Plastic Packaging Tax exemptions

Q: How does this look in practice?

Illustration only. A pharmaceutical wholesaler imports filled packs over a 12 month period. The plastic packaging comprises 7 tonnes of blister film in direct contact with licensed tablets, 4 tonnes of plastic overwrap around the cartons, and 5 tonnes of pallet wrap on the inbound pallets. All the plastic contains less than 30% recycled content. Threshold count: 7 + 4 = 11 tonnes. The blister film counts even though it is exempt; the pallet wrap does not. The wholesaler must register. Chargeable weight: only the 4 tonnes of overwrap. At the 2026 to 2027 rate of £228.82 per tonne, that is £915.28 for those components. Leaving the blister film out of the threshold would have shown 4 tonnes and a business that wrongly believed it had nothing to register. How importers build up their threshold figure is covered in Plastic Packaging Tax for importers, and how exempt weights are entered each quarter in Plastic Packaging Tax returns and deadlines.

Section 52 of the Finance Act 2021 exempts four kinds of plastic packaging from Plastic Packaging Tax: immediate packaging for licensed human medicines, components permanently set aside for a non packaging use, transport packaging used to bring goods into the UK, and packaging used as stores on international journeys. Separate regulations take long term storage products, integral parts of goods and reusable display items out of the definition of packaging altogether. Each relief has its own conditions, and only some of them reduce the tonnage that counts towards the 10 tonne registration threshold.

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What is the difference between exempt and excluded packaging?

An exempt item is still a plastic packaging component, but section 52 says no charge arises on it. An excluded item is not a packaging component at all, because regulation 4 of the Plastic Packaging Tax (Descriptions of Products) Regulations 2021 (SI 2021/1417) removes it from the definition. The difference shows up in the registration test and on the return.

Relief	Where in law	Counts towards 10 tonnes?
Immediate packaging of licensed human medicines	FA 2021 s.52(4)	Yes
Permanently set aside for non packaging use	FA 2021 s.52(6)	Yes
Transport packaging on imported goods	FA 2021 s.52(1)	No
Stores on international journeys	FA 2021 s.52(3)	No
Long term storage, integral and reusable presentation products	SI 2021/1417 reg. 4	No

Section 55(3) is the provision that leaves transport packaging and stores out of the threshold calculation. Because medicine packaging and set aside components still count, a business can owe no tax on most of its output and still be required to register, file quarterly returns and keep full records. The wider rules on registration and the charge itself are covered in our guide to Plastic Packaging Tax.

When is packaging for medicines exempt?

Section 52(4) exempts components produced or imported for use in the immediate packaging of a medicinal product. Both terms take their meaning from the Human Medicines Regulations 2012: immediate packaging from regulation 8(1) and medicinal product from regulation 2(1). HMRC’s guidance puts it simply. Immediate packaging is the container or other packaging that is in immediate contact with the product when it is produced. A medicinal product is one for use by people to prevent or treat disease, to restore, correct or modify a physiological function through a pharmacological, immunological or metabolic action, or to make a medical diagnosis, and it must be licensed by the Medicines and Healthcare products Regulatory Agency.

Three points follow from that wording:

The relief is for human medicines. HMRC lists medical device packaging and diagnostic kit packaging among its examples of packaging that is in scope of the tax.
Only the layer touching the product qualifies. A blister film holding tablets is immediate packaging; a plastic overwrap around the carton of blisters is not, so it is taxed in the normal way unless another relief applies.
The evidence is specific. HMRC’s records guidance gives the licence numbers of the medicines involved as an example of what you need to hold to support the claim.

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What does set aside for non packaging use require?

Section 52(6) exempts components that, before or as soon as they are produced or imported, are permanently designated or set aside for a use other than the containment, protection, handling, delivery or presentation of goods, provided the producer or importer keeps a record of that designation. HMRC’s examples are plastic film used to coat whiteboards and film whose main purpose is to allow fermentation when making silage.

HMRC says it expects the exemption to apply to a small number of highly specialised products and that clear evidence is needed for any claim. The timing condition is strict: the record must exist before or as soon as the component is made or imported, not when someone later notices how the product was used. HMRC also gives microwave food pouches and ready meal oven trays as examples that do not qualify, because cooking in the packaging does not stop it being packaging.

