The plastics packaging tax comes into force six weeks from today (April 1st) but research by the Foodservice Packaging Association (FPA) shows 80% of its members who sell packaging subject to the tax are ill-prepared.
Three quarters of those the FPA surveyed in January have attended an HMRC plastics tax webinar and/or read the tax guidance notes. Most (85%) found the webinars ‘unhelpful’, said the FPA.
Around one in two members said they were still unsure which of their packs and products are subject to the tax, while over 60% have yet to work out a method for measuring recycled content. The government’s guidance is extensive but alterations, new exemptions and updates have created confusion.
More than half of those responding to the survey were yet to implement a system for recording recycled content. Of those importing packaging, 80% will rely on their overseas suppliers for confirmation of recycled content, with fewer than one in 10 considering third party certification or evidence.
HMRC talks of the need for businesses to provide “robust” evidence of compliance. It will need to be furnished with approved paperwork, for example certificates of conformity and product specifications. However, the requirement for manufacturers or importers to show on invoices the amount of tax paid on packaging will be voluntary at first. The onus will be on businesses to undertake due diligence and to provide an audit trail, according to lawyers at Pinsent Masons.
There remains little information on how the tax will be regulated and no information on how it will be enforced. Penalties could range from a fixed fine to imprisonment.
The plastics packaging tax places a GBP200 per ton charge on plastic packaging that doesn’t contain at least 30% recycled content. Justin Turquet from Bunzl Catering Supplies said the cost impact “is not quite as high as some people might have expected” but is just one element of a perfect storm facing foodservice packaging.
There is the rise in inflation, which has bumped up packaging prices by around 10%, and well-documented staffing and supply issues. The usually slick system behind container shipping has spun out of rhythm. Footprint has for example heard of businesses defaulting to 16oz cups rather than 12oz because they can’t get the stock.
Campaigners have argued that some of these supply chain issues highlight the benefits of circular economy thinking.