The United Kingdom is linking packaging recyclability directly to Extended Producer Responsibility costs.

From the 2026/2027 financial year, the household packaging waste disposal fees paid by large producers are being adjusted according to the packaging’s Recyclability Assessment Methodology rating. Packaging rated red attracts a higher fee, amber packaging remains at the base rate and green packaging receives a discount. The first modulated fees are calculated using packaging supplied and reported for 2025.

A producer’s own recycling claim does not determine the result.

Packaging may be technically recyclable, accepted by a specialist recycler or labelled as recyclable for consumers and still receive a red RAM rating. The methodology considers whether the packaging can move through the United Kingdom’s existing collection, sorting, reprocessing and secondary-material markets at scale.

This creates a closer connection between packaging design, supporting evidence and the EPR fees ultimately paid by the producer.

What is the Recyclability Assessment Methodology?

The Recyclability Assessment Methodology, commonly referred to as RAM, is the system used to classify relevant packaging as red, amber or green.

Large producers must assess the household packaging they supply and report the resulting ratings alongside their other packaging data to the applicable environmental regulator. The assessment also covers packaging that commonly becomes waste in public bins. Reusable and refillable household packaging is assessed when it is first supplied.

The requirement applies to large packaging producers. Under the UK EPR framework, an organisation is generally classed as large where it has annual turnover of at least £2 million and is responsible for supplying or importing more than 50 tonnes of packaging in the UK. Smaller obligated producers have separate registration and data-reporting requirements but are not currently required to complete the same RAM assessments.

RAM does not ask only whether a packaging material can theoretically be recycled. It examines whether it is recycled in practice using established operational infrastructure with sufficient capacity to manage the quantities placed on the market. Pilot projects and technically possible processes that are not available at a meaningful scale are not enough to support a green rating.

Which version of RAM applies?

The applicable methodology depends on the reporting year.

RAM version 1.1 must be used for packaging supplied during the 2026 calendar year. RAM 2027, published by PackUK in July 2026, applies to packaging supplied from 1 January to 31 December 2027.

RAM 2027 therefore does not replace the methodology used for current 2026 reporting.

Companies should maintain a clear distinction between:

• ratings already reported for packaging supplied in 2025;
• assessments prepared under RAM version 1.1 for the 2026 reporting year;
• assessments that must be updated under RAM 2027 for packaging supplied in 2027.

A packaging design can receive a different rating in a later reporting year if the methodology, collection coverage, recycling infrastructure or available evidence changes. PackUK intends to review and publish RAM annually so that the assessment reflects current UK recycling conditions.

A recyclable label does not determine the RAM rating

RAM ratings are expressly separate from other recyclability labels or environmental claims displayed on packaging.

A producer may use an on-pack recycling label based on consumer guidance, a voluntary industry methodology or the availability of a specialist collection route. None of these automatically establishes the packaging’s RAM status.

The difference arises because the systems may answer different questions.

A consumer label may explain what the consumer should do with the packaging. A technical claim may show that a material can be processed under controlled conditions. RAM asks whether the packaging can reliably pass through the UK’s operational recycling system at scale.

A producer should consequently avoid assuming that an existing “recyclable”, “widely recycled” or similar statement can be copied into the EPR report as evidence of a green rating.

The reverse also requires care. A green RAM result does not automatically authorise an environmental marketing claim. Consumer-facing claims remain subject to the UK’s rules on fair and substantiated environmental statements, including the Competition and Markets Authority’s Green Claims Code.

RAM assesses four stages of recycling

RAM 2027 evaluates packaging through four connected stages:

• collection;
• sortation;
• reprocessing;
• application of the resulting recyclate.

A green result requires the packaging to be rated green at every relevant stage. Packaging that receives an amber assessment at one or more stages cannot obtain a final green rating. A red result at any stage will generally determine the final rating.

This means that the performance of the base material alone is not sufficient.

A plastic container may be widely collected but fail during automated sorting. It may be correctly sorted but contaminate the reprocessing stream. It may produce recyclate for which no practical end application exists.

The weakest stage can therefore determine the final EPR classification.

Collection: is the packaging actually captured?

The first stage examines whether the packaging enters the UK recycling system through an established collection route.

For a green collection-stage rating under RAM 2027, the packaging or component must generally be collected at the kerbside by at least 75% of UK local authorities.

Packaging collected by at least 50% but fewer than 75% of local authorities is treated as having limited collection. It may continue through the later assessment stages, but its final result is capped at amber.

Packaging falling below both thresholds is generally red unless it qualifies through an acceptable take-back scheme.

These thresholds explain why a material can be technically recyclable but still fail RAM.

