Plastic Packaging Tax (‘PPT’) and the public sector – Requirement to Notify HMRC

PPT came into effect on 1 April 2022, requiring people, who manufactured more than 10 tonnes of taxable products in the previous year or who imported that weight of product over the same period, to notify HMRC and register for the tax.

While the principles of PPT are pretty straightforward – to tax products that contain less than 30% recycled plastic to encourage recycling – determining what products are taxable and who must register has proven to be rather more complicated.

We now understand that HMRC may be concerned about the number of PPT registrations. Having expected 10s of thousands of registrations, it seems that the number of applications to register were only some 10% of projected numbers, and HMRC are keen to identify the rest.

The public sector is not wholly excluded from PPT. Local authorities, government departments, charities, colleges and universities who import or make plastic products for use in their business activities, will be registerable for PPT, unless they are able to justify to HMRC that they fall below the registration volumes or that their suppliers are taking responsibility for PPT.

It is particularly important, therefore, that these bodies:

1. Review the volume of plastic products they make, buy or import;

2. Determine to what extent these are directed towards business and non-business use, and;

3. Consider whether the plastic used for business activities requires them to register for the tax, or;

4. Undertake due diligence into their suppliers of plastic products that is sufficiently detailed that HMRC would accept that the supplier has responsibility for the tax.

Our experience of environmental taxes and PPT means that we can help identify your exposure to PPT registration.

For instance, we can:

• Help you identify which products fall into PPT;
• Assist with devising a business/non-business apportionment method;
• Help with due diligence steps to provide comfort that PPT may not be your responsibility, and if necessary;
• Advise regarding PPT registration and compliance.

If you are unaware of your PPT status or would like some assistance to prove that you don’t have responsibility for PPT, please get in touch at emailus@centurionvat.com or contact your usual Centurion advisor.

For the avoidance of doubt, the content recorded in this news article does not constitute formal advice and we do not guarantee the accuracy of any information provided at the time of reading. It is always recommended that you seek professional advice before acting on any of the news articles or information included.