Records and submissions under the new Plastic Packaging Tax
Description

This is a new tax that will apply from the 1 April 2022 to businesses that use plastic packaging manufactured in, or imported into the UK, that does not contain at least 30% recycled plastic. Plastic packaging is packaging that is predominantly plastic by weight.

Cause
Resolution

Who needs to register?

You need to register for the Plastic Packaging Tax if you’ve manufactured or imported 10 or more tonnes of finished plastic packaging components within the last 12 months, or will do so in the next 30 days.

There are two tests to check this that you can utilise from HMRC’s website, looking back at the last 12 months or looking forward to the next 30 days.

TIP: If you're unsure what counts as plastic packaging please view HMRC's guidance.


When do you need to register?

Registration will not be open until 1 April 2022, but if you think you fall within this threshold you must register before 30 April 2022 even though the first report will not be due until July 2022. If you become liable for this tax at a later date, you must register within 30 days of becoming liable. 


When will the returns be due?

Your returns must cover an accounting period. The accounting periods are:

  • 1 April to 30 June
  • 1 July to 30 September
  • 1 October to 31 December
  • 1 January to 31 March

You must submit the return and pay any tax due no later than the last working day of the month following the end of the accounting period being reported.

The format of these returns is still to be determined by HMRC but following these rules of what will be included will help you to determine what records you need to keep. However, this is just guidance and we strongly advise if this tax applies to your business you seek the advice of a tax consultant.


What information will I need to include in the return?

  • The total weight of finished plastic packaging components manufactured in the UK in the accounting period
  • The total weight of finished plastic packaging components imported into the UK in the accounting period
  • The total weight of finished plastic packaging components not subject to the tax in the accounting period
  • The total weight of finished plastic packaging components manufactured or imported for use in the immediate packaging of licenced human medicines in the accounting period
  • The total weight of finished plastic packaging components manufactured or imported in this accounting period which are due for export by you
  • The total weight of any finished plastic packaging components that contain at least 30% recycled plastic content in the accounting period
  • The total value of taxed plastic packaging components for which a credit is being claimed in the accounting period
  • Credits will be for packaging components where tax has been paid in a previous accounting period and has subsequently been exported or has been converted into a different plastic packaging component.
  • The time limit for claiming a tax credit is 2 years from the manufacture or import of the plastic packaging component.
  • The total weight of chargeable plastic packaging components after deductions

What records will I need to keep?

There is a lot of detailed record keeping that you must now keep at a product line level, for at least 6 years in written (includes electronic) form.

If you think you will be liable for this tax at any point, it would be good practice to start keeping these records now as you may be asked to prove why you are exempt.

You must keep accounts showing how you’ve worked out each entry on your quarterly tax return. Where relevant, your accounts must include:

  • A breakdown of the weight of plastic packaging components finished or imported in each period
  • The weight of plastic packaging exported in the period on which the tax was deferred
  • A breakdown of the weight of any plastic packaging for which a credit is claimed if the packaging has been:
       - Exported.
       - Converted into new packaging components.
  • Any adjustments or corrections made to previous accounting periods — you must include the date and the accounting period they relate to
  • You must keep accounts by reference to each ‘product line’ that you produce or import. A ‘product line’ is a group of plastic packaging components produced to the same specification.

Your accounts must show how you’ve worked out the figures you submit on your return. Your records must show the evidence to support these figures.


What records will I need to keep for products that are exempt?

Plastic packaging components are not chargeable for Plastic Packaging Tax when they contain at least 30% recycled plastic as a proportion of the total weight of plastic. If you want to claim this exemption, you must have records that:

  • Show how you’ve worked out the percentage of recycled plastic
  • Provide sufficient supporting evidence that recycled plastic was used
  • Show which dates the evidence relates to, such as the dates that the components were finished or imported
  • Show which plastic packaging component the percentage relates to, including product lines or production runs
  • Are an accurate reflection of the proportion of recycled plastic contained in the output materials of that recycling process
  • Confirm the source of the recycled plastic 

What records will I need to keep for products that I am deferring tax on?

If you want to defer paying Plastic Packaging Tax for components you intend to export, you must keep records that show you intend to export them.

The records must be either a document:

  • Used for any other tax or duty
  • Which clearly identifies the components to be exported, such as a sales contract or order

The records must:

  • Be dated at or before the time of production or import
  • Include details that allow the plastic packaging components you intend to export to be identified
  • Include the weight of the plastic packaging components which you intend to export

Further resources

Further product specific information will be available soon in our Help Centre >


NOTE: This information is subject to change from HMRC – You can find the guidance from HMRC here and this should be your source of truth when determining if you are liable for Plastic Packaging Tax. 


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