A recycler may be able to process a particular packaging format, but that capability has limited value if most households cannot place it into an established collection system.

Collection classifications can also change between reporting years as local-authority services develop. Producers should use the official collection list for the relevant reporting period rather than rely on an older assessment or general assumptions about UK recycling.

Sortation: can the system identify and separate it?

Collected packaging must be separated into the appropriate material stream.

RAM considers whether existing material recovery facilities can identify and sort the item reliably at normal operating volumes. Size, shape, colour, density, labels and material combinations can all influence this result.

For rigid plastic packaging under RAM 2027, an item or component generally needs to measure at least 40 millimetres in at least two dimensions to receive a green sortation-stage rating. Smaller detachable components can be rated red where they cannot be reattached to the main packaging body.

Carbon black that prevents effective near-infrared detection also results in a red sortation assessment for rigid plastics. A container may therefore be manufactured from a polymer with an established recycling route and still receive a red result because sorting equipment cannot reliably identify it.

Labels and sleeves are another important factor.

An attached label or sleeve made from a different material and covering more than 60% of a rigid plastic item’s surface can lead to an amber sortation rating. The packaging may still be recyclable, but its design makes correct identification more difficult.

Reprocessing: does the design contaminate the material stream?

After collection and sorting, the packaging must be capable of being reprocessed into usable secondary material.

RAM assesses whether coatings, barriers, additives, inks, adhesives and components interfere with the relevant recycling process or reduce the quality of the recyclate.

Under RAM 2027, rigid plastic packaging can receive a red reprocessing rating where it contains materials such as PVC, polystyrene, certain foamed plastics, oxo-degradable plastics, biodegradable or compostable plastics, or other specified contaminants. Adhesives that do not release labels during a standard hot-wash process can also produce a red result.

The criteria become more specific for individual polymer and packaging formats.

For example, a PET bottle can be rated red where it contains specified high-density labels, sleeves, seals or valves that interfere with the PET recycling process. Certain multilayer structures and barriers can also affect the rating of PET, HDPE and polypropylene packaging.

This is why a statement that a package is “made from PET” or “made from polypropylene” is not enough for a RAM assessment.

The complete structure must be understood.

Application: can the recyclate be used again?

Recycling does not end when waste has passed through a reprocessing facility.

RAM also considers whether the resulting secondary material can be used in practical applications that keep the resource circulating within the economy.

A process that produces material with no stable or suitable end use does not demonstrate recycling at scale. The same applies where contamination or material degradation substantially restricts the use of the recyclate.

This application stage prevents a packaging format from receiving a green result solely because it can be collected and mechanically processed. The resulting output must have a functioning place in the current recycling economy.

For some materials, colour, additives or direct printing can reduce the range or value of future applications.

RAM 2027, for example, gives PET bottles a red application-stage result where the plastic is a colour other than clear or translucent light blue. Direct printing beyond limited batch or expiry information can also lead to a red assessment for certain rigid plastic formats.

Packaging must be classified correctly before it is rated

Before applying the four recycling stages, a producer must decide what is being assessed.

Some packaging must be assessed as separate components. Other packaging is treated as one integrated item and reported under its predominant material by weight.

A component should generally be assessed separately where it is distinct from the main packaging body or where it must be removed to use the product and cannot be reassembled. Examples include a plastic blister attached to cardboard backing or a removable cork from a wine bottle.

Where components of different materials form one item and cannot be separated without tools or mechanical processing, the whole item is generally assessed under the material that represents the greatest weight.

This classification decision can materially affect the rating and the fee.

A cardboard-backed blister pack should not automatically be reported as one paper item. A metal aerosol can with integrated plastic parts may require a different approach. A composite paper package with more than 5% plastic by mass must be assessed as a fibre-based composite rather than ordinary paper or board under RAM 2027.

Companies need component-level specifications before they can determine the correct material category.

A small design feature can affect the complete item

Packaging teams often focus on the main container because it represents most of the packaging weight.

RAM can make smaller features equally important.

Relevant features can include:

• a full-body sleeve;
• a non-releasing adhesive;
• a silicone valve;
• a barrier layer;
• a coloured polymer;
• a metal spring in a trigger mechanism;
• a non-separable foil layer;
• direct printing on the container;
• an integrated battery or electronic light.

Some of these features can downgrade the package from green to amber. Others can result in a red rating.

This creates a commercial incentive to assess recyclability before finalising the packaging specification rather than after products have already been supplied and the EPR data is being prepared.

Some packaging is automatically red

RAM 2027 introduces criteria under which packaging must be rated red without proceeding through the remaining material assessment.

