Plastic Packaging Tax for importers

An importer must register for Plastic Packaging Tax once the finished plastic packaging components imported on its behalf, together with any it makes in the UK, reach 10 tonnes in the previous 12 months or are expected to reach 10 tonnes in the next 30 days. Filled imports count component by component, excluding the goods inside; unfilled imports count once they are finished. Transport packaging on inbound shipments is left out of the count, but exempt medicine packaging and packaging with 30% or more recycled plastic are not.

Who is the importer for Plastic Packaging Tax?

Section 44 of the Finance Act 2021 makes the person on whose behalf a component is imported liable for the tax. HMRC’s guidance says this will generally be the consignee on the import documents, unless the consignee holds records showing that it is acting for someone else who controls the import and is only storing the goods for them. HMRC’s example is a haulier delivering packaging for a UK distributor: the distributor controls the order, so the distributor is liable.

Three practical points come out of this:

• A consignee that believes another business is liable should, as part of its due diligence, make sure that business is accounting for the tax.
• Where goods move under incoterms, the parties need to agree in writing who will include the components on a return and pay. The tax becomes chargeable at import but is accounted for quarterly in arrears, so it is easy for both sides to assume the other has it.
• A non resident business that imports finished components on its own behalf must register if it meets the threshold, in the same way as a UK business.

When does an import take place?

Under section 50, a component subject to customs formalities is imported as soon as all those formalities have been complied with; otherwise the time of importation for customs purposes applies. HMRC’s guidance describes this as the point at which the packaging has cleared all customs procedures, and confirms that imports from the Channel Islands, and from outside the UK into the Isle of Man, are included. The date decides two things: which month’s tonnage it falls into for the threshold, and which quarterly return it belongs on.

How are filled and unfilled imports treated differently?

Filled packaging

Packaging that arrives already filled with goods is treated as finished, and the importer is liable on every plastic component of it. HMRC’s example is a filled drinks bottle, where the bottle, cap and label are three separate finished components, all chargeable to the importer at the point of import. When weighing, you do not include the weight of the goods inside.

Unfilled packaging

For unfilled imports you must decide whether each component is already finished. A component is finished when it has undergone its last substantial modification, meaning a process that changes its shape, structure, thickness or weight. HMRC lists four processes that are never substantial modifications: blowing from a preform, cutting, labelling and sealing. So:

• Imported printed film that a UK customer only cuts and uses to wrap food is finished at import, and the importer is liable.
• Imported film that a UK business then laminates is not finished at import. HMRC’s example makes the laminator liable, and the importer has no charge on it.
• Imported bottle preforms have already been moulded, and blowing them into bottles is not a substantial modification, so on these rules they are finished when imported.

Unfinished components imported for further processing do not count towards the importer’s own threshold, because section 55 looks only at finished components. They will count for whichever UK business finishes them.

What counts towards the 10 tonne threshold?

Section 55 counts the weight of finished components produced by, or imported on behalf of, the business. Import and UK manufacture are added together. HMRC’s guidance on exemptions and on scope sets out what goes in and what stays out.

Item	In the threshold count?
Plastic components around filled imported goods	Yes
Finished unfilled components	Yes
Components with 30% or more recycled plastic	Yes, although not taxed
Immediate packaging of licensed human medicines	Yes, although not taxed
Pallet wrap, straps, crates and containers used to deliver the imported goods	No
Products excluded from the definition of packaging, such as toolboxes	No

Our page on Plastic Packaging Tax exemptions explains the limits of the transport packaging relief, which does not cover bulk containers or the normal packaging of sales units.

When must an importer register?

Section 55(2) and HMRC’s registration guidance set two tests, and you must register within 30 days of meeting either:

1. Forward look. On any day, if there are reasonable grounds for believing that 10 tonnes or more will be imported or made in the next 30 days. Liability runs from the date you had reason to expect this.
2. Look back. On the first day of each month, if 10 tonnes or more were imported or made in the 12 months to the end of the previous month. Liability runs from that first day.

If both tests are met, the earlier date applies. From the liability date, tax is due on all chargeable components, including normal volumes as well as the order that triggered registration. If you stay below the threshold, HMRC still expects you to keep records showing that you import or make less than 10 tonnes a year, including filled packaging. Companies under common control can register as a group so that one representative member files for all of them.

How should imported packaging be weighed and evidenced?

HMRC accepts five weighing methods: individual component, sample component, material inputs, verified specification and bulk weighing. Importers usually rely on the verified specification method, using the weights in the product specification. HMRC requires a random selection of components to be weighed to confirm the specification, which for overseas production the manufacturer can do, and requires due diligence to make sure the specification stays accurate. Estimates are not a recognised method; if you need to rely on them you must discuss it with HMRC first.

To show that imported packaging contains at least 30% recycled plastic, HMRC says you must either hold evidence from the manufacturer or show that you, or a competent third party, run a robust supply chain audit. HMRC will consider checks by equivalent international accreditation bodies case by case. A new assessment is needed whenever the specification or materials change.

How does this work for a growing importer?

Illustration only. A UK retailer imports filled homeware. The plastic packaging on its usual imports weighs about 0.6 tonnes a month, plus pallet wrap on each shipment. On 3 September 2026 it accepts a seasonal order from an overseas supplier that will arrive before the end of September, carrying 11 tonnes of plastic packaging.

• The pallet wrap is ignored. The look back test is not met, because the previous 12 months total about 7.2 tonnes.
• The forward look test is met on 3 September 2026, because more than 10 tonnes is expected in the next 30 days. The retailer is liable from that date and must register within 30 days, by 2 October 2026.
• Tax is due on every chargeable component imported from 3 September 2026, including its usual monthly volumes, on the July to September 2026 return.

The first return is then due by the last working day of October 2026; see Plastic Packaging Tax returns and deadlines.

What mistakes do importers make?

• Including the weight of the goods, or leaving out caps and labels, when weighing filled packaging.
• Leaving packaging with 30% or more recycled content out of the threshold calculation.
• Assuming the overseas supplier pays because it arranges delivery, without a written agreement.
• Accepting a supplier’s specification with no sample weighing or recycled content evidence.
• Registering late. A failure to notify penalty is based on the tax lost, and businesses that buy from importers who fail to pay can face joint liability for Plastic Packaging Tax.

For the charge, rate and recycled content rules in general, see our main Plastic Packaging Tax guide.

If HMRC opens a check into your return, tax investigation insurance pays your accountant’s fees. Solar Protect cover pays up to £100,000 with no excess; it never pays tax, interest or penalties. Read how our cover works or get a quote.

Related Accountapedia entries

• Plastic Packaging Tax and packaging EPR compared
• The UK carbon border adjustment mechanism
• Postponed VAT accounting on imports
• Dropshipping: VAT for UK sellers
• Inward processing relief

Sources

• legislation.gov.uk: Act 2021 c. 26, section 44
• legislation.gov.uk: Act 2021 c. 26, section 50
• legislation.gov.uk: Act 2021 c. 26, section 55
• GOV.UK: Decide if you need to register for plastic packaging tax
• GOV.UK: When you must register for plastic packaging tax
• GOV.UK: Check which plastic packaging is exempt from plastic packaging tax
• GOV.UK: Work out which packaging is subject to plastic packaging tax
• GOV.UK: How to work out the weight of packaging for plastic packaging tax
• GOV.UK: Record keeping and accounts for plastic packaging tax
• GOV.UK: Register a group of companies for plastic packaging tax

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.