In the world of product packaging, meeting customer requirements while adhering to sustainability standards can be a complex challenge. At Skymark, we believe in turning these challenges into opportunities for innovation. This case study explores how we used our unique approach to problem-solving to meet a customer’s specific needs while also addressing sustainability concerns.


Our journey began in 2021 when our customer approached us with a request for a premium matt finish for their product packaging. To meet this requirement, we initially offered a Matt OPP/PE laminate, using 50um SKYMAX 6546M-C. This solution also allowed for venting through a gap in the end seal, facilitating packing and transit utilising our laser score capabilities.


There was a growing need to transition to a more sustainable, recyclable packaging solution. This was not only to meet consumer expectations for sustainability but also to mitigate the impact of the Plastic Packaging Tax and to also future proof their product regarding the upcoming EPR legislation.


In response to these challenges, Skymark’s innovative R&D team developed a laser score vent in the back of the pack. This allowed a full end seal to be applied, resolving the pack failure issue the customer had been experiencing .

But we didn’t stop there. Recognising the need for a more sustainable solution, our team developed a shift from the laminate to SKYMONO P, a recyclable material that consumers can return at store. The proposed structure is 20um Matt OPP / 30um SKYLENE 1711.


The introduction of the laser score vent significantly improved pack integrity, eliminating the previous issues with pack failures. Meanwhile, the transition to SKYMONO P not only offers a recyclable solution, meeting consumer demand for sustainability, but also results in a 28% pack weight reduction. This helps the customer mitigate the UK Plastic Packaging Tax, demonstrating Skymark’s commitment to providing innovative, customer-centric, and sustainable packaging solutions.


This case study showcases Skymark’s dedication to innovative problem-solving and sustainable practices. By listening to our customers and understanding their unique challenges, we’re able to develop bespoke solutions that not only meet but exceed their expectations. At Skymark, we believe in the power of partnership and innovation to drive growth and create value.

Please contact us to help with your packaging needs

The UK government’s Extended Producer Responsibility (EPR) plans are set to reshape the landscape of waste management and recycling in the country. Despite opposition from some industry groups, the Department for Environment, Food and Rural Affairs (Defra) is pressing forward with the EPR scheme, which is still on track to be implemented in 2024.

What is EPR?

EPR is a system designed to make firms that supply household packaging more responsible for the costs of dealing with packaging waste. This shifts the financial burden away from councils and taxpayers, encouraging businesses to increase their use of recyclable materials. The EPR system aims to protect the environment from waste, promote resource efficiency, and move towards a more circular economy.

Data Collection and Reporting

Data collection and reporting are key components of the EPR system. Obligated businesses, including many in the packaging industry, must collect data for the revamped packaging producer responsibility system, and pay for the cost of waste collections.

According to the latest information available to Skymark, data will be reported during 2023 using the new data capture format covering household and non-household data. The data will then be used to calculate the estimate using a cost estimator tool for the payments, which will be billed in April 2024 and due to be paid in Q3 2024.

Defra has confirmed that obligated packaging producers in England, Northern Ireland, and Scotland must collect information on the amount and type of packaging they have supplied during 2023. Wales will follow shortly. Producers with a turnover of greater than £2 million and who handle more than 50 tonnes of packaging each year must also report this information to the Environment Agency twice a year. The first reports must be submitted from 1 October 2023.

Preparing for EPR

At this stage, businesses should assess their current data submission format, review all items of eligible waste, assign the relevant type, origin, and material categories, and change their template based on this. This is important as some organisations may be required to not only submit data to DEFRA, but also downstream to their supply chain depending on their position in the chain. By adjusting the reporting format, it will be easier to split those sections out.

Opposition and Cost Concerns

Despite the government’s commitment, the EPR system has met with opposition from industry groups such as the British Retail Consortium (BRCGS), who argue that the EPR and the deposit return scheme (DRS) combined will add around £4 billion in costs to retailers, which will be passed down the line. The Food and Drink Federation, whose members include large producers like Coca-Cola and Unilever, called on ministers to pause the plans, which they claim would add £60 to shopping bills.

However, Defra has listened to feedback from industry and reduced its business waste proposals from £2.7 billion to £1.4 billion. The total net cost of the new EPR system is expected to be around £1.7 billion, a figure significantly lower than early estimations of £2.8 billion.

