UK RAM 2027 Packaging Recyclability Guidance: What Large Producers Need to Know

Background: Packaging Recyclability Data Requirements

RAM stands for Recyclability Assessment Methodology. Under the UK's pEPR framework, it provides a consistent technical method and detailed guidance for determining packaging recyclability. Large producers subject to the scheme must assess household packaging and its components, retain supporting evidence and report the results.

Since 2024, PackUK has issued the applicable RAM version before each reporting year and has continued to revise the methodology through annual policy reviews, technical consultation and research into key materials.

As explained in the official RAM 2027 overview, the methodology goes beyond asking whether a material is technically recyclable. Packaging must not only be technically recyclable; it must also be collected, sorted, reprocessed and returned to a viable end use at scale. The focus therefore shifts from material properties alone to evidence across the full recycling chain.

Assessment Framework: Four Stages and Three Ratings

RAM 2027 covers the following material categories:

• paper and paperboard;

• fibre-based composite materials, including liquid and non-liquid cartons;

• flexible and rigid plastics;

• steel, aluminium and glass;

• wood; and

• other materials, such as cork, textiles, rubber, ceramics and natural fibres.

A producer should first check whether the packaging meets an automatic-red criterion. If it does not, the producer determines the material category for the packaging and its components and then assesses four stages:

The final assessment uses three ratings:

RAM ratings directly affect packaging waste disposal fees under the UK scheme. Red packaging attracts a fee above the base rate, amber is charged at the base rate, and green packaging may receive a discount. Companies should also strengthen material evidence, optimise packaging design and report on time; otherwise, packaging may be charged as red and create compliance risk.

Assessment Criteria and Typical Cases

Automatic-Red Screening

RAM 2027 introduces an automatic-red screening step. Packaging may be rated red without further recyclability assessment where specified conditions apply, including:

• packaging with integrated electrical components that would themselves be classed as electrical and electronic equipment, batteries or accumulators;

• substances of concern in packaging or components that exceed applicable limits under UK REACH, rules on substances of very high concern, persistent organic pollutants, biocides legislation or CLP;

• printing inks that were not manufactured in compliance with the EuPIA charter on raw-material selection and exclusion;

• more than 1 ppm of total PFAS in an item or component, or PFAS in food packaging exceeding 25 ppb for any individual PFAS or total PFAS, as stated in the RAM 2027 guidance;

• food-contact packaging that does not comply with applicable UK food-contact-material legislation, including relevant migration restrictions; and

• packaging formats subject to UK restrictions or phase-outs, including certain restricted single-use plastic formats.

Flexible Plastics

Flexible plastic packaging, including bags, films and snack packaging, should generally be rated red. It may be rated amber where a producer can meet the evidence requirements for a take-back scheme and demonstrate that the packaging is handled through collection, sortation, reprocessing and subsequent application.

Rigid Plastics

Rigid plastic packaging, such as bottles, jars, boxes and trays, can generally receive a green result at the collection stage where it is collected at the kerbside in at least 75% of UK local authority areas. Later-stage results still depend on the specific packaging design.

Other Materials

RAM 2027 also sets different assessment benchmarks for paper, fibre-based composite materials and other material categories.

Recommended Compliance Actions

1. Build packaging-material evidence files: Document the material composition, mass ratio, size, colour, coatings, inks, adhesives, barrier layers and separability of each packaging item and component. Where information is missing, request technical specifications and compliance declarations from packaging suppliers.

2. Prioritise automatic-red screening: Review PFAS, food-contact compliance, restricted substances and ink formulations first. For food packaging in particular, confirm the available PFAS test results or substance declarations and evidence of compliance with applicable UK food-contact-material requirements.

3. Improve sortability and reprocessability of rigid plastics: For PET, HDPE and PP packaging, review risk factors such as carbon black, non-releasing label adhesives, PVC or PVDC, EVOH, metallised labels, dark colours, direct printing and high-density attached components.

4. Assess market routes for flexible plastics and less common materials: For flexible plastics, wood, cork, textiles and rubber that are generally difficult to collect at the kerbside, confirm in advance that any take-back scheme relied on for an amber rating covers collection, sortation, reprocessing and recycled-material use, and retain the corresponding evidence.

Overall, RAM 2027 more closely links packaging recyclability ratings with the UK's existing collection, sortation and reprocessing capacity and the practical use of recycled materials. Companies should integrate RAM considerations into product development and packaging design, as well as material procurement, supplier management, compliance review and packaging EPR data reporting. Preparing technical evidence and identifying high-risk designs early can reduce the risk of a red rating, future disposal fees and later packaging-adjustment costs.

Recommended Reading

• UK REACH Service

• UK Proposes Amendments to POPs Regulation: Five Chemicals Restricted, PFOS Limits Tightened

• UK REACH: HSE Proposes Critical Management Measures to Control PFAS Use

Official Resources

• PackUK and Defra: RAM 2027 Materials Assessment Guidance

• PackUK and Defra: RAM 2027 Overview

• GOV.UK: Assess Packaging Recyclability — RAM 2027