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United KingdomGOV.UK

EPR closed-loop column gets strict validation: blanks now fail

EPR registration guidance now requires explicit Yes/No in column CA for closed-loop reporting; blank cells and invalid values fail validation instead of defaulting to No.

By Taxxa AI OyPublished 10 September 2026

Public Sector & Economy

Industry: Across industries

Producers registering for extended producer responsibility (EPR) for packaging record their closed loop packaging waste reporting position in column 'CA' (closed_loop_registration) of the organisation details file.GOV Column 'CA' is shown in the organisation details template provided in the registration guide. A producer registering to report closed loop packaging waste data enters 'Yes' in column 'CA'.GOV

A producer that does not intend to report closed loop packaging waste data has two compliant options: submit the organisation details file without a column 'CA' at all, or enter 'No' in column 'CA' for every row in the file.GOV The previous behaviour no longer applies: the column was described as optional, and a missing column or a blank cell defaulted to 'No'GOV. Under the revised instructions, blank cells and invalid values cause a validation error for column 'CA'GOV — only 'Yes' or 'No' may be enteredGOV.

The practical consequence is that files relying on the old blank-default can now fail validation. An organisation details file that includes column 'CA' but leaves any of its cells blank, or enters any value other than 'Yes' or 'No', produces a validation error instead of registering silently as 'No'.GOV Compliance schemes and consultants preparing files for clients should populate every row explicitly where column 'CA' is present. Producers that do not intend to report closed loop data may either omit column 'CA' altogether or enter 'No' for every row.GOV

The change concerns the registration file format only. Details are submitted in comma-separated values (CSV) files structured per the organisation details, brand details and partner details templates, with brand details required where goods are supplied in packaging under the producer's own brand and partner details required for organisations registered as partnerships with Companies House.

Legal basis: the registration guide is procedural guidance for the EPR for packaging registration file; no new statutory duty is stated on the pageGOV.

Audit organisation-details files for column CA before the next EPR submission: fill every row with Yes or No, or remove the column entirely, so no blank or invalid cell triggers a validation error.

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