Looking Ahead

As the 2024 EPR deadline approaches, businesses and industry groups are expected to continue lobbying for changes and clarifications. However, the UK government remains steadfast in its commitment to implementing EPR as part of its wider strategy to protect the environment and promote a more circular economy.

Deep Sagar, Chair of the Advisory Committee on Packaging, has pointed out that packaging materials that are not recycled back into new packaging harm the natural environment. EPR is expected to reduce such waste and encourage goods producers to pay for the collection of all packaging waste, thereby stimulating them to reduce or recycle more packaging. Sagar anticipates that EPR could be a game-changer, reducing the impact packaging has on the environment by regulating material use and increasing recycling.

The EPR system is a part of wider waste reforms introduced by the UK government, which also includes bans on more single-use plastic items, a deposit return scheme for drinks containers, and consistent recycling collections for households and businesses, on top of targets for recycling packaging waste.

The government’s EPR plans are in line with its 2018 Resources and Waste Strategy, which outlines how it intends to preserve material resources by minimizing waste and promoting resource efficiency. The revenue generated from the EPR scheme will support better local council services and ensure that households can recycle the same packaging materials.

In conclusion, the implementation of EPR in the UK is a significant step towards achieving a more sustainable and circular economy. Despite concerns and opposition from certain industry groups, the government stands firm in its belief that the EPR will help preserve material resources, minimize waste, and promote resource efficiency. While the transition may bring challenges, it also presents opportunities for innovation and improved environmental stewardship. As the 2024 implementation date approaches, businesses are advised to prepare accordingly, ensuring they understand their obligations and are ready to embrace the opportunities this major policy shift offers.

Plastic waste has become a significant environmental concern, prompting the implementation of various plastic packaging taxes across Europe. These taxes aim to reduce plastic waste, promote recycling, and support a circular economy. This comprehensive article provides a detailed overview of plastic packaging tax regulations in the United Kingdom, Spain, Italy, Portugal, and Hungary, as well as the impact of these taxes on businesses, consumers, and the global context.

United Kingdom:

The UK government has introduced a £200/metric ton (mT) Plastic Packaging Tax on materials containing less than 30% recycled content. This tax aims to encourage the use of more recycled materials in packaging production. Exemptions from this tax include human medicines packaging and non-packaging films.


Spain imposes a plastic tax on all items, including import transit packaging, at a rate of €450/mT on non-reusable plastic packaging. However, certain exemptions apply, such as medical packaging, intra-Community items (e.g., silage film, paints, inks, and lacquers intended to be incorporated into the product), and 100% recycled plastic packaging. To qualify for these exemptions, the packaging must comply with UNE-EN 15343:2008, and recycled content material should be certified by, for example, RecyClass. Declarations on total packaging weights are required on shipping and invoice documentation.


Italy’s plastic tax is charged at €450/mT of virgin plastic on MACSI (Single use) plastics, which primarily include single-use food packaging items and items not designed for more than one cycle of use. This tax also applies to packaging items containing partly recycled content materials. If the total tax value of the items is less than €25, no tax is incurred.


Portugal imposes a packaging tax at a rate of €300/mT on single-use packaging, which primarily includes single-use food and beverage packaging items made of plastic or aluminum. This also covers “service” packaging designed to be filled at the point of sale.


Hungary has implemented an Environmental Product Fee, with varying rates depending on the product and its composition. For plastics, the fees are primarily based on packaging and carrier bags. The rates are as follows:

Plastic Packaging – £130/mT

Plastic Carrier Bags* – £4,200/mT

Plastic flowers, etc. – £4,200/mT

When the product fee is less than £221/mT, no tax is payable. Bags declared as non-packaging, raw materials, and items reused in their original form are also exempt from this fee.

The introduction of plastic packaging taxes across Europe has significant implications for businesses and consumers. Businesses may experience increased costs in packaging materials, which may be passed on to consumers in the form of higher prices. However, these taxes also incentivize businesses to adopt more sustainable packaging solutions and encourage innovation in the development of eco-friendly alternatives.

In addition to plastic packaging taxes, many European countries have implemented Extended Producer Responsibility (EPR) schemes. These schemes require producers to take responsibility for the management and disposal of their products and packaging waste. EPR schemes complement plastic packaging taxes by encouraging businesses to design products that are more easily recyclable and reduce overall waste.

