR fees with plastic modulation.**  Schemes such as Citeo, Fost Plus and PackUK charge more for plastic or for hard-to-recycle plastic, but they are producer responsibility fees, not taxes; the [EPR fees per tonne article](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) compares them.

## What leaders should do now

1. **Converters and importers, by 31 December 2026:**  recalculate every UK component's recycled share without pre-consumer scrap, and list the components that fall below 30% on 1 April 2027.
2. **Procurement, by 1 April 2027:**  secure post-consumer or certified mass balance supply for any component in the high case of Exhibit 9, and write the evidence duty into supply contracts.
3. **Tax and compliance teams, by 21 December 2026:**  decide whether to comment on HMRC's draft mass balance regulations, especially on the dual-use factor and certificate checks.
4. **Brand owners selling into the UK and Spain, now:**  model each pack under both bases, whole weight below 30% in the UK and non-recycled kilograms in Spain, before approving any redesign.
5. **Spanish operations, each filing period:**  match every recycled kilogram to an accredited certificate and keep buyers' prior declarations for exempt sales, because the fines are 50% and 150% of the unpaid tax.
6. **Sustainability teams, from the next report:**  report recycled content per component and split pre-consumer from post-consumer, since group averages do not show tax exposure.
7. **Finance teams with EU exposure, in 2027 budgets:**  treat the EUR 1 per kg EU proposal as a reason governments may raise national plastic charges or EPR fees, without assuming it is adopted.

## Questions for your board

- How many tonnes of our UK components are below 30% recycled plastic today, and what is that line in GBP?
- How much of our recycled content is pre-consumer, and which components drop below 30% on 1 April 2027?
- Do we hold accredited certificates for every recycled kilogram we claim in Spain?
- Where do we rely on group averages rather than component data to judge tax exposure?
- Which suppliers can provide certified mass balance or post-consumer material, and at what lead time?
- How would a higher EU own resource, without lump-sum reductions, change national charges in our largest EU markets?

## What to watch

- **21 Dec 2026:**  HMRC's technical consultation on the draft mass balance regulations closes at 11:59pm ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)).
- **31 Dec 2026:**  the Commission's method for calculating and checking recycled content under the PPWR is due, a separate EU measure that will shape how recycled shares are evidenced ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)).
- **1 Apr 2027:**  pre-consumer plastic stops counting towards the UK 30% threshold and certified mass balance becomes available for chemically recycled plastic. A UK rate from that date had not been published on 14 October 2026.
- **Aug 2027:**  HMRC has published its PPT statistics each August since 2023; a 2026-27 release would be the first to show whether taxable tonnage kept falling before the April 2027 change.
- **1 Jan 2028:**  the EU plastic own resource would rise to EUR 1 per kg, without lump-sum reductions, if COM(2025) 574 is adopted ([PR-EU-018](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-018/)).

## Methodology

- **Data used:**  the 4 tax rules in the SPI Regulation Tracker and their SPI rule notes; the tax rows FEE-GB-025, FEE-IM-001 and FEE-ES-001 and the Ecoembes rows in the SPI EPR & Plastic Tax Calculator; HMRC's PPT statistics of 27 August 2026; SPI Packaging Buyers Database profiles; official pages consulted on 14 October 2026.
- **Counting rules:**  rates as published, in their own currency; per-kg rates x1,000 for per tonne; no currency conversion; totals only inside one currency; worked examples and scenarios use stated weights and recycled shares and assume no exemption applies.
- **Cut-off:**  14 October 2026.
- **Limitations:**  Spain's scope and exemptions rest on the Agencia Tributaria pages and the law's preamble; the UK draft regulations may change; PackUK's Year 2 fees are illustrative; the EU proposal is not adopted; company figures are averages with different scopes. Nothing here is tax or legal advice, and liability depends on facts SPI has not seen, so check with counsel and with HMRC or the Agencia Tributaria where it applies.

