Packaging Sustainability Specialist at Ecosurety Alison Appleby explores how the new recyclability assessment is shaking up the packaging industry and why producers should prepare now.
With the final version of the packaging Recyclability Assessment Methodology (RAM) released by government in the last week of 2024, businesses are now starting to wrap their heads around the additional work required to use the RAM and the impact it will have on them.
What is the RAM?
The Recyclability Assessment Methodology (RAM) is the mechanism through which large producers (those companies with a turnover greater than £2 million and that supply or import more than 50 tonnes of packaging in the UK) will need to assess the recyclability of their household and shipment packaging and report it to government, under the packaging Extended Producer Responsibility (EPR) regulations.
As businesses assess their packaging components using the RAM, each item will receive one of three ratings:
- Red – Difficult to recycle at scale.
- Amber – May experience challenges in the collection and recycling process.
- Green – Widely recyclable in the UK.
They will then need to report the tonnage of their household commonly street binned and shipment packaging into the relevant categories of “red”, “amber” and “green” from the October 2025 EPR data submission.
This information will be important, not only to understand the general recyclability of packaging placed on the market in the UK, but also to inform eco-modulation of Waste Management Fees (WMFs) payable by producers.
WMFs are being introduced to cover local authority packaging waste management costs and are a new cost for producers.
Base fees will be required in 2025, with eco-modulation based on the results of the RAM expected from 2026.
At this stage, government has not yet released information on what eco-modulation will look like. It is understood that packaging classed as “red” by the RAM will likely incur higher WMFs than those with an “amber”, and those with a “green” result.
However, we do not yet know to what extent “red” packaging will be more expensive than “green” packaging, and at this stage we only have a third release of illustrative base fees for 2025 to 2026, which are still subject to change before the final base fees are released sometime after April 2025.
What we do know is that the fees will be modulated within material types, as broken down by the material classifications of the RAM. These are:
- Paper and board;
- Fibre-based composite materials;
- Plastic (flexibles);
- Plastic (rigids);
- Steel;
- Aluminium;
- Glass;
- Wood;
- Other materials.
Challenges for industry
To successfully complete a RAM assessment, businesses will need a much greater level of detail on their packaging. This includes detail on packaging adhesives, label sizes, ink types, and additives – to name just a few.
When looking at the full RAM, there are almost 700 unique data points and features within its 6,500 words. This will be no small task for businesses and should be taken seriously.
One of the biggest challenges for industry will be the collection of this additional detail from suppliers and packaging manufacturers.
This will be a time-consuming task for most, and likely require a lot of back-and-forth enquiries trying to capture all the details required to complete a RAM assessment successfully.
This is because several of the features that will need to be considered as part of the RAM cannot be determined by simply looking at a physical packaging format – it’s about the material make-up of the packaging, which includes lots of new information not previously required for reporting purposes in the UK.
It was also announced in late February 2025 that an updated version of the RAM would be published around April 2025.
Given this news, many businesses are pressing pause on their assessment of packaging using the RAM due to uncertainty and the amount of work that will go into completing an assessment which may have to be completed again.
Expected industry response
One of the key objectives of the RAM is to incentivise the use of more recyclable packaging.
Since its publication, there has been significant talk within the industry around how to reduce the amount of packaging classified as “red” – packaging that is not recyclable.
Over the next few years, we predict several packaging format changes away from “red” non-recyclable packaging components to “green” readily recyclable packaging components as businesses attempt to reduce their costs as much as possible.
This will support the transition towards a circular economy for packaging as businesses move to more recyclable packaging.
We also anticipate movement away from the use of substances of very high concern under the UK Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and packaging containing intentionally added per- and polyfluoroalkyl substances (PFAS) as these result in an instant “red” outcome.
This will be beneficial for human and environmental health, and while not directly impacting recyclability functionally, it’s a good opportunity to phase-out these substances in line with bans occurring globally for these materials.
This also aligns with similar phase-outs and bans occurring throughout Europe.
Where to from here?
We are yet to know the full effects of the RAM. Businesses could have a knee-jerk reaction and change packaging that will have higher WMFs, but this could lead to unintended consequences in the long term. For example, in the case of flexible plastic packaging, which is not currently collected at kerbside.
This will be collected in England from 2027 once Simpler Recycling is in play and could receive an “upgrade” in terms of its RAM outcome in two years’ time.
Will we see businesses jump to alternatives in the interim, or will they foot the bill for it being “red” or “amber” in the short term?
Other businesses may wait until after the update to the RAM is made around April 2025. While waiting for certainty, this will give those businesses even less time to assess their packaging before the October submission.
At Ecosurety, we’re supporting businesses through this change. Implementing this new assessment for EPR is certainly complex, and we know this is causing concern about the task ahead.
In general, we know that detail will be required on inks, adhesives, laminations etc., so businesses should start to capture what they can now.