Addressing the issue of plastic waste requires collaboration between governments, businesses, and consumers. By working together, stakeholders can develop and implement more effective policies and practices to reduce plastic waste, foster innovation, and promote a circular economy. This collaboration may include public

How will the extended producer responsibility benefit the UK

Extended producer responsibility (EPR) is a policy approach that requires manufacturers and producers to take greater responsibility for the environmental impacts of their products throughout their life cycle. This can include responsibilities such as the collection and disposal of products at the end of their useful life, as well as the use of more sustainable materials in the production of those products.

In the UK, the implementation of EPR has the potential to provide several benefits. These include:

  • Reducing waste and pollution: By requiring manufacturers to take responsibility for the disposal of their products, EPR can help to reduce the amount of waste that is generated and prevent pollution from discarded products.
  • Encouraging the use of more sustainable materials: By making manufacturers responsible for the environmental impacts of their products, EPR can provide incentives for them to use more sustainable materials in the production process. This can help to reduce the overall environmental footprint of products.
  • Improving resource efficiency: EPR can help to ensure that products are designed for reuse, repair, and recycling, which can help to extend the useful life of products and improve the overall efficiency of the economy.
  • Creating new jobs and economic opportunities: The implementation of EPR can create new jobs in the waste management and recycling industries, as well as new opportunities for companies that provide eco-friendly products and services.

As a business, you should consider several factors in preparation for EPR.

  • First, you should assess the environmental impacts of your products and identify any potential challenges or liabilities that may arise from implementing EPR. This could include the cost of collecting, transporting, and recycling your products, as well as any potential negative impacts on your supply chain or operations.
  • Second, you should consider how EPR may affect your business strategy and operations. This could include changes to your product design, manufacturing processes, distribution channels, or marketing efforts. You should also consider how EPR may impact your relationships with customers, suppliers, regulators, and other stakeholders.
  • Third, you should develop a plan for implementing EPR in your business. This could include setting targets and goals, identifying responsible parties and roles, developing systems and processes for collection, transportation, and recycling, and providing training and support to your employees.

Overall, it is important for businesses to carefully consider the potential impacts of EPR and develop a plan for implementing it in a way that minimizes any negative effects and maximizes the benefits for the environment and your business.

Are you ready?

The Plastic Packaging Tax (PPT) comes into effect on 1 April 2022, impacting plastic packaging manufacturers, importers and purchasers.

PPT is a new tax on plastic packaging manufactured in, or imported into the UK, that does not contain at least 30% recycled plastic. Manufacturers / importers of plastic packaging (including importers of packaging surrounding other goods) will need to take action as soon as possible in preparation for the new tax, which will be levied at a rate of £200 per metric tonne of plastic packaging.

What can be classified as recycled plastic?

The Draft Plastic Packaging Tax document by the HMRC, Paragraph 8 “Meaning of “Plastic” and “Recycled Plastic”, page 6 elaborates the definitions of plastics, recycled and recovered plastics. By this definition, Recycled Plastic is permitted to consist of “plastic that has been reprocessed from recovered material by means of a chemical or manufacturing process so that it can be used either for its original purpose or for other purposes.”. Within the section, the definition of Recovered Material is further elaborated under section 4, stating that “Recovered Material is pre-consumer material or post-consumer material that:

a) has been collected and recovered as a material input, in lieu of new primary materials, for recycling or a manufacturing process, and

b) would otherwise have been disposed of as waste or used for energy recovery.

It is therefore our understanding, that “Recycled plastics do not simply restrict themselves to PCR material but in fact includes Pre-Consumer waste/Post Industrial waste, as well (see definition under section 5 of page 6 of the guidance as well as ISO 14021 definitions on Waste – Waste recycled away from a process using recognised/ accredited process will likely be eligible, albeit legislation does not currently require separate accredited repressor accreditation).

What is the Difference between EPR and Plastic Tax?

In a nutshell, Plastic Tax is a tax levied on industry for materials which do not contain a minimum level of recycled content (currently 30% in the UK – other regions may vary). EPR is a cost levied by the UK Government on the likes of Brand owners, retailers, on line market places and importers being held accountable for the net cost of collection and sorting for recycling, education and clear up of Packaging items they place on the UK marketplace. These costs are presently assumed by local councils

What is the Tax and its impact in UK and EU and what is EPR?

