According to the World Bank, solid waste production reached 2.24 billion tonnes in 2020, and is projected to surge by 73% to 3.88 billion tonnes by 2050.
Plastic is ubiquitous and troublesome—one-third of the world’s plastic is used in packaging. Plastic bags snag on trees, clamshell packaging jams garbage bins, straws, and drinks lids litter sidewalks. The Great Pacific Garbage Patch—mostly plastic and twice the size of Texas—floats between Hawaii and California.1 of the 6.3 billion tons of plastic waste produced over the last seven decades, only 9% has been recycled and another 12% incinerated.2 Given that only a small percentage of the plastic waste has ever been recycled or incinerated, the need for strategic action against plastic misuse has never been more crucial.
There is some good news: Initiatives aimed at reducing plastic waste are growing globally, with the United Nations Environmental Programme (UNEP) championing the movement. In May 2023 UNEP launched negotiations to develop a framework for addressing plastic waste, with the goal of reaching an agreement by 2025.3 Many countries are also enacting regulations that ban or tax plastic manufacturing, imports, or general use.
Yet varying regulations and timelines add a layer of complexity for multinational companies as tax teams seek to comply with new rules; take advantage of related incentives; and mitigate regulatory, financial, and reputational risk. This article examines the burgeoning plastic regulations and their implications on tax teams, using the UK’s Plastic Packaging Tax (PPT) as a representative example.
Plastic has been the default option in design for too long. It is time to redesign products to use less plastic, particularly unnecessary and problematic plastics, to redesign product packaging and shipping to use less plastic, to redesign systems and products for reuse and recyclability...
—Inger Andersen, Executive Director, UN Environment Programme
Since introducing a charge for single-use plastic bags in 2015, the UK government reports a 98% decrease in their use at major retailers.
Furthermore, the UK’s plastic packaging tax went into effect April 1, 2022, as part of an initiative that sets recycling targets for six types of packaging by 2030. The PPT requires manufacturers and importers to use at least 30% recycled plastic by weight, or pay a tax currently assessed at £210.82 per ton of plastic packaging.
Currently, the UK government is consulting on how to measure recycled content in chemically recycled packaging for the purposes of PPT. The consultation process is expected to conclude in October 2023.
Demonstrating compliance can be challenging, but there are several actions organizations and tax teams can take to smooth out the process. So, what can we learn from the plastic packaging tax initiative? We can glean several lessons:
Promote data transparency and clarify roles:
Businesses seeking to demonstrate compliance with PPT targets must decide who will document plastics use, design, and implement data collection processes, and collect and submit the results. While many organizations have a sustainability officer or tax lead dedicated to environmental issues, PPT’s specific data analysis and reporting requirements are likely to require a cross-functional effort from tax, procurement, logistics, and product design and manufacturing—including clarification of individual responsibilities and adoption of new work processes.
Rethink the entire product lifecycle and supply chain:
Because the PPT applies to imports, businesses must capture information on packaging from supply chain counterparties as well as UK-based operations—in many cases, working with suppliers to prioritize recyclability in product design and throughout the product lifecycle. This could mean redesigning both business models and manufacturing processes to reduce waste, boost recyclability, and promote overall resource efficiency.
Strategize on plastic use:
Complying with the PPT—and practicing true sustainability—takes more than supply chain optimization and data analysis. It takes a whole new mindset. This is particularly true in the UK, where updates to the Extended Producer Responsibility (EPR) Act will be phased in beginning in 2024. Businesses will pay the cost of collecting and recycling any packaging they use, eventually paying more for less sustainable packaging. The act is designed to encourage not just use of, but research into, materials that replace or dramatically reduce plastics use.
Regulations to reduce plastic use and increase recyclability are being adopted around the world. Many are grounded in broader producer responsibility, including bans on specific products. Others incorporate incentives for sustainable design and production. Some do both. And for tax teams, it’s becoming more challenging to track, understand, comply with, and use all the methods needed to mitigate risk.
Around the world, many jurisdictions are passing regulations to curtail plastic use and promote recyclability. From the EU's innovative plastics initiatives to the Asia-Pacific's regional collaboration and Canada's ambitious Zero Plastic Waste Strategy, nations are stepping up to the challenge.