Extended Producer Responsibility for packaging: closed loop recycling
Closed loop recycling under Extended Producer Responsibility (EPR) for packaging - what it is, how to report it and a summary of fees and conditions
The regulations supporting this guidance are currently going through Parliament. There are unlikely to be changes to the draft regulations that will affect this guidance. They are expected to come into force on 1 January 2026.
If you are a large producer reporting under EPR for packaging, you will be able to offset the weight of ’closed loop’ packaging waste that you collect and recycle against the weight of household packaging you supply.
You’ll have to contact your regulator and pay a charge to do this.
For more information about EPR for packaging, including who must report and what information they must collect and submit, check the EPR for packaging guidance.
What ‘closed loop’ packaging waste is
‘Closed-loop’ packaging waste is household packaging that meets certain conditions:
It must be:
- made of food-grade plastic packaging
- collected from the end user by or on behalf of the same producer who supplied it
- recycled by a single reprocessor, in the UK or overseas
- recycled into food-grade plastic material or articles
What materials are used
Eligible closed loop packaging waste must be made from food grade plastic household packaging.
Examples include PET ready-meal trays.
Collection
To be eligible for the closed loop offset, the producer who supplied this packaging must also collect it from the consumer.
They can do this themselves or commission someone to do this on their behalf. The closed loop packaging waste must not be mixed with any other waste during the collection and transport.
Recycling process
The closed loop waste must go to a single accredited reprocessor or exporter.
The reprocessor or exporter must recycle the waste back into food-grade plastic material or articles.
What closed-loop waste is eligible for offsetting
You can only report closed loop packaging that you supplied as filled packaging on or after 1 January 2024.
You must report this packaging in your packaging waste data for the appropriate period.
If you collected the packaging before 1 January 2025 and have already submitted data for that period, you can amend your data and resubmit it.
How to report or amend your data
You’ll report your closed loop recycling using the Report Packaging Data service.
For data from 2024 and 2025, you will resubmit an amended figure for self-managed consumer waste.
For 2026 data, there will be a new reporting process in Report Packaging Data. Details will given in 2026.
When you must report your closed loop data
| Reporting period | Deadline |
|---|---|
| January to June 2024 | 28 January 2026 |
| July to December 2024 | 28 January 2026 |
| January to June 2025 | April 2026 |
Evidence you must supply
You must supply evidence that all the conditions that apply to closed loop recycling have been met.
For example, you could obtain written confirmation from your reprocessor that outlines what percentage of material collected and sent to them was actually recycled. The reprocessor would have to show how they determined this value. You’d also need a documented process for validating the reprocessor’s figures.
What you will pay to offset your household packaging
You will have to pay an additional charge to submit closed-loop packaging data. This is a set annual charge. For 2024, 2025 and 2026 data the charge is £2,548.
You pay the same amount for each year whether you are using the closed loop offset for one or both annual reporting periods.
There is a single combined charge for 2024 and 2025 data. Pay £2,548 by 28 January 2026 to cover both years.
If you wish to submit data for 2026, you must pay another £2,548 charge before 28 January 2026.
If you wish to submit data for 2027, you must pay another charge before 1 October 2026.
For each year after that, you will pay in October for data that is due to be submitted the following October.
You cannot submit closed loop packaging data if you do not pay this charge.
Email your regulator for advice on how to pay:
- the Environment Agency (England): packagingproducers@environment-agency.gov.uk
- Natural Resources Wales: packaging@naturalresourceswales.gov.uk
- the Northern Ireland Environment Agency: packaging@daera-ni.gov.uk
- the Scottish Environment Protection Agency: producer.responsibility@sepa.org.uk
Include your organisation number in the email. You’ll get this number when you create your account to report packaging data.
Updates to this page
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A note to say that these regulations have not yet passed Parliament, but should come into force 1 January 2026
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First published.