Pre-consumer waste stops counting in 2027

From 2027, pre-consumer waste (factory scrap, off-cuts, start-up material, reject product) will no longer count toward the 30 per cent recycled content threshold under the Plastic Packaging Tax.

This is a larger change than its billing suggests. A substantial number of producers currently clear the threshold by reintroducing their own in-house scrap, which is efficient, sensible and about to stop qualifying. Those producers will need verifiable post-consumer streams instead, and they will need them alongside everyone else who is discovering the same thing in the same quarter.

The threshold is a cliff edge rather than a slope. At 30 per cent you pay nothing on that packaging; at 29.9 per cent you pay on the whole tonnage. That structure makes the marginal tonne of qualifying material worth far more than its market price, and it makes the timing of supply arrangements considerably more important than the price of them.

Two things follow. First, if you are currently qualifying on in-house scrap, model your position now rather than in the quarter it bites. The answer determines whether you are looking for a supplier or a supply agreement. Second, whatever you secure has to be evidenced. Recycled content claims are only worth what the audit trail behind them is worth, and 'our supplier told us' is not an audit trail.

The market for verified post-consumer recyclate in 2027 will be tighter than it is today. Contracts signed in 2026 will look considerably better than contracts signed in 2027.