There are significant differences in the Taxation systems between the UK and the EU. We have attempted to simplify the differences in a tabulated form below:

Taxation cost per tonne£ 200 from April 2022*¹€ 800 from January 2021
Applicability of TaxMaterials not containing at least 30% Recycled content materials. Recycled material coming from chemical recycling is admissible for the calculation of the minimum recycled contentThe levy will be composed of a share of revenues from national contributions calculated on the weight of non-recycled plastic packaging waste *₂; *₃. This share
is paid by member states, as opposed to industry, however, may translate to industry taxation further down the line. Due to the definitions of Recycling needing to be collected and recycled at Scale, this tax will likely apply to all materials which are not able to be mechanically recycled and/ or in line with CEFLEX design guidance. Chemical Recycling and EfW will therefore likely not be eligible to be defined as Recycled.
Taxation PointCurrent legislation on taxation point states tax will be levied at the last substantial modification before packaging and filling. Current definition on this is: A component is finished if it has undergone it last substantial modification or in cases where the last substantial modification happens when the component is packed or filled; its last substantial modification will be that before being packed or filled. Tax on Exported goods will be reimbursed, but the mechanism is not yet clear. This is just one exemption others include primary packaging used for medicines, transport packaging for imported goods, cellulose.The levy will be paid annually by each Member State. However, it will be up to each member state to decide their own mechanism to raise the necessary contribution to the EU budget. It is not a direct taxation on the plastic industry. Each Member State can decide where to find the resources to honour this obligation.
Measures of evidence2 systems: For Tax accounting, invoices may need to list the Tax Levy as a separate line which will need to be reported in accounts. For Evidence of recycled content materials (and therefore Tax exemption) mass balance evidence will likely be used. This should include:
total amount in weight and a breakdown by weight of the materials used to manufacture plastic packaging, excluding packaging which is used to transport imported goods. weight of exempted plastic packaging and the reason for the exemption. amount in weight of plastic packaging exported, and therefore the allowed relief from the tax.
To be determined, however Mass Balance and self-declaration by governments most likely. Imports will also be applicable within the accounting by member states.
Use of revenue streamLikely used as a revenue stream to offset other governmental budget expenses. Cost impact currently queried by BPFContribution to overall EU budget funding – not destined for Recycling infrastructure *⁴

*¹ Skymark Packaging have been informed by HMRC via the BPF that the taxation levy of £200 is applicable before adding VAT charges, therefore levying a Tax onto a Tax.
*² Separate Taxation systems for plastics are also currently running alongside the EU taxation system in Italy and Spain. These are in addition to the EU taxation rules and apply to all plastics not meeting minimum technical requirements, as opposed to the EU taxation. The current position across the EU:

  • Greece implements a plastics tax of €66/tonne
  • Italy implements €450/tonne of plastic contained in the product with the exclusion of the amount of recycled plastic used (exemptions include Medical packaging and Compostable plastics
  • Spain (from July 2021) €450/tonne of non-reusable plastics containers, and all non-reusable plastic products serving to contain liquid or solid products, or to wrap goods or food products (including composite containers with plastic (medical and export packaging is exempt).

*³ The EU will base its calculations on the new methodology to calculate waste reported towards the attainment of recycling targets for the current financial year. Under this methodology, the amount of recycled packaging equals the amount which enters the recycling facility (input to recycling) as a general rule. The plastic levy will be calculated by deducting the weight of recycled (plastic) packaging from the weight of all (plastic) packaging placed on the market /waste generated, which needs to be reported by Member States.

On the other hand, EPR is a charge levied on business to foot the net costs traditionally absorbed by Government in regard to Material collection, sorting, segregation for recycling, system administration and consumer education on littering and clean-up costs. It has been estimated that the bill facing business could exceed £2.7 billion pounds at the point of implementation, however some argue that the cost may well be higher than expected due to uncertainty in volumes, reporting, etc. of this amount 1.5bn is associated with business waste and it is possible government may not require these costs to be transferred to brands, retailers and importers.

EPR will include a modulated fee (values yet to be decided) and it is unclear how detailed the categorisation will be in the final proposal. That being said, in the initial draft documentation, plastic packaging has had significantly higher levels of modulation than any other packaging material – attributed by the policy setters to the complexity of ranges of Polymer application, combinations and uses.

