The Institute of Chartered Accountants in England and Wales (ICAEW) has urged the government to take a cautious approach to any plan for universal mandatory certification for mechanically recycled plastic packaging.
It warned that a blanket requirement could put businesses off using recycled packaging.
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In its response to a government consultation, ICAEW said it supports the policy goal behind the proposal.
However, it said the case for introducing a new compulsory certification system across the full supply chain has not been clearly made.
The body said HMRC has little evidence of widespread fraud in this area.
It argued that the scale of any problem, and where it sits in the market, should be established before ministers decide on new rules.
ICAEW also said the current design of the plastic packaging tax already offers protection for tax revenues.
The tax applies by default, while any exemption depends on businesses being able to provide evidence.
If a company cannot get sufficient proof from a supplier, the tax must still be paid.
The chartered accountancy body said that leaves businesses with a commercial choice: pay the tax, push suppliers for better evidence, or switch to another supplier.
On that basis, ICAEW said a mandatory certification scheme is not required to secure compliance.
It added that such a system would instead bring additional administrative work and higher costs for businesses.
The organisation also pointed to the focus of the government’s own consultation paper.
It said the evidence and concerns raised there appear to relate mainly to imported packaging.
Because of that, ICAEW said any new requirement should be proportionate and based on risk.
It said the same compliance burden should not be imposed across both domestic and overseas supply chains.
The Institute also called for a realistic implementation period if any changes go ahead.
ICAEW tax technical manager Ed Saltmarsh said: “A universal mandate, applied without regard to size or risk, would sit uneasily with the government’s commitment to reduce the administrative burden of regulation on business by 25% by the end of this Parliament.
“Therefore, any requirement should be risk-based, evidenced, and designed to avoid a situation where the cost of demonstrating eligibility outweighs the benefit of using recycled plastic. If certification does proceed, it should build on a competitive market of accredited schemes and bodies, align with and follow the framework being developed for chemically recycled plastic, and allow a realistic lead-in time that does not clash with the other plastic packaging tax changes planned for April 2027.”
