The challenges and opportunities to verify recycled content in plastic packaging

Helen Jordan, Sustainability Manager at the British Plastic Federation (BPF), and Steve Morgan, Head of Policy & Infrastructure at RECOUP, outline the challenges and opportunities for verifying recycled content in their new report, Recycled Content Verification Systems (RCVS).

Since the introduction of the Plastic Packaging Tax in April 2022, providing evidence of recycled content in plastic packaging has become a priority for both commercial as well as environmental reasons.

With a minimum of 30% recycled content required to avoid paying the tax, it was believed that there was a significant risk of potential fraud from false claims being made. This was particularly true of packaging imported into the UK, where UK plastic packaging manufacturers, brands and retailers could be at a competitive disadvantage if they were complying by the rules whilst, intentionally or unintentionally, others were making false claims about recycled content in their packaging. A level playing field was needed.

For the original report published in August 2021, we set about researching the verification solutions, which are all designed to give confidence to purchasers of plastic packaging that claimed levels of recycled content were accurate.

Since the introduction of the Plastic Packaging Tax in April 2022, providing evidence of recycled content in plastic packaging has become a priority

These were based around three areas: independent third-party auditing, certification schemes, and a scientific laboratory-based testing approach — the latter being centred around exciting developing technology to determine recycled content by physical analysis, which could be used to complement auditing-based solutions.

The research was done for two reasons. Firstly, to help our members see the different solutions, schemes and technologies available, and secondly, to set out key policy ‘asks’ of HMRC. Eighteen months on, other developments happened, including the emergence of certification schemes and changes in legislation, which led us to look at wider key policy asks and how those tied in with verifying recycled content.

Recycled Content Verification Framework

When developing the initial report, third party audits and many certification schemes were still being developed, but since then recycled content audits have taken place by businesses around the world. Whilst there were differences in their approach, there were also many similarities.

This helped us to develop a list of not only what we considered to be the key recommendations for a Recycled Content Verification Framework that HMRC could introduce, but also considerations for any verification activity businesses undertook:

  • Use a consistent reporting mechanism.
  • Operate internationally / multinationally to recognised international standards on recycled content and traceability.
  • Include an annual in-person audit at site level with an audit pool which can be deployed worldwide.
  • Be affordable, credible and add value.
  • Monitor developments in scientific laboratory-based testing technology.

Investment in Recycling Infrastructure


Producing the updated report helped us to reflect on the advantages the wider key policy asks had on recycled content verification. Like with all policy, no successful legislation can work or be developed in isolation.

Industry has repeatedly called on the UK government for support around the investment in plastic packaging recycling infrastructure in the UK. There are numerous commercial and environmental advantages in investing in the UK’s capabilities to recycle plastic, and simply put, it is the only approach that can reduce the UK’s reliance on exporting plastic waste for recycling.

In terms of verifying recycled content, it helps with waste tracking, as keeping the material in the UK would mean a much less complex supply chain, and this would in turn help businesses undertake a simpler chain of custody approach to the recycled content they would be using.

Industry has repeatedly called on the UK government for support around the investment in plastic packaging recycling infrastructure in the UK

How is this concept supported by policy? Reinvesting funds generated from the Plastic Packaging Tax and Extended Producer Responsibility (EPR) for packaging provide the perfect opportunities to achieve a continuous and reliable funding source.

This should create the ‘investment ready conditions’ to unlock private investment for plastic reprocessing infrastructure in the UK, which was a clear recommendation from the recent House of Commons Plastic Waste Environment, Food and Rural Affairs (EFRA) Committee, The Price of Plastic – Ending the Toll of Plastic Waste report.

Material Switching – The Best Environmental Outcomes?

Whereas creating those conditions would be a hugely positive step, policy changes can also deliver negative unintended consequences. Since plastics in the environment has been at the forefront of the public and politicians’ minds in recent years, we have seen moves away from using plastic in packaging in favour of other materials. The Plastic Packaging Tax is compounding this further, with businesses opting to use other materials to avoid paying the tax.

This is leading to alternative materials being used that can have a higher carbon footprint, and create unrecyclable or difficult-to-recycle alternatives that the waste and recycling sector have to manage.

Final Thoughts

Researching and pulling together this report has led to some targeted legislative and practical interventions that will enable the UK to transform the structure and funding around use of recycled content in plastic packaging.

Implementing a Recycled Content Verification Framework, readjusting policy to prioritise investment in the UK’s plastic packaging reprocessing infrastructure, and ensuring packaging material choices achieve the best overall environmental outcomes all feature.

Having robust recycled content verification solutions in place can underpin all of these — providing the evidence that recycled content is genuine and that plastic is working as part of a circular economy to replace virgin plastic in new products. Building the recycling infrastructure in the UK to do this makes commercial and environmental sense and would provide confidence to businesses to continue to use plastics where they are the best solution and to achieve the best environmental outcomes we all want to see.

The report has only been available to RECOUP and BPF members for the first 3 months after its release. The report is now available for anyone to download at both the RECOUP and BPF websites.

To access it visit either:

RCVS report (RECOUP) (BPF)

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