Which transport packaging on imported goods is exempt?

Section 52(1) applies only to the import charge. No tax arises on components used in the delivery of goods into the UK that are transport or tertiary packaging within regulation 3(2)(c) of the Packaging (Essential Requirements) Regulations 2015, or that are road, rail, ship or air containers. HMRC describes transport packaging as packaging conceived to make it easier to handle and transport a number of sales units or grouped packaging, so as to prevent physical handling and transport damage. The exemption turns on how the packaging is used, not what it is.

When used to import goods, HMRC treats the following as covered: freight containers; reusable plastic crates, pallets and other heavy duty containers designed to carry a range of products; single use components such as pallet wrap and retaining straps; and reusable mail sacks. It is not covered when it is:

unfilled plastic packaging, including transport packaging imported as goods in its own right
the normal packaging around a sales unit or a number of sales units
an intermediate bulk container or flexible intermediate bulk container used to move liquids or commodities in bulk
manufactured in the UK, or used to move goods within the UK

Separately, reusable packaging brought in under the customs Temporary Admission procedure is not subject to the tax. UK manufacturers of transport packaging, and importers of unfilled transport packaging, can defer the tax if they intend to export it unfilled within 12 months; the liability is cancelled once it is exported and the export is evidenced. Transport packaging used to export goods is taxed first and a credit is then claimed on proof of export.

How does the stores exemption work?

Section 52(3) exempts components that are stores within the meaning of section 1 of the Customs and Excise Management Act 1979. In practice this is packaging used in stores on aircraft, ships and railway vehicles making international journeys. HMRC’s guidance adds that if the packaging is later removed from stores and released into the UK, the import must be recorded together with the weight and recycled content of the packaging.

What is excluded from the definition of packaging?

Regulation 4 of SI 2021/1417 removes three types of product, which never appear on a return or in the threshold calculation.

Long term storage: A product designed to be suitable to be filled when the goods are sold, suitable for reuse to store the same or similar goods, and with its packaging function secondary to its storage function. HMRC’s examples are toolboxes, first aid boxes and earbud cases. It does not cover anything designed to be thrown away once the original contents are used up.
Integral to the goods: A product without which the goods cannot reasonably be used or consumed, and which is expected to be discarded once the goods are used or with them. HMRC’s examples are water filter cartridges, printer and toner cartridges and inhalers. A ready meal tray is not integral, because the food can be heated in another dish, and film around a CD case is still taxable because it does not stay in place while the product is used.
Reusable presentation: A product designed primarily for reuse in presenting goods, permanently designated for that use before or as soon as it is made or imported, with a record kept. Examples include sales display shelves, shop fittings and presentation stands.

How does this look in practice?

Illustration only. A pharmaceutical wholesaler imports filled packs over a 12 month period. The plastic packaging comprises 7 tonnes of blister film in direct contact with licensed tablets, 4 tonnes of plastic overwrap around the cartons, and 5 tonnes of pallet wrap on the inbound pallets. All the plastic contains less than 30% recycled content.

Threshold count: 7 + 4 = 11 tonnes. The blister film counts even though it is exempt; the pallet wrap does not. The wholesaler must register.
Chargeable weight: only the 4 tonnes of overwrap. At the 2026 to 2027 rate of £228.82 per tonne, that is £915.28 for those components.

Leaving the blister film out of the threshold would have shown 4 tonnes and a business that wrongly believed it had nothing to register. How importers build up their threshold figure is covered in Plastic Packaging Tax for importers, and how exempt weights are entered each quarter in Plastic Packaging Tax returns and deadlines.

What mistakes do businesses make with exemptions?

Treating medical device or diagnostic kit packaging as medicine packaging.
Claiming the medicine relief for outer packaging that does not touch the product.
Applying the transport exemption to pallet wrap bought and applied in the UK, or to bulk containers.
Recording a set aside designation after the event, or with no supporting evidence.
Assuming an exempt product is also outside the threshold. Registering late can bring a failure to notify penalty.

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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.