What RAM 2027 means for packaging producers and pEPR fees

 

Packaging recycling

PackUK has published the next version of its Recyclability Assessment Methodology, known as RAM 2027, setting out how large packaging producers will assess the recyclability of household packaging supplied during 2027.

The methodology is a key part of packaging extended producer responsibility, or pEPR. It determines whether packaging is rated red, amber or green, with those ratings used to adjust the household waste disposal fees paid by obligated producers.

RAM 2027 applies to packaging placed on the market between 1 January and 31 December 2027. It does not replace the existing RAM version 1.1 for 2026 packaging data, which producers must continue to use for the current reporting year.

What is the purpose of RAM?

The methodology is intended to move the conversation beyond whether packaging is theoretically recyclable.

Instead, it asks whether a package can be recycled at scale through the UK’s existing operational systems. That means considering whether it is collected, sorted, reprocessed into usable material and ultimately has an established end use that reduces reliance on virgin resources.

The assessment therefore looks at four stages: collection, sortation, reprocessing and application. To achieve a green rating, packaging must be assessed as green at every stage. A package can receive an amber rating where it is assessed as green or amber throughout, while a red rating applies where it fails at any stage or where the producer cannot provide evidence to support a higher rating.

That distinction matters. Packaging may be accepted by some local authorities, for example, but still face barriers further down the chain because it is difficult to separate in a materials recycling facility, contains problematic additives or cannot produce recyclate with a reliable end market.

Who needs to use it?

RAM 2027 applies to large producers that are obligated to pay household packaging waste disposal fees under pEPR.

A large organisation is generally one with annual turnover of at least £2 million that supplies or imports more than 50 tonnes of packaging in the UK each year. Obligations depend on the packaging activities a business carries out, including supplying packaged goods under its own brand, filling packaging, importing packaged products, operating an online marketplace or supplying empty packaging.

The methodology covers household packaging, including household glass drinks containers, as well as packaging that commonly ends up in public bins. Reusable and refillable household packaging only needs to be assessed the first time it is supplied.

What has changed?

RAM 2027 does not replace the underlying red, amber and green system. However, PackUK says the updated methodology responds to feedback from producers, trade associations and technical specialists, with changes designed to improve clarity, consistency and usability.

One important structural change is that classification now sits before the four recyclability stages. Producers must decide whether a package should be assessed as a whole item made up of integrated components, or whether elements such as sleeves, caps, labels and inserts should be assessed separately.

Where components are integrated and cannot reasonably be separated by the consumer, the package may be assessed according to its predominant material by weight. This can be significant for items such as bottles with attached labels or caps, where the component’s separate rating might otherwise be lower.

The methodology also includes automatic red ratings for some packaging, including packs containing integrated electrical components or certain substances of concern. Packaging containing PFAS above the specified limits, formats subject to UK restrictions or phase-outs, and food-contact packaging that does not meet relevant requirements may also be automatically rated red.

How will collection affect ratings?

The collection stage remains a major test.

Packaging collected at kerbside by at least 75% of UK local authorities can be rated green at collection stage. Packaging collected by between 50% and 75% of authorities is classed as having limited collection and can proceed through later stages with an amber cap.

Packaging that is not on either list must generally be rated red unless the producer can meet the evidence requirements for a qualifying take-back scheme.

That means collection alone is not enough to secure a green rating. A pack still needs to pass the sortation, reprocessing and application stages, including demonstrating that sufficient operational capacity exists to deal with the volumes being placed on the market.

What does this mean for pEPR fees?

The rating matters because pEPR disposal fees are being modulated according to recyclability.

Amber packaging is treated as the baseline. Red-rated packaging attracts a higher household packaging waste disposal fee, while green-rated packaging receives a discount funded by the additional payments collected from red-rated material. The modulation does not increase the overall pot of disposal fees paid by producers; it changes how those costs are allocated between materials and formats.

Under PackUK’s current modulation policy, the red multiplier rises over the initial three assessment years: 1.2 for 2026/27, 1.6 for 2027/28 and 2.0 for 2028/29. The green discount is not fixed in advance because it depends on the proportion of red, amber and green packaging reported across the system.

It is also important that modulation applies to the household packaging waste disposal element of the fee, rather than automatically doubling a producer’s total pEPR bill.

For context, PackUK’s Year 2 illustrative fees showed a red rating carrying a 20% uplift on the amber fee, while the illustrative green discount was around 9%. Those figures were not final and were dependent on producer data, but they show the financial direction of travel.

What should producers do now?

The publication gives businesses time to review packaging supplied in 2027 before the methodology takes effect.

That should include checking packaging specifications with suppliers, identifying component materials and weights, reviewing labels, inks, adhesives, barriers and inserts, and ensuring technical evidence is available for each assessment. A producer that cannot demonstrate an amber or green outcome must report the packaging as red.

Producers will report RAM assessments alongside their other packaging data through the Report Packaging Data service. The deadlines are 1 October for packaging supplied from January to June in the same year, and 1 April for packaging supplied from July to December in the previous year. For RAM 2027, this means reporting in October 2027 and April 2028.

RAM ratings are not consumer-facing recyclability labels. A pack may carry recycling information for households while receiving a different RAM rating for pEPR purposes, because the methodology assesses how the material performs through the full recycling system at scale.

For packaging producers, the practical message is clear: recyclability will increasingly be judged not simply by whether a material can be recycled somewhere, but by whether it can be collected, sorted, reprocessed and used again through established UK infrastructure.

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