The tax assesses each individual packaging component separately. So your bottle, your cap, your pump, your label — each one is its own "plastic packaging component" for PPT purposes.

For each component, the recycled content is calculated as a percentage of the total plastic weight in that component:

Recycled content (%) = weight of recycled plastic ÷ total weight of plastic × 100

If a component hits 30% or above, no tax is due on that component. If it falls below, the full weight of that component is taxable at £228.82 per tonne.

Critically, a component is only classed as "plastic" if plastic is the predominant material in it by weight. If a component contains aluminium, steel, glass, paper and cardboard, wood, or other non-metals at a higher weight than plastic, then it's not a plastic packaging component for PPT purposes.

In 2026, both post-consumer recycled (PCR) and pre-consumer/post-industrial recycled (PIR) content count towards the 30% threshold

From April 2027, pre-consumer waste will no longer qualify. However, chemically recycled plastic will count through a mass balance approach (MBA), which is good news food-contact or plastics in contact with sensitive ingredients, however it will require certification under an approved scheme, and the detailed standards are still being finalised.

Let's make this tangible. A beauty brand might have a product line with the following components:

• A PET bottle (say 30g)

• A PP pump or cap (say 12g)

• A PS or PP overcap (say 8g)

• A PE shrink sleeve or label (say 2g)

Each of those is assessed independently. The bottle might be 100% rPET and sail through. But that PP pump? Almost certainly virgin plastic right now, because recycled PP of the quality needed for pump mechanisms is hard to source. That pump would be fully taxable.

At £228.82 per tonne, the cost per unit is small — a 12g virgin PP pump costs you roughly £0.003 in PPT. Multiply that across a million units and it's around £3,000. Not huge, but not nothing — and it stacks up across a full product range.

The real cost isn't the tax itself. It's the direction of travel. Rates are going up annually. The definition of what counts as recycled is tightening. And the overlap with other regulations — the EU's PPWR, UK EPR reform, and the forthcoming Deposit Return Scheme — means the brands that get their material choices right now will have a significant compliance advantage in three to five years.text goes here

The evidence burden

Under the PPT regulations, plastic is treated as virgin by default. You can't just say your packaging contains recycled content — you need documented evidence to prove it. The regulation requires producers and importers to keep written records of the recycled content calculation for every packaging component, supported by sufficient evidence as prescribed by HMRC.

Design and sourcing implication 

For brands working with overseas contract manufacturers or packaging suppliers i.e. most brands, this means getting proper documentation from your supply chain. A line on a spec sheet that says "contains recycled material" isn't enough. You need the methodology, the weight breakdown, and ideally third-party certification to back it up. And those records need to be kept for six years.

All packaging must be recyclable by 2030, with clear performance grades based on the percentage of the packaging unit (by weight) that can actually be recycled:

Grade A: 95%+ recyclable Grade B: 80%+ recyclable Grade C: 70%+ recyclable

Anything below 70% is considered non-recyclable and cannot be placed on the EU market from 2030. By 2038, the bar rises again — Grade C is phased out, meaning only packaging achieving 80%+ recyclability will be permitted.

Crucially, the recyclability grade depends on the separability of components. If you’ve seen those plastic bottles with a drinks-can aluminium closure, well they won't be on the EU market for much longer, even though each material could be recycled independently. 

By 2035, packaging must also be "recycled at scale in practice," meaning it's actually being processed by existing collection and sorting systems, not just designed to be recyclable in principle.

Detailed Design for Recycling (DfR) criteria will be outlined in January 2028. This will cover parameters like separability of components, sorting and recycling efficiency, and the quality of the resulting recyclate. 

Design and sourcing implication: Multi-layer laminate pouches and complex mixed-material formats are effectively dead for the EU market. Brands should be designing toward mono-materials and ensuring all components — caps, labels, pumps, sleeves — can be separated either by the consumer before disposal or by sorting infrastructure. If your packaging can't pass a credible DfR assessment, it can't be sold.

The PPWR introduces hard limits on packaging waste and design inefficiency. Member States must reduce per capita packaging waste by 5% by 2030, 10% by 2035, and 15% by 2040, against a 2018 baseline.

At the product level, from January 2030 packaging must be reduced to the minimum size and weight required for its intended function. Double walls, false bottoms, unnecessary layers, and any features designed to increase the perceived volume of the product are explicitly banned.

For grouped, transport and e-commerce packaging, the regulation caps empty space at a maximum of 50%.

Design and sourcing implication: No more "Russian doll" unboxing experiences where a 30ml cream arrives in a box the size of a small shoebox. If your secondary packaging exists primarily for brand theatre rather than product protection, it's now a compliance risk. Brands need to think about custom inserts, right-sized cartons, and SKU-specific packaging rather than one-box-fits-all approaches. "Air" is now a regulated material.

