The closed-loop recycling amendment to packaging Extended Producer Responsibility (pEPR) was laid before Parliament in November 2025 and came into force on 1 January 2026, with updated guidance published on 13 January 2026 by GOV.UK.
The amendment allows large producers to offset qualifying closed-loop food-grade plastic packaging that they collect and recycle against the weight of household packaging they place on the market, reducing their household pEPR fee liability where strict conditions are met.
This article explains what qualifies as closed-loop packaging, how it must be reported, key deadlines, and the additional reporting costs producers should plan for.
What is closed-loop recycling?
“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.” – Extended Producer Responsibility for packaging: closed loop recycling – GOV.UK
Closed-loop recycling under pEPR applies only where producers take direct responsibility for collecting and recycling specific qualifying packaging they have placed on the market, and where that material is demonstrably recycled back into food-grade plastic.
Which packaging qualifies as closed loop?
To qualify, packaging must be household packaging placed on the market by a large producer and must meet all of the following criteria:
- It is food-grade plastic packaging
- It is collected from the end user by or on behalf of the same producer who supplied it
- It remains segregated from other waste streams during collection and transport
- It is recycled by a single accredited reprocessor or exporter
- It is recycled back into food-grade plastic material or finished articles
An example of packaging that could qualify is PET ready-meal trays, if they are made from food grade plastic and are classified as household packaging.
Collection requirements
To claim a closed-loop offset, the producer that placed the packaging on the market must also arrange its collection from the consumer. Collection may be carried out directly or through an approved third party acting on the producer’s behalf. Materials must remain segregated from other waste throughout handling and transport.
Recycling process requirements
Closed-loop material must be processed by a single accredited reprocessor or exporter who confirms that the material has been recycled back into food-grade plastic material or articles. Split processing across multiple reprocessors does not qualify.
What evidence is required for closed loop reporting?
Producers must hold sufficient documentary evidence confirming that all closed-loop conditions have been met. Evidence must come from the accredited reprocessor or exporter and should include:
- confirmation of the proportion of collected material successfully recycled
- a clear explanation of how this percentage was calculated
- documented producer validation checks on reported figures
What are the eligibility timing rules for closed-loop offsets?
Closed-loop offsets can only be claimed for packaging that was supplied as filled on or after 1 January 2024.
Where producers collected qualifying packaging before 1 January 2025 and have already submitted packaging data, they may amend and resubmit those reports within the permitted correction windows.
How do I report closed loop data?
Closed-loop recycling data is reported through the Report Packaging Data (RPD) service.
Clarity members should submit this information as part of their standard packaging data submission to Clarity.
For the 2024 and 2025 reporting periods, producers must resubmit data using amended self-managed consumer waste figures. A revised reporting process for 2026 data is expected to be introduced, with further guidance to follow.
What are the key reporting deadlines?
Producers must meet the following reporting deadlines for closed loop packaging data:
| Reporting period | Deadline |
| January – June 2024 | 28 January 2026 |
| July – December 2024 | 28 January 2026 |
| January – June 2025 | April 2026 |
Are there additional reporting charges?
Producers claiming closed-loop offsets must pay an additional reporting charge of £2,548 per year of data submitted.
- One combined £2,548 payment covers both 2024 and 2025 submissions (due by 28 January 2026)
- A further £2,548 payment is required to submit 2026 data (also due by 28 January 2026)
- For 2027 data, payment must be made by 1 October 2026
- In future years, payment will be due each October for the following year’s submission window
Closed-loop packaging data cannot be submitted until the charge is paid.
Further information on closed-loop recycling is available on the GOV.UK website.
