Plastic Packaging exempt or excluded from Plastic Packaging Tax

23rd March 2022

Below are the specific types of packaging which are exempt from the Packaging Tax.

However, the generic definitions of plastics which are exempt from the tax are as follows:

• Plastics which are printed as being fully recyclable, which the recycling motif printed on them;
• Plastics designated as being for end-use (e.g. transport, containers for beverages etc., international transit etc – see below);
• Processing, i.e. as part of a production process.
• Plastics accompanied by a laboratory certificate stating their eligibility for recycling.   

Packaging exempt from the tax

There are 4 categories of packaging exempt from the tax. They are products:

• Used for the immediate packaging of licensed human medicine
• Permanently recorded as set aside for non-packaging use
• Used as transport packaging to import multiple goods safely into the UK
• Used in aircraft, ship and rail goods stores

Exempt packaging which counts towards the 10-tonne threshold for registration

Plastic packaging used for human medicinal products, and plastic packaging permanently recorded as set aside for non-packaging use, must be included when working out the total weight of packaging manufactured or imported.

Plastic packaging for human medicinal products

Plastic packaging manufactured or imported for the immediate packaging of licensed human medicinal products is not subject to Plastic Packaging Tax.

Immediate packaging is a container (or other form of packaging) that is immediately in contact with a product when it is produced.

A medicinal product is for use by people to:

• Prevent or treat diseases
• Restore, correct or modify a physiological function by exerting a pharmacological, immunological or metabolic action
• Make a medical diagnosis

A medicinal product must be licensed by the Medicines and Healthcare Products Regulatory Agency.

You can find out more about medicinal products in the Human Medicines Regulations 2012.

Plastic packaging components permanently recorded as set aside for non-packaging use

Plastic packaging components permanently recorded as set aside to be used for something other than packaging, are not subject to Plastic Packaging Tax. For example, plastic film that will be used to coat whiteboards.

This exemption includes products that are primarily used for something other than packaging, such as film to enable the fermentation process to take place to make silage.

HMRC expect this exemption to apply to a small number of highly specialised products. You must provide clear evidence to verify any claim for this exemption.

You must record them as set aside before or as soon as they have been manufactured or imported, and you must keep records to show this.

Exempt packaging which does not count towards the 10-tonne threshold for registration

Plastic packaging used for transporting imported goods, and for stores on international aircraft, ship and rail journeys, does not need to be included when working out the total weight of packaging manufactured or imported.

In both cases, the exemption is determined by how the packaging is used rather than the type of packaging.

Transport packaging on imported goods

Plastic Packaging Tax is not charged on transport packaging (also known as tertiary packaging) used in the delivery of goods into the UK.

You do not need to account for it on your tax return, as long as it is either a:

• Road, rail, ship or air container

Packaging component that is used to both:

• Transport multiple sales units or grouped packaging
• Prevent damage during transportation

This exemption applies to transport packaging used for preventing damage during shipment to the UK.

This exemption does not apply to:

• Normal packaging around a sales unit
• Normal packaging around a number of sales units
• Unfilled transport plastic packaging imported as an item in its own right

Packaging used to:

• Prevent damage to a single good on import
• Transport goods within the UK
• Transport goods out of the UK

Find examples of transport packaging used to import goods into the UK.

Packaging used for stores on international aircraft, ship and rail journeys

Plastic Packaging Tax is not charged on packaging products that are used in stores for international journeys. These can be stores on aircraft, ship or railway vehicles.

If the plastic packaging is subsequently imported (removed from stores and released into the UK) the import will have to be recorded, along with the weight and recycled content of the packaging.

Find more information about what are classed as stores.

Packaging excluded from the tax

There are 3 types of products excluded from the tax. These do not need to be included when working out the total weight of packaging manufactured or imported.

They are products which are deigned to be:

• Used in the long-term storage of goods
• An integral part of the goods
• Reused for the presentation of goods

Plastic packaging designed to be used for the long-term storage of goods

Plastic packaging with the primary use of storing goods long-term, is not subject to Plastic Packaging Tax and you do not need to account for it on your tax return.

This packaging is designed:

• As suitable to be filled when the goods it is designed to contain are sold
• As suitable to be re-used for the storage of the same or similar goods
• So that its packaging function is secondary to its storage function

Examples include:

• Toolboxes
• First aid boxes
• Earphone or earbud cases

Find more examples of packaging designed to be used for long-term storage of goods.

