NFU responds to proposed packaging certification rules

The National Farmers’ Union has called on the UK government to ensure that proposed certification requirements for recycled plastic packaging do not create additional costs, administrative burdens or supply disruption for primary producers.

The organisation submitted its response to an HMRC consultation examining whether businesses claiming relief from the Plastic Packaging Tax should be required to provide mandatory certification confirming the recycled content of their packaging.

Government targets stronger recycled content verification

The consultation focuses specifically on mechanically recycled plastic packaging. Under the proposed approach, businesses would need certified evidence that qualifying packaging contains sufficient recycled material before claiming exemption from the Plastic Packaging Tax.

The government is considering the measure as a way to improve the reliability of recycled-content claims and reduce the risk of incorrect or fraudulent declarations, particularly for imported packaging where traceability can be more difficult to verify.

Farmers support accuracy but fear additional red tape

The NFU said it supports efforts to ensure that recycled-content claims are accurate and that food safety remains protected. However, it warned that certification should not introduce another layer of bureaucracy for farmers and growers already operating with limited administrative resources.

Primary producers often have little ability to recover additional packaging compliance costs through higher selling prices, making even relatively small certification or documentation expenses potentially significant.

Dairy, egg and horticulture sectors could be affected

The proposed changes may be particularly relevant to businesses in dairy, egg and horticulture that package their own products using plastic containers, trays, films or other formats.

These companies may depend on packaging suppliers for information about recycled content and material composition, meaning certification requirements could extend compliance obligations further along the supply chain.

Packaging availability is another concern

The NFU has also warned against introducing rules that could restrict access to suitable packaging. Agricultural and food applications frequently require materials that meet strict hygiene, durability and food-contact standards, limiting the number of viable alternatives available to producers.

If certification requirements reduce the number of approved suppliers or increase lead times, smaller producers could face disruption even when their packaging already meets technical and environmental requirements.

International supply chains need recognition

The organisation is calling for the UK system to recognise equivalent overseas certification schemes where they provide comparable levels of assurance.

This could be particularly important for packaging imported from international suppliers. Requiring separate UK-specific certification for materials already verified under recognised systems could increase costs without necessarily delivering additional environmental benefits.

Traceability becomes central to the Plastic Packaging Tax

The consultation reflects a broader shift in UK packaging regulation towards stronger evidence and traceability. From April 2027, post-industrial recycled material will no longer count towards the 30% recycled-content threshold used for Plastic Packaging Tax relief, increasing the importance of proving the origin of recycled material.

For packaging users, the focus is therefore moving beyond simply incorporating recycled plastic. Companies will increasingly need reliable documentation showing where recycled content came from, how it was processed and whether it qualifies under the applicable tax rules.

Compliance must balance assurance and practicality

The NFU’s response highlights the challenge of strengthening packaging verification without creating disproportionate costs for smaller businesses. Certification can improve confidence in recycled-content claims, but poorly designed systems may shift administrative responsibility onto companies with limited ability to absorb it.

As the UK develops the next phase of the Plastic Packaging Tax framework, the balance between robust verification, food safety, packaging availability and practical compliance will be critical for agricultural producers and their packaging suppliers.