FILLERS & THE PLASTIC TAX

The FPA submitted a question to HMRC regarding the role of fillers to reduce plastic polymer content and whether fillers would be taxed under the Plastics Packaging Tax. The following response has been received: "Fillers added in this way would be considered as part of the plastic for the purpose of the tax, as would colourant and other additives”.

The FPA has countered this arguing:

• The filler is used to replace plastic content.
• Plastic is defined as a polymer: 'a synthetic material made from a wide range of organic polymers'- the filler is therefore not a polymer
• In the event the filler were to be cellulose, the decision means HMRC would be taxing cellulose, but cellulose is excluded from the tax

The HMRC decision flies in the face of research taking place to reduce plastic content with the use of fillers. Some of the funding has come from governments, so effectively this work has been wasted. HMRC is punishing those seeking to reduce plastic content.

Executive Director Martin Kersh says: "While the point about cellulose may be hypothetical, the aim is to establish a principle since such a lot of research is taking place on fillers and in 10 years the technology may well have changed. This means the secondary legislation needs to be future-proofed, otherwise investment in new technology may be reduced. Material developers need certainty their investment will be reflected in reduced tax.

"We’ve asked for a meeting as a matter of urgency as there is a big conflict between reducing plastic content and being taxed for doing so."

The FPA has countered this arguing:

• The filler is used to replace plastic content.
• Plastic is defined as a polymer: 'a synthetic material made from a wide range of organic polymers'- the filler is therefore not a polymer
• In the event the filler were to be cellulose, the decision means HMRC would be taxing cellulose, but cellulose is excluded from the tax

The HMRC decision flies in the face of research taking place to reduce plastic content with the use of fillers. Some of the funding has come from governments, so effectively this work has been wasted. HMRC is punishing those seeking to reduce plastic content.

Executive Director Martin Kersh says: "While the point about cellulose may be hypothetical, the aim is to establish a principle since such a lot of research is taking place on fillers and in 10 years the technology may well have changed. This means the secondary legislation needs to be future-proofed, otherwise investment in new technology may be reduced. Material developers need certainty their investment will be reflected in reduced tax.

"We’ve asked for a meeting as a matter of urgency as there is a big conflict between reducing plastic content and being taxed for doing so."

The FPA has countered this arguing:

• The filler is used to replace plastic content.
• Plastic is defined as a polymer: 'a synthetic material made from a wide range of organic polymers'- the filler is therefore not a polymer
• In the event the filler were to be cellulose, the decision means HMRC would be taxing cellulose, but cellulose is excluded from the tax

The HMRC decision flies in the face of research taking place to reduce plastic content with the use of fillers. Some of the funding has come from governments, so effectively this work has been wasted. HMRC is punishing those seeking to reduce plastic content.

Executive Director Martin Kersh says: "While the point about cellulose may be hypothetical, the aim is to establish a principle since such a lot of research is taking place on fillers and in 10 years the technology may well have changed. This means the secondary legislation needs to be future-proofed, otherwise investment in new technology may be reduced. Material developers need certainty their investment will be reflected in reduced tax.

"We’ve asked for a meeting as a matter of urgency as there is a big conflict between reducing plastic content and being taxed for doing so."