This exemption does not apply to any packaging designed with the expectation of being discarded after the goods contained in the packaging at the time of sale have perished or been consumed.

Plastic packaging designed to be an integral part of the goods

Plastic packaging components which are an integral part of the goods, are not subject to Plastic Packaging Tax and you do not need to account for them on your tax return.

A packaging component is an integral part of the goods where both the:

• Goods cannot reasonably be used or consumed without the component
• Component is expected to be discarded once the goods (of which it is a part of) are used, consumed or discarded

Examples include:

• Water cartridge filters
• Printer or toner cartridges
• Inhalers

Other plastic packaging in place when the product is sold, which does not stay in place while the product is used (such as a film wrap on a CD case), is still subject to the tax.

A packaging component is not an integral part of the good by virtue of performing a packaging or storage function. For example, a tray for a ready meal is not integral to the meal, as it still provides a packaging function and the food can be heated and consumed using another dish.

Find more examples of packaging which is designed to be an integral part of the goods.

Plastic packaging which is primarily designed to be reused for the presentation of goods

Plastic packaging designed for the presentation of goods to a consumer or user (that is recorded as permanently set aside for this purpose before, or as soon as, it’s manufactured or imported), is not subject to Plastic Packaging Tax and you do not need to account for it on your tax return.

Examples include:

• Sales display shelf
• Shop fittings
• Sales presentation stand

Find more examples of packaging which is primarily designed to be reused for the presentation of goods.

Exporting plastic packaging

You can defer paying the tax for up to 12 months if the packaging is going to be exported.

Plastic packaging designed for use in the Supply Chain

This is packaging designed to be used in the supply chain from the manufacturer to the user or consumer. It is used for the containment, protection, handling, delivery, or presentation of goods.

You can read the definition of packaging designed for use at any stage in the supply chain.

If the packaging component meets this definition, it does not matter if it is produced or imported for use in the supply chain of the goods, or by a consumer or user.

Examples of items of this type, that are subject to the tax, include:

• Bottles designed for single use (even if they can be refilled and reused)
• Bottle tops or caps
• Labels designed to present the goods and describe the contents of a product
• Trays designed to contain and protect food, such as ready meal trays
• Film designed to protect produce, such as film around raw meat
• Pots designed to handle and deliver products, such as yoghurt and soup pots (the lids of these products are separate packaging components in their own right)
• Wrap designed to group products together for easier handling, such as shrink wrap around canned goods
• Reusable plastic crates designed to deliver fresh fruit or baked goods
• Flexible food pouches
• Film windows on items just as sandwich or quiche packets
• Salad bags
• Crisp packets
• Biscuit wrappers
• Pallet wrap
• Plastic film around a box to protect the box and the contents (alcohol and cigarettes usually have these)
• Pick bins used in warehouses
• Tamper proof seals
• Clothes hangers designed for use in the supply chain
• Plant pots designed to be sold with plants inside
• Kimble tags designed for labelling or pricing goods

Examples of items that do not meet this definition and are not subject to the tax include:

• Food storage boxes and containers designed to be reused, such as lunch boxes
• Drinks bottles designed to be reused
• Plastic cutlery
• Reusable coffee cups
• Reusable medical sharps bins
• Pipe insulation
• Cable trunking
• Plastic file sleeves
• Light bulbs
• Toy and storage boxes
• Bags for life
• Bag resealing clips
• Mop buckets
• Home storage boxes

Plastic packaging designed as single use consumer packaging

This is packaging designed to be used once by a consumer or domestic user in containing any item or waste.

You can read the definition of single use packaging.

Examples of items covered by this category of products, that are subject to the tax, include:

Plastic bags including:

• Carrier bags
• Bin liners and refuse sacks
• Food bags (such as sandwich bags)
• Nappy sacks

Disposable cups including:

• Expanded polystyrene cups
• Vending machine cups
• Plastic wine and pint glasses
• Party cups
• Disposable plastic bowls and plates
• Gift wrapping such as ribbon and sticky tape
• Ready meal and vegetable pouches and packets
• Medical sharps bin (single use)

Examples of items not covered by this category of products, that are not subject to the tax, include disposable:

• Nappies
• Urine bags
• Cutlery

Plastic packaging where the primary function is for storage

This packaging is not subject to Plastic Packaging Tax.

