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

A New Horizon for Sustainable Packaging

In the current environmental and economic landscape, the issue of plastic waste has taken centre stage. Governments, businesses, and consumers alike are grappling with the challenge of reducing plastic waste and promoting sustainable practices. One such initiative is the Plastic Packaging Tax (PPT), introduced by HM Revenue and Customs (HMRC). Recently, HMRC has proposed a significant change to this tax – the use of a mass balance approach to account for chemically recycled content in plastic packaging.

The mass balance approach is a method of accounting where the input and output of a process are balanced, and the properties of the input are allocated to the output products. In the context of PPT, this approach would allow businesses to account for the chemically recycled content in their plastic packaging, potentially reducing their tax liability.

The HMRC consultation document outlines the potential implications of this approach. The primary aim is to incentivize the use of chemically recycled plastics, thereby reducing the environmental impact of plastic waste. This could stimulate growth and investment in the emerging sector of chemical recycling, leading to economic development and job creation. However, the proposal is not without its challenges. Implementing a mass balance approach could introduce additional administrative burdens for businesses, requiring them to become certified and provide evidence of the recycled content in their products.

The mass balance approach presents both opportunities and challenges. On the positive side, it could drive the demand for chemically recycled plastic, promote investment in the recycling sector, and enable businesses to reduce their PPT liability. However, it could also introduce additional administrative burdens, create verification challenges, and potentially open the door to misleading environmental claims.

In analyzing these points, it becomes clear that the success of the mass balance approach will largely depend on its implementation. The potential benefits are significant, but they must be balanced against the potential drawbacks. Clear guidelines, robust verification processes, and effective enforcement will be crucial to ensure the integrity of the system and prevent misuse.

Looking ahead, the mass balance approach could represent a significant step forward in the quest for sustainable packaging. However, it is just one piece of the puzzle. Achieving a circular economy for plastics will require a multi-faceted approach, involving not only innovative taxation measures but also advancements in recycling technology, changes in consumer behavior, and global cooperation.

As we reflect on the potential of the mass balance approach, it is clear that this is a complex and evolving issue. The HMRC consultation is an important part of the process, providing an opportunity for stakeholders to contribute their views and help shape the future of the PPT. As the consultation progresses, it will be fascinating to see how this proposal develops and what impact it could have on the future of plastic packaging.

New changes in the tax rate and penalties for non-compliance take effect on April 1st, 2023, as the “soft landing” period comes to an end.

The final meeting of the Industry Working Group for the Plastic Packaging Tax took place yesterday at the Treasury, where important changes to the tax were discussed and finalized. The tax rate has been increased from £200 to £210.82, in line with the Consumer Price Index (CPI) inflation rate. These changes will come into effect on April 1st, 2023. This change comes as the “soft landing” period for the tax draws to a close in April, and non-compliant companies will now face fines.

The Plastic Packaging Tax, which was introduced as a measure to encourage the use of recycled materials in plastic packaging and reduce plastic waste, has now become more stringent. With the end of the “soft landing” period, businesses that fail to comply with the tax regulations will be subject to penalties.

Key changes to the tax regulations include:

  1. Tax rate increase: The tax rate has been increased to £210.82, in line with the CPI inflation rate, to ensure that the tax remains effective in encouraging the use of recycled materials and reducing plastic waste.
  2. End of the “soft landing” period: The one-year grace period for companies to adjust to the new tax rules is ending in April. Starting from April 1st, 2023, non-compliant companies will face fines for failing to meet the tax requirements.
  3. Late return submission penalties: Companies that submit their tax returns late will now be fined. Late payment rules have been modified to bring the Plastic Packaging Tax in line with other taxes.
  4. Interest charges for late payments: Companies that submit their tax payments late will be charged interest on the outstanding amount.
  5. Penalties for non-submission: Companies that fail to submit a return will not only be fined but will also have their tax obligations estimated by the authorities.

As the Plastic Packaging Tax becomes more stringent, it is crucial for businesses to be aware of these changes and ensure their compliance. Companies are urged to review their current practices, make necessary adjustments, and submit their returns and payments on time to avoid fines and penalties. The increased tax rate and the introduction of stricter enforcement measures signal the government’s commitment to reducing plastic waste and promoting a more sustainable future.

In light of these changes, Skymark remains committed to innovation and development in relation to recycled content across our product ranges. Our continuous efforts in sustainability and eco-friendly packaging solutions will help our customers adapt to the new tax regulations while contributing positively to the environment.

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

The year 2022 has seen a multitude of developments in the realm of packaging trends, making it difficult to stay abreast of all the changes. However, we are here to provide a summary of the most noteworthy trends we have observed in 2022

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.

Launching with its most popular product, Andrex® Classic Clean, the new packaging will be designed using 30% recycled plastic packaging made from post-consumer resin. Ensuring the packaging continues to be fully recyclable, PCR is a sustainable packaging alternative made from plastic materials used by consumers.

The plastic is then taken to a facility where it is washed, reground and pelletized into a new usable material.  The new Andrex® Classic Clean packs will begin to appear on all major retailers’ shelves from June 2020, a change which will remove 481 tonnes of virgin plastic over the next 12 months from this variant alone. That’s the equivalent of over 48 million 500ml PET virgin plastic bottles.

The announcement marks yet another step towards a wider ambition to reduce the brand’s usage of virgin plastic. By 2023, Andrex® is targeting to have at least 50% recycled plastic across all its packaging.

Ori Ben Shai, Vice President & Managing Director of Kimberly-Clark UK, said: “At Andrex, we are committed to improving the sustainability of our products and packaging. The launch of the new 30% recycled plastic packaging forms part of our wider ambition to leave a greener ‘pawprint’ on the planet. Beyond this, we aim to have at least 50% recycled plastic content in our packaging by 2023, and we will continue to look for more sustainable alternatives that reduce our environmental footprint, without compromising on the quality of our products that our customers know and love.”

The announcement is just the latest step in the brand’s wider plan to further enhance its sustainability of its products, packaging and processes as part of the Andrex® Greener Paw Print initiative.

All Andrex® Toilet Tissue dry packaging is 100% recyclable and the brand recently removed plastic handles from wrapped Andrex® packs of toilet tissue saving 31 tonnes of plastic per year.  In addition to this, Andrex® Washlets were the first major UK brand to receive Water UK’s ‘Fine to Flush’ certification, which scientifically tests whether flushable wipes can be flushed down toilets and pass safely through sewer systems. The certification, announced earlier this year, sits across the full Andrex® Washlets range.