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Posted Thu, 17 Feb 2022 16:32:41 GMT by James
We will import our own empty plastic pallets (purchased in the EU) into the UK. These plastic pallets will be used to export goods from the UK to the EU. This cycle will repeat. We will re-import those same plastic pallets, once the goods have been taken from them, from the EU back into the UK. We will put goods onto the same pallets and export goods from the UK. https://www.gov.uk/government/publications/examples-of-packaging-in-and-out-of-scope-of-plastic-packaging-tax/packaging-in-and-out-of-scope-of-plastic-packaging-tax#plastic-packaging-designed-for-use-in-the-supply-chain This guidance notes that: "Examples of items not covered by this exemption, that are subject to the [Plastic Packaging] tax (PPT), include: transport packaging: imported into the UK as goods in their own right" It would appear that we would need to pay the Plastic Packaging Tax when we import the empty reusable plastic packaging. There are rules on deferring or obtaining credits in respect of the Plastic Packaging Tax. https://www.gov.uk/guidance/claim-a-credit-or-defer-paying-plastic-packaging-tax "Exporting finished plastic packaging: You can claim a credit or relief for finished plastic packaging which is exported from the UK if: at the point you import the finished plastic packaging, you intend to export the packaging yourself. *** You cannot claim relief for finished plastic packaging used for transport. ***" This suggests that we cannot reclaim the PPT when we use the reusable plastic pallets to transport our goods from the UK to the EU. Is it the case that, each time we import the same reusable plastic pallet, we will have to pay the PPT? and that we will be unable to recover this PPT? i.e. we will pay the PPT multiple times in respect of the same pallet? This seems very odd. I'm sure that I must be missing something,...
Posted Thu, 17 Feb 2022 17:06:32 GMT by James
Is the answer that you cannot claim 'relief', but you can claim a 'credit'? i.e. you have to pay the tax and then claim a credit each time that it is moved into and back out of the UK?
Posted Mon, 07 Mar 2022 15:04:31 GMT by HMRC Admin 17

Hi,
 
Plastic pallets are suitable for handling, delivering and presenting goods in the supply chain, and so are clearly packaging components for the purpose
of Plastic Packaging Tax.

If it is known when the pallets are imported that they will be exported again, the tax can be deferred and then cancelled when the export takes place.

 Alternatively, if the tax is accounted for on import and the pallets later exported, a credit can be claimed for the tax paid when the export takes place.

Pallets which are already in use but outside the UK on 1 April 2022 will also be subject to the tax on import according to the conditions outlined here.

I attach a link to some further guidance around this:

Claim a credit or defer paying Plastic Packaging Tax   .

Thank you.
Posted Mon, 14 Mar 2022 08:46:41 GMT by James
Thank you for your reply. Since posting the first query, I have continued to research this area. I would like to check your suggestion that the "the tax can be deferred and then cancelled when the export takes place." As noted in the original query, the pallets will be used to transport goods out of the UK. I don't believe that we can defer the tax in this scenario... albeit I struggle to see the policy rationale for this difference between export, and export with goods. Please would you confirm whether your reply "the tax can be deferred and then cancelled when the export takes place" is correct or not.
Posted Thu, 28 Apr 2022 15:48:43 GMT by HMRC Admin 10
Hi
Plastic Packaging Tax which was introduced on 1st April 2022 is to promote the use of recycled plastic.
Plastic Packaging Tax
Plastic Packaging Tax: steps to take
From the information provided, you will be able to defer the Plastic Packaging Tax (PPT) on the pallets you have purchased/imported provided that the following conditions are met. 
•    You Export the packaging within 12 Months of Import (or manufacture if produced in the UK).
•    Suitable records must be kept to demonstrate the weight of the packaging and the date of Export.
Please see guidance below on record keeping for PPT.
Records and accounts you must keep for Plastic Packaging Tax
All of the above would apply regardless of whether the pallets are empty or filled.
Thankyou.
Regards.
 
Posted Mon, 09 May 2022 12:47:52 GMT by James
Hi, Please would you double-check the advice provided above by "HMRC Admin 10", to ensure that it is correct. My understanding is that the tax deferral option doesn’t apply to transport packaging (singled out in the legislation), but that tax credits can be used to claim a credit on all chargeable plastic packaging components where tax has been paid on the components on import, and which are then exported. I understand that the pallets will need to be accounted for at import as a packaging component in their own right (and tax paid is applicable i.e., they contain less than 30% recycled plastic) and then the tax claimed back using the tax return during which the export of the pallets took place. Thanks
Posted Mon, 16 May 2022 17:04:21 GMT by HMRC Admin 10
Hi
Please follow this link to GOV.UK guidance.                                                                                                                                                                      Claim a credit or defer paying Plastic Packaging Tax - GOV.UK (www.gov.uk).
Claim a credit or defer paying Plastic Packaging Tax
Thankyou.
Regards.   

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