You can read the definition of plastic packaging where the packaging function is secondary to the storage function.

Examples of items covered by this category of products, that are not subject to the tax, include:

• Toolboxes
• First aid boxes
• Earphone or earbud cases
• Manicure sets
• Glasses cases
• CD, DVD, and video game cases
• Board game boxes

Examples of items not covered by this category of products, that are subject to the tax, include:

Single use bottles, such as for:

• Soft drinks
• Condiments
• Cleaning products
• Hair and beauty products
• Bath and shower products

Disposable pots and tubs, such as:

• Yoghurt pots
• Ice cream tubs
• Butter and food spreads
  
  
• Plates (designed to be sold with food)
• Trays (sold with food, for example, ready meals or takeaway)
• Resealable food packaging (such as that sold containing cheese or pasta)
• Plastic packs, which pens and pencils are sold in

Plastic packaging that is an integral part of the goods

This packaging is not subject to Plastic Packaging Tax.

You can read the definition of plastic packaging where the packaging is an integral part of the goods.

Examples of items covered by this category of products, that are not subject to the tax, include:

• Water filter cartridges
• Refillable room deodorisers
• Printer and toner cartridges
• Inhalers
• Lighters
• Ink cartridges and ink refills
• Dental floss cases
• Tea bags
• Perforated rice bags
• Mascara brush, wand, and cap (but not the bottle)
• Lipstick mechanism and case (but not the cap)
• Pump containers for toothpaste (but not toothpaste tubes)
• The roller ball of roll-on deodorant
• Stick deodorant
• Coffee capsules
• Aerosol actuators
• Droppers and pipettes, such as for eye drops and flea treatments

Examples of items not covered by this category of products, that are subject to the tax, include:

• Ready meal trays
• Pots for ‘food on the go’
• Flexible pouches and resealable packaging, such as pet food pouches and chocolate bags
• Microwave food pouches, such as for vegetables
• Coat hangers designed for use in the supply chain
• Liquid soap pumps
• Closures on condiment bottles and jars
• Grow bags
• Intermediate bulk containers (IBCs)

Plastic packaging to be reused primarily for presentation

This packaging is not subject to Plastic Packaging Tax.

You can read the definition of plastic packaging where the packaging is designed primarily to be reused for the presentation of goods.

Examples of items covered by this category of products, that are not subject to the tax, include:

• Shop fittings
• Sales display shelves
• Sales presentation stands
• Reusable meal trays, such as those used on aeroplanes and in schools

Examples of items not covered by this category of products, that are subject to the tax, include:

• Crates for food, such as those for fruit and vegetables
• Single use:
• Display shelves
• Presentation stands
• Meal trays, such as those used on aeroplanes and in schools

Plastic packaging permanently set aside for a non-packaging use

This specialised packaging and its components are exempt from plastic packaging tax. This includes products that are primarily used for something other than packaging.

You can read the definition of plastic packaging components which are recorded as permanently set aside to be used for something other than packaging.

Examples of items covered by this exemption and are not subject to the tax include film used to:

• Coat whiteboards
• Enable the fermentation process to make silage

Examples of items not covered by this exemption and that are subject to the tax include:

• Ready meal oven trays
• Microwave food pouches

Transport packaging

Transport packaging used to import goods into the UK is exempt from Plastic Packaging Tax if it is used to both:

• Transport multiple sales units or grouped packaging
• Prevent damage during transportation

You should consider how this packaging it used, rather than the type of packaging it is, when determining if the exemption applies. Find out more about when transport packaging is exempt.

Examples of items covered by this exemption (when used to prevent damage of multiple sales units or grouped packaging imported into the UK) include:

• Road, rail, ship or air containers used to import goods into the UK
• Pallet wrap
• Straps
• Plastic pallets

Examples of items not covered by this exemption, that are subject to the tax, include:

• Crates that act as primary or secondary packaging, and are used for transporting goods into the UK for delivery to a consumer or supplier (this includes items such as fruit and vegetables)
• Transport packaging:
• Used to transport goods within the UK
• Manufactured in the UK
• Imported into the UK as goods in their own right
• Used to import a single good into the UK
• Large containers used to import alcohol to be bottled

Mark Rowbotham.  The Sheffield International Trade Centre.  March 2022

For more information please contact International@scci.org.uk