Automatic-red criteria apply where legal, chemical or systemic barriers mean that the packaging cannot be treated as recyclable within the EPR framework, regardless of whether a technical recycling process may exist.

Examples include packaging with integrated electrical or battery components, packaging containing specified substances of concern above relevant thresholds, non-compliant food-contact packaging and packaging formats subject to UK restrictions or phase-outs. RAM 2027 also introduces specific criteria concerning PFAS and printing inks.

An illuminated presentation box containing integrated LED components may therefore be treated differently from an ordinary cardboard box.

The automatic-red rules also demonstrate why RAM is not solely a mechanical-recycling test. Legal compliance and chemical safety form part of the methodology.

Medical packaging may receive special treatment

Some packaging designs are difficult to recycle because another regulatory framework requires particular materials, barriers or performance characteristics.

RAM 2027 includes a specific mechanism for medical packaging that is red because of a regulatory requirement. Where the required conditions are met, the producer may report the packaging as amber rather than red.

The producer must retain clear evidence identifying the applicable regulatory requirement and showing why a more recyclable alternative cannot lawfully be used.

This is not a general exemption for all pharmaceutical, veterinary or medical-device packaging.

The package must meet the relevant definition of medical packaging, and the red feature must result from an actual regulatory requirement rather than commercial preference, historic design or internal quality standards.

Can a take-back scheme improve the rating?

A dedicated take-back system can support an amber rating for certain packaging that is not collected through ordinary kerbside systems.

It cannot produce a green rating.

To qualify, the producer must retain evidence that the scheme meets detailed accessibility, neutrality and traceability requirements. Among other conditions, collection points must be accessible to at least 75% of the UK population or households within five miles of their homes, or a postal system must cover at least 75% of UK home addresses.

The scheme must accept the relevant packaging from all brands, must not require a new purchase and must trace the specific material through collection, sorting, reprocessing and application.

A small brand-operated collection box at a limited number of stores will therefore not necessarily qualify.

A general statement from a waste contractor that the material is recycled is also unlikely to be sufficient. The evidence must connect the particular packaging material and format to each stage of the recycling process.

Packaging using a qualifying take-back route can be rated amber. Without adequate evidence, it remains red.

How RAM ratings affect producer fees

Fee modulation applies to the household packaging waste disposal component of the EPR charge.

Amber represents the base disposal fee for the relevant material. Red packaging receives a multiplier, while the additional revenue generated by red packaging is redistributed as a discount for green packaging.

The overall amount collected across all household packaging is not increased by modulation alone. Modulation changes how the costs are allocated between producers and packaging designs.

The red multiplier increases over the first three modulation years:

• 2026/2027: 1.2 times the amber disposal fee;
• 2027/2028: 1.6 times the amber disposal fee;
• 2028/2029: 2.0 times the amber disposal fee.

Amber packaging receives no modulation adjustment. The green discount is variable because it depends on the amount of additional revenue generated by red packaging and the total quantity of green packaging reported across the system.

A green rating therefore does not guarantee a fixed percentage discount from year to year.

What could the cost difference look like?

PackUK’s latest illustrative Year 2 figures show how RAM classifications can affect costs.

For plastic packaging, the illustrative rates were:

• £415 per tonne for green;
• £455 per tonne for amber;
• £545 per tonne for red.

The red figure reflects the fixed 20% increase on the amber rate. The illustrative green rate represented a discount of approximately 9%, based on the RAM data available when the estimate was produced.

These figures are not the final 2026/2027 rates.

PackUK stated that the estimates could change as more complete and verified producer data became available. The green discount is particularly sensitive to the proportion of packaging ultimately reported under each RAM category.

The example nevertheless shows the direction of the policy. A business placing 1,000 tonnes of red-rated plastic packaging on the UK market could face a materially higher disposal charge than a competitor using a green-rated design in the same material category.

The financial difference will become more significant as the red multiplier increases in later years.

Why accurate 2025 data remains important

The first modulated disposal fees for 2026/2027 are calculated using packaging supplied during 2025.

PackUK has introduced a deadline of 1 September 2026 for fee-paying producers to resubmit corrected 2025 packaging data where necessary. Corrections submitted after that date must still be made to keep regulatory data accurate, but they will not affect the relevant Notices of Liability or disposal fees.

This makes the current data review commercially significant.

An incorrect material category, household classification, packaging weight or RAM result can affect the producer’s fee allocation. A producer reporting through a compliance scheme may also need to meet an earlier internal deadline so that the scheme has time to validate and resubmit the information.

The review should not focus only on missing tonnage. It should also examine whether the underlying RAM assessments are supported by the packaging specifications and evidence available at the time of reporting.

