Certification and Verification of Recycled Content

Under the plastic packaging tax, any plastic packaging item that does not contain 30% recycled content has to pay the tax (£217.85 currently). This led to a proposal from industry, before the tax was in place, for a ‘Recycled Content Verification System’ (RCVS). The British Plastics Federation (BPF), together with RECOUP, produced a Recycled Content Verification Systems Research Document in 2021, which was later updated in 2022 following the release of the tax. The tax did not specify the need for a RCVS but instead set out a list of records that need to be kept for a company wanting to claim an exemption from the tax (i.e. their product contains 30% recycled content). However, the research document sets out how a RCVS could still be beneficial for the industry.

How can verifying material as recycled plastic be achieved?

There are different verification solutions:

• Independent third-party auditing
• Certification schemes
• Scientific Laboratory-Based Testing Approach

The Recycled Content Verification Systems Research Document provides examples of each of the verification solutions. These schemes cover both mechanical and chemical recycling. The document did not set out a recommendation to use a specific scheme(s) but did set out requirements which are important in any scheme. These include:

A consistent reporting mechanism

• To be multinational and to operate to recognised international standards
• To provide an annual, in-person, audit at site level
• To be affordable, credible and to add value
• To monitor relevant laboratory-based testing technology

Will there be further developments?

It is likely that there will be further legislation in the future that will specify certain levels of recycled content which need to be achieved. It is essential for these and the tax that there are proper controls in place to verify claims made about products. Concerns have been raised in Parliament, for example, about reports of imported material fraudulently claiming to contain recycled content.[1] This creates market distortion and ultimately can cause the closure of UK businesses, resulting in job losses.

In conclusion…

Increasing recycled content in particular products has a whole host of benefits for the environment, but a means of verifying and certifying recycled material correctly is essential to creating a level playing field for companies, particularly UK companies faced with foreign competion.

Certification schemes are already available that can be utilised by companies to provide their customers with reassurances about the recycled content within their products. 

Certification via a specified scheme should not be required but minimum requirements should be set out.

 

 

Further information

For more information on verification systems please refer to the BPF/RECOUP Recycled Content Verification Systems Research Document.

Sources

1) Plastic Packaging Tax on Imports: HMRC Enforcement - Hansard - UK Parliament

 

 

First published July 2024

Reviewed February 2025