Valpak launched its own research on the consultation to establish what the likely impact of the EPR modulation may be and arrived at the following key findings:

The average historic EPR costs covering a period of 11 years and all material categories (Plastic, paper wood, glass, metal(s)) has yielded an average cost of compliance of around £24.14 per tonne which was cumulated through the supply chain as a whole.

Valpak went on to extrapolate that based on the government’s cost prediction and available volume data & expectations, the costs of EPR for Household and Household like waste could reach an average of around £310 per tonne – an almost 15 fold increase in cost of compliance. It is important to note that this figure is an average across ALL waste categories, therefore would be subject to being skewed by relatively cheaper EPR materials (Wood and Paper) compared to higher modulated materials (plastics and metals).

As mentioned, in the absence of defined modulation categories and predicted costs by the government (expected last 2021/ early 2022) it is difficult to work out what exactly the impact will be.

However, Skymark are of the opinion that the cost of EPR could well exceed that of the plastic tax. On that basis, Skymark are advising their clients that it may be in the longer-term interest to pay the Plastic Tax at the earlier stages, with a view of creating a more sustainable technical development which allows both the Tax and EPR to be adequately addressed. Not sure I understand this.

What are the impacts of these costs to me?

Well, as always, there are two sides to the coin:

Plastic Tax is the relative short-term impact on the manufacturer which drives a use of recycled content materials in packaging applications, so far as they are legally permitted to do so.

EPR is a longer-term impact which forces Brand Owners and Retailers to rethink their packaging formats in order to ensure they utilise the most recyclable version of a format possible. The reason for the distinction on these two costs to business (ultimately both are costs to consumers), is that solving one doesn’t necessarily negate the other. Let’s examine a few scenarios:

Please note, the following examples fictitious and values used within are used to illustrate only. Actual charges of EPR may vary.

Company A is a Packaging manufacturer for Spices and has decided it needs to take action to avoid Tax by building a multi-material structure with functional barrier which allows the use us PCR material in the structure without impacting on regulatory compliance. Company A now has a material capable of avoiding taxation charges but has an adverse impact on the recyclability of its material due to the added material complexity.

This means that by avoiding the Tax, they have increased the modulation fee of their material for EPR. Company A may have saved £200/t on Plastic taxes but may now face a higher EPR modulation charge of £400/t

Company B is a manufacturer of food packaging, whose mono material solution has been designed with recyclability in mind. The context of Legislation does not permit the use of Recycled content material within their packaging application in its current format. However, the Mono-material structure used by Company B has a high grade of purity and therefore attracts lower EPR modulation charge. Although Company B pays £200/t +VAT @20% for not meeting the requirements of the plastic tax, their modulation charge carries a cost of £150/t.

As a result of the above, Company B is paying £10/t less on the cost of its materials compared to Company B, however may be able to claim the VAT back later (Skymark Packaging are not financial advisers, so please seek independent financial advice on taxation matters).

What about Mass Balance Raw materials?

There are several products emerging which allow recycled material, either from Chemical recycling or Waste Stocks (Oil, Food, Pulp, etc) to be used in a food safe application. Products from the likes of Borealis, Lyondell Basell and Braskem to name a few are sparking a lot of discussion (particularly in regard to “what constitutes the boundary of recycled materials?”).

There are a few key points to note on these products:

  1. Chemical Recycling is considered in the UK to be permissible to be considered toward your min 30% recycled content threshold for taxation purposes, however, recycled materials from Gen 2 Feedstocks, such as Oils, Food source and other bio matter is not.
  2. Both raw material streams work on a mass balance approach, which means the material you purchase may not necessarily be recycled content, however, comes from a plant in which recycled content is handled and as such can be issued as certified to the requirements.
  3. In order to make any claims on these types of materials, the entire value chain must subscribe to Mass Balance systems, such as ISCC+ or BonSucro, each of them carrying some reasonably substantial costs with them, particularly for multi-site operations.
  4. The manufacturer premium levied on these types of products is dependent on the level of PCR % you would like to be certified, e.g., a 30% recycled content material mass balance certification may carry a £1,200/t premium over and above the cost of the virgin grade equivalent.