Missing RAM information can lead to red treatment

The 2025 reporting period included regulatory flexibility for producers that did not submit RAM information for the first half of the year.

Where the applicable conditions are met, PackUK can extrapolate the producer’s second-half 2025 RAM proportions across the full year.

However, insufficient recyclability information can result in affected packaging being charged at the red rate. If a producer supplied relevant household packaging only during the first half of 2025 and failed to provide the required assessment information, the packaging can be treated as red for fee-modulation purposes.

This reinforces the difference between missing data and neutral data.

A producer should not assume that an unassessed package will receive an amber rating. Where the scheme cannot determine the relevant sustainability level, the financial outcome can be equivalent to a red assessment.

Packaging data must extend beyond weight and material

Traditional packaging reporting often relies on the material category, component weight and quantity supplied.

RAM requires more.

Depending on the packaging format, the producer may need reliable information concerning:

• polymer type;
• component dimensions;
• colour;
• density;
• adhesives;
• coatings and barriers;
• label and sleeve materials;
• surface coverage;
• printing;
• additives;
• chemical compliance;
• separability;
• collection routes;
• take-back evidence.

A general packaging specification stating “plastic bottle” or “cardboard carton” will not always support a defensible rating.

Importers and brand owners may need this information from packaging manufacturers, contract fillers and non-UK suppliers. The legal reporting responsibility remains with the obligated producer even where the technical information sits elsewhere in the supply chain.

Supplier certificates do not replace the assessment

A supplier may provide a certificate declaring that packaging is recyclable or compliant with a private design guideline.

That information can support the assessment, but it does not automatically establish the RAM result.

The producer must classify the packaging under the UK material categories, apply the methodology for the relevant reporting year and retain evidence supporting the rating.

A supplier assessment prepared for another country may use different collection coverage, sorting infrastructure, recycling technology or end-market assumptions. It may therefore reach a different conclusion from the UK RAM.

This is particularly important for international packaging portfolios. A design that is considered widely recyclable in Germany, France or another market may not receive the same result in the United Kingdom.

Red does not necessarily mean the packaging is prohibited

A red RAM rating does not automatically mean that packaging cannot be sold in the UK.

In most cases, it means that the packaging is considered difficult to recycle at scale under the current methodology and will attract a higher EPR disposal fee.

Separate legal restrictions can still apply to certain materials, chemicals and single-use formats. Some of these restrictions are reflected in the automatic-red criteria, but RAM is primarily a reporting and fee-modulation mechanism rather than a general market-access approval.

Businesses should therefore distinguish between:

• packaging that is lawful but rated red;
• packaging that is red because of another regulatory restriction;
• packaging that is non-compliant and cannot lawfully be supplied;
• packaging that could achieve a better rating following a design change.

This distinction matters when deciding whether the appropriate response is redesign, alternative evidence, corrected reporting or withdrawal from the market.

Packaging redesign can have delayed financial effects

A producer’s disposal fee is calculated using packaging data from an earlier reporting period.

A design improvement introduced during 2026 will therefore not normally change the fee associated with packaging supplied in 2025. Its financial benefit appears when the improved design is reflected in the relevant future data and fee cycle.

The applicable RAM version also changes annually.

A redesign should consequently be assessed against:

• the methodology that applies when the new packaging will be supplied;
• the expected collection and recycling infrastructure for that year;
• the material rate and modulation framework;
• manufacturing and product-protection requirements;
• other packaging taxes and legal obligations.

Replacing one red-rated material with another material is not necessarily beneficial if the alternative carries a higher base fee or creates other environmental disadvantages.

PackUK’s modulation policy is designed partly to reduce incentives for producers to switch between materials solely to obtain a more favourable EPR result.

RAM is becoming a commercial packaging metric

The UK EPR system turns recyclability from a general design objective into a reportable and financially relevant packaging attribute.

A packaging format can receive a red rating even where it is technically recyclable or carries an on-pack recycling instruction. The result depends on whether the package can pass through collection, sorting, reprocessing and end-use stages using the UK’s existing operational infrastructure.

Design details that previously appeared minor can now influence the producer’s disposal fees.

For affected businesses, RAM should therefore be integrated into packaging procurement, product development and supplier management rather than treated only as an annual environmental-reporting exercise.

The immediate priority is to review the accuracy of the 2025 data that will determine the first modulated fees. At the same time, companies need to apply RAM version 1.1 to their 2026 packaging and prepare for the updated RAM 2027 criteria.

Viron Compliance supports manufacturers, importers and online sellers with UK packaging EPR assessments, registration, data reporting and the coordination of RAM classifications across complex packaging portfolios.