Mandatory minimum recycled content targets apply to all plastic packaging placed on the EU market, with staged deadlines:

By 2030:

• 30% PCR for contact-sensitive packaging made primarily from PET (e.g. bottles)

• 10% PCR for contact-sensitive packaging made from other plastics

• 35% PCR for non-contact-sensitive plastic packaging

By 2040:

• 50% PCR for contact-sensitive PET packaging

• 25% PCR for contact-sensitive packaging from other plastics

• 65% PCR for non-contact-sensitive plastic packaging

Two critical points to note. First, only post-consumer recycled content (PCR) counts. Second, there is still some discussion about whether bio-based plastics will contribute towards these quotas. The Commission is due to assess this by February 2028, potentially with a conversion factor (e.g. 2 tonnes bio-based = 1 tonne PCR), but nothing is confirmed.

The recycled content requirement applies to each plastic component, unless that component represents less than 5% of the total weight of the packaging unit. So the small mechanical components inside a pump — springs, balls, dip tubes — may be exempt as long as the overall assembly is recyclable as one unit (e.g. a mono-material pump).

There are also exemptions for packaging where the inclusion of recycled content would breach food contact regulations (Regulation EC 1935/2004), for medical device and pharmaceutical packaging, and for compostable plastic packaging.

Design and sourcing implication: Recycled content above 30% can have performance implications — clarity, colour consistency, mechanical strength, barrier properties — so it isn't necessarily possible to straight-swap a virgin plastic for one with 30% PCR and expect the same result. This is a materials engineering challenge, not just a procurement one, so it’s best to start testing early.

The PPWR sets specific reuse targets for certain packaging formats, primarily in transport, beverage and takeaway:

By 2030:

• Beverage distributors must ensure at least 10% of beverages are made available in reusable packaging within a reuse system (rising to 40% by 2040)

• Take-out food and drink distributors must endeavour to offer 10% of products in reusable packaging

• Companies using transport packaging (pallets, plastic crates, foldable boxes etc.) must ensure at least 40% is reusable (rising to 70% by 2040)

Takeaway food and beverage distributors must also allow consumers to bring their own containers, at no extra charge.

These targets don't directly hit beauty or personal care brands yet, but the Commission has scope to expand reuse targets to other sectors in future reviews.

Design and sourcing implication: If you're shipping palletised goods within the EU, collapsible crates and reusable transit packaging should be on your radar. For D2C, consider returnable mailers. And if you're already doing refill (which is increasingly common in beauty), make sure your refill system meets the PPWR's definition of a "reuse system" — it needs to be formally established, with collection and reconditioning infrastructure, not just a marketing claim.

From 1 January 2030, certain single-use packaging formats are banned outright. These include:

• Very lightweight plastic carrier bags (under 15 microns, with narrow exceptions)

• Single-use plastic packaging for unprocessed fresh fruit and vegetables under 1.5kg

• Single-use packaging for condiments, sauces, coffee creamer, sugar etc. in the HORECA sector

• Single-use packaging for cosmetics and toiletries of less than 50ml (e.g. hotel miniatures)

• Shrink wrap for luggage at airports

• Single-use packaging for food and beverages filled and consumed within HORECA premises

Design and sourcing implication: Consider switching sample sachets or travel-size products in single-use plastic packaging under 50ml, to refillable dispensers, solid formats, or explore alternative packaging materials.

Strict restrictions on the use of PFAs, BPAs and heavy metals including lead, cadmium, mercury, and hexavalent chromium. Whilst this primarily affects food packaging, it signals the regulatory direction for all packaging categories. 

One that often gets overlooked: the PPWR introduces EU-wide harmonised labelling requirements for all packaging. From August 2026, packaging must carry labels showing material composition using standardised pictograms (to be defined by the Commission in implementing acts). From 2028, packaging must also include digital information — via QR code or other data carrier — covering sorting instructions, recyclability information, and material identification.

Design and sourcing implication: This affects every SKU, so build the labelling requirements into the brief from the start rather than retrofitting them later.

• February 2025: PPWR entered into force

• August 2026: General application begins — labelling, substances of concern, PFAS ban in food-contact packaging, reuse system requirements

• January 2028: Delegated acts defining Design for Recycling criteria due

• January 2030: All packaging must be recyclable (Grades A–C). Recycled content targets apply. Single-use format bans take effect. Minimisation requirements apply. First reuse targets apply

• January 2035: Packaging must be "recycled at scale" — not just designed for recycling but actually processed by real infrastructure

• January 2038: Grade C phased out — only Grades A and B (80%+ recyclability) permitted

The 2030 deadline is the hard wall. But given that packaging redesign, tooling, testing and qualification typically takes 18–24 months minimum, the design decisions can’t be left until the last minute.