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24 February 2022 Press Release


HMRC is classifying pan liners as packaging and as such they will be included in the scope of the Plastic Packaging Tax, even though they do not perform a packaging function, and prices will rise accordingly from the introduction of the tax in April of this year. Pan liners are widely used in commercial kitchens and bakeries, protecting pans (including gastronorm pans and commercial cake tins) and ensuring longer life, saving labour costs on time spent cleaning, saving water and energy, and for religious purposes.

The FPA conducted a survey on LinkedIn and Twitter last week, with responses coming from non members in hospitality and in answer to the question ‘Is a pan liner packaging?’ the answer was a resounding ’no’, with 92% disagreeing with HMRC’s insistence that pan liners are packaging.


HMRC has correctly granted an exemption for silage wrap on the grounds ‘The intention of this exemption is to exclude items from the tax which meet the definition of a packaging component but are manufactured or imported for a different primary purpose’. Pan liners fit this description exactly but HMRC still maintain that pan liners are packaging:  "Our view is that these meet the definition of packaging” (and when not in the supply chain..) "fall under a single use product designed to be used by a consumer or user in performing one or more of the following functions in respect of goods or waste: containment, protection, handling, presentation and delivery".


Executive Director Martin Kersh says: “Many in hospitality won’t be aware pan liners are included in the scope of the tax, and some may not even be aware of how the tax will increase their costs. Packaging is designed to protect its contents, however the role of pan liners is to protect pans - a completely different function from packaging. The Exchequer Secretary, Helen Whately MP, has been made aware of this anomaly and that it equally meets, if not exceeds, her criteria for exempting silage wrap.”


The FPA is continuing to lobby for an exemption for pan liners.


Ends                                                                                                          22 February 2022


Issued on behalf of the Foodservice Packaging Association by Leapfrog PR. Editorial contact is Felicity Read on 07887 608353 or email