## Sources

1. GOV.UK, Plastic Packaging Tax: steps to take (check if you need to register), [https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax](https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax), consulted 2026-10-14.
2. GOV.UK, Work out which packaging is subject to Plastic Packaging Tax, last updated 28 August 2026, [https://www.gov.uk/guidance/work-out-which-packaging-is-subject-to-plastic-packaging-tax](https://www.gov.uk/guidance/work-out-which-packaging-is-subject-to-plastic-packaging-tax), consulted 2026-10-14.
3. GOV.UK, Check which plastic packaging is exempt from Plastic Packaging Tax, [https://www.gov.uk/guidance/check-which-plastic-packaging-is-exempt-from-plastic-packaging-tax](https://www.gov.uk/guidance/check-which-plastic-packaging-is-exempt-from-plastic-packaging-tax), consulted 2026-10-14.
4. GOV.UK (HMRC), Plastic Packaging Tax (PPT) statistics commentary, 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 2026-10-14.
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8. GOV.UK (HMRC), Plastic Packaging Tax: potential certification for mechanically recycled plastic packaging, consultation, 18 May 2026, [https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging/plastic-packaging-tax-potential-certification-for-mechanically-recycled-plastic-packaging](https://www.gov.uk/government/consultations/plastic-packaging-tax-mechanically-recycled-plastic-packaging/plastic-packaging-tax-potential-certification-for-mechanically-recycled-plastic-packaging), consulted 2026-10-14.
9. legislation.gov.uk, Finance Act 2021, Part 2 (Plastic packaging tax), as amended, [https://www.legislation.gov.uk/ukpga/2021/26/part/2](https://www.legislation.gov.uk/ukpga/2021/26/part/2), consulted 2026-10-14.
10. Isle of Man Government (Treasury), Plastic packaging tax rate to increase from 1 April 2026, 3 March 2026, [https://www.gov.im/news/2026/mar/03/plastic-packaging-tax-rate-to-increase-from-1-april-2026/](https://www.gov.im/news/2026/mar/03/plastic-packaging-tax-rate-to-increase-from-1-april-2026/), consulted 2026-10-14.
11. Agencia Tributaria, Impuesto especial sobre envases de plástico no reutilizables: base imponible, tipo impositivo y cuota tributaria, [https://sede.agenciatributaria.gob.es/Sede/impuestos-especiales-medioambientales/impuesto-especial-sobre-envases-plastico-reutilizables/base-imponible-tipo-impositivo-cuota-tributaria.html](https://sede.agenciatributaria.gob.es/Sede/impuestos-especiales-medioambientales/impuesto-especial-sobre-envases-plastico-reutilizables/base-imponible-tipo-impositivo-cuota-tributaria.html), consulted 2026-10-14.
12. Agencia Tributaria, Liquidación y pago del impuesto, inscripción y obligaciones contables, [https://sede.agenciatributaria.gob.es/Sede/impuestos-especiales-medioambientales/impuesto-especial-sobre-envases-plastico-reutilizables/liquidacion-pago-impuesto-inscripcion-obligaciones-contables___.html](https://sede.agenciatributaria.gob.es/Sede/impuestos-especiales-medioambientales/impuesto-especial-sobre-envases-plastico-reutilizables/liquidacion-pago-impuesto-inscripcion-obligaciones-contables___.html), consulted 2026-10-14.
13. BOE, Ley 7/2022, de 8 de abril, de residuos y suelos contaminados para una economía circular (BOE-A-2022-5809), [https://www.boe.es/buscar/act.php?id=BOE-A-2022-5809](https://www.boe.es/buscar/act.php?id=BOE-A-2022-5809), consulted 2026-10-14.
14. EUR-Lex, Council Decision (EU, Euratom) 2020/2053 of 14 December 2020 on the system of own resources, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32020D2053](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32020D2053), consulted 2026-10-14.
15. EUR-Lex, COM(2025) 574 final, proposal for a Council Decision on the system of own resources of the European Union, 16 July 2025, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52025PC0574](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52025PC0574), consulted 2026-10-14.
16. European Parliament Legislative Observatory, procedure file 2025/0574(CNS), [https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0574(CNS](https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0574(CNS)), consulted 2026-10-14.
17. GOV.UK (PackUK), Year 2 illustrative waste disposal fees, EPR for packaging, published 16 December 2025, updated 19 December 2025, [https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging](https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging), consulted 2026-10-14.
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19. Mondelez UK, Cadbury's iconic purple packaging is now using 80 percent recycled plastic, 16 May 2025, [https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/cadburys-iconic-purple-packaging-is-now-using-80-percent-recycled-plastic-3386958?site=uk](https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/cadburys-iconic-purple-packaging-is-now-using-80-percent-recycled-plastic-3386958?site=uk), consulted 2026-10-14.
20. McDonald's, Purpose & Impact Report 2024-2025, [https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonalds_PurposeImpact_ProgressReport_2024_2025.pdf](https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonalds_PurposeImpact_ProgressReport_2024_2025.pdf), via SPI Packaging Buyers Database, consulted 2026-10-13.
21. Colgate-Palmolive, 2025 Sustainability & Social Impact Report, 30 June 2026, [https://www.colgatepalmolive.com/content/dam/cp-sites-aem/corporate/corporate/common/pdf/cp-2025-ssi-report.pdf](https://www.colgatepalmolive.com/content/dam/cp-sites-aem/corporate/corporate/common/pdf/cp-2025-ssi-report.pdf), via SPI Packaging Buyers Database, consulted 2026-10-13.
22. SPI Packaging Buyers Database, profiles of Kimberly-Clark (2025 Sustainability Report), Nestlé (packaging sustainability progress), Reckitt (Sustainability Report 2025) and Tesco (Sustainability Factsheet: Packaging; Sustainability Report 2026), /data/packaging-buyers-database/, consulted 2026-10-14.
23. SPI Regulation Tracker and SPI rule notes PR-GB-001, PR-ES-001, PR-EU-017, PR-EU-018, PR-DE-002, PR-GB-003, /data/packaging-regulation-tracker/, consulted 2026-10-14.
24. SPI EPR & Plastic Tax Calculator, /data/epr-plastic-tax-calculator/, consulted 2026-10-14.
25. Trade press, for the Italy note only (not an official source): Argus Media, "Italy delays plastic tax to 2027", [https://www.argusmedia.com/en/news-and-insights/latest-market-news/2742946-italy-delays-plastic-tax-to-2027](https://www.argusmedia.com/en/news-and-insights/latest-market-news/2742946-italy-delays-plastic-tax-to-2027); Plastics News, "Italy postpones plastic tax 2027", [https://www.plasticsnews.com/news/italy-postpones-plastic-tax-2027/](https://www.plasticsnews.com/news/italy-postpones-plastic-tax-2027/), consulted 2026-10-14.