The UK is tightening the evidence for recycled content and PFAS

For companies selling plastic packaging, textiles, food packaging, cosmetics or cleaning products in the United Kingdom, evidence is becoming more important. For recycled content the Plastic Packaging Tax depends on it directly. For PFAS, new requirements are emerging for monitoring, procurement and product testing.

The two developments rest on different legal bases but lead to the same practical question: can the company substantiate its claim for the actual product and the supply chain?

Recycled content becomes a tax criterion

The UK Plastic Packaging Tax applies to relevant plastic packaging with less than 30 per cent recycled plastic. Since 1 April 2026 it stands at 228.82 pounds per tonne. The threshold stays as it is. What is being developed further is how companies have to substantiate the recycled share.

Chemical recycling with certification from April 2027

From 1 April 2027, chemically recycled plastic can be counted towards the Plastic Packaging Tax through a mass balance approach. For that, the supply chain must be covered by a suitable certification scheme meeting the UK minimum requirements.

The requirements foreseen include material allocation and mass balance, independent certification, accredited certification bodies, audits and retention of records. Without the required evidence, the share allocated through mass balance cannot be counted as recycled content for tax relief.

Mechanical recycling is the next step

HM Revenue and Customs is also examining mandatory certification for mechanically recycled plastics. The consultation concluded in 2026 expressly covers new evidence requirements, fraud risks, international supply chains and possible dates of introduction.

No binding start date has been published for mechanical recycling yet. The direction is nevertheless clear: a standardised, independently verifiable proof is to replace a mixture of documents and self-declarations. Companies relying on the 30 per cent threshold should therefore review their chain of custody and mass balance for robustness now.

PFAS moves into product testing and procurement

In parallel the UK government is building a cross-departmental framework with its PFAS plan. It links monitoring, UK REACH, public procurement and analytical testing. A blanket ban on all PFAS in all consumer products has not been decided. Several product groups are nevertheless explicitly in focus.

Textiles

The plan names water, oil and stain repellent textiles including clothing, footwear and carpets. The government is also examining PFAS requirements for Government Buying Standards, recommendations on PFAS-free school uniforms and information requirements in Ministry of Defence procurement. PFAS evidence can therefore matter increasingly for tenders as well.

Food packaging

For food contact materials, analytical testing capability is to be expanded. Priority goes to materials where PFAS are likely because of grease, oil or moisture repellent properties. Monitoring data is at the same time intended to provide a basis for possible later regulatory measures.

Cosmetics and cleaning products

Cosmetics and personal care products are named as well. Cleaning products sit in the same group of further consumer products for which additional measures are being examined. Companies should therefore not look at these categories in isolation.

One market, two reasons for independent evidence

For recycled content, solid evidence increasingly decides whether recycled plastic is recognised for tax purposes. For PFAS it supports compliance, procurement and credible product communication.

flustix RECYCLED can independently verify mechanically and chemically recycled plastics as well as suitable chain of custody and mass balance structures. flustix PFAS-FREE combines analytical testing of finished products with independent certification, among others for textiles, packaging, cosmetics and further consumer products.

In both areas the UK development points the same way: declarations alone carry less weight. What counts is whether the evidence fits the product, the supply chain and the claim being used.