What is the RAM, and why does it matter?
by Ana Pilcher May at 12:56 in Circular Economy, Content, Packaging, Environmental, Emerging
If you're a large packaging producer in the UK, you've probably heard about the new Extended Producer Responsibility (EPR) rules. From 1 January 2025, all household packaging must be assessed using something called the RAM.
RAM stands for Recyclability Assessment Methodology. It's a system created by Defra for large producers to measure how recyclable their packaging really is within the UK infrastructure.
Packaging is assessed in these material categories:
Rigid plastic
Flexible plastic
Paper and board
Fibre-based composite liquid cartons
Fibre-based composite non-liquid cartons
Aluminium
Steel
Glass
Wood
Other materials
Who Has to Do This?
If you're classed as a large producer under the new Packaging EPR rules, you must assess and report the recyclability (RAM rating) of your household packaging.
Your first RAM assessments must be submitted with your Half-Year 1 2025 EPR data by 1 October 2025.
Unsure if you are a large producer? Not sure how to report your packaging? Read our blog demystifying UK Packaging EPR to find out more.
Timeline
The first version of the RAM was published by Defra at the end of December 2024, but due to industry backlash over the tight timelines and complexity of the assessment, a slightly simplified RAM v1.1 was published at the end of April this year.
Why RAM ratings matter
RAM is tied to something called eco-modulation. This means your EPR fees will change based on how recyclable your packaging is assessed to be.
🟥Red packaging = higher fees
🟨 Amber = base fees
🟩 Green = discounted fees
Although not confirmed yet, Defra has released a draft eco-modulation methodology which would mean in 2026 Red rated packaging would get 20% higher fees than the base fee for that material. See the table below for the proposed eco-modulation factors for the next three years.
Year | Red | Amber | Green |
2026 | Base fee + 20% | Base fee | Calculated based on Red fee excess |
2027 | Base fee + 60% | Base fee | Calculated based on Red fee excess |
2028 | Base fee + 100% | Base fee | Calculated based on Red fee excess |
How the RAM assessment works: The 5 factors of recyclability
The RAM is spilt into five sections which check for the presence of various features, materials and contaminants that affect that factor of recyclability.
Classification
Information to help determine whether the packaging item falls within the material category being assessed.
Collection
Assesses how widely the packaging format is collected at kerbside by local authorities.
If collected by over 75% of local authorities, the component is rated Green at this stage.
If collected by 50–75%, it receives an Amber rating at this stage.
If less than 50%, it is rated Red, unless it qualifies under an approved takeback scheme meeting strict criteria, in which case it may achieve Amber.
Sortation
Evaluates whether the packaging can be effectively identified and separated at material recovery facilities (MRFs), based on features such as size and colour.
Reprocessing
Considers any materials, features, or contaminants that could prevent the packaging component from being mechanically recycled at scale.
Application Looks at whether any features or contaminants could negatively affect the quality of the recyclate or cause secondary material loss.
How the RAM ratings work
One Red result at any point during the assessment results in an overall red rating
One Amber without a Red is an Amber rating.
If every single output is green across all 5 stages, the packaging can be assessed as green.
Missing the data required to evidence that the packaging is free of any of the recyclability-impacting features, results in a Red assessment.
For each material type, there are up to 23 criteria across the five stages. These criteria require data to show that the packaging does not include certain non-recyclable features. Materials like glass, aluminium, and steel has fewer criteria, as they face fewer limitations to recyclability within the UK's existing collection, sorting, and reprocessing infrastructure. The most difficult aspect of the RAM is having the data about your packaging to assess it. For example, there are 22 separate criteria for paper and board, each requiring data to show the absence of these for the packaging to achieve a green rating.
Packaging must also be free from so-called "Automatic Reds" to gain amber or green ratings. Automatic reds are critical features that lead to an automatic Red rating across all material types, regardless of format or design. These include:
Integrated electronic and electronic equipment (EEE)
Presence of Substances of Very High Concern (SVHC) under UK REACH
Inks banned under the EuPIA Exclusion Policy for Printing Inks and Related Products
Intentionally added PFAS (does not apply to packaging with predominant material of Aluminium, Steel or glass)
Summary
RAM stands for Recyclability Assessment Methodology
RAM is mandatory for household packaging placed on the market by large producers from 2025.
You must assess and report recyclability ratings alongside EPR data in October 2025.
RAM ratings affect your EPR fees invoiced in 2026.
Red = expensive. Green = savings.
RAM is complex, intricate and requires a lot of data about your packaging.
Incomplete data = Red rating
Resources
See the official RAM guidance on Gov.UK: https://www.gov.uk/guidance/recycling-assessment-methodology-how-to-assess-your-packaging-waste
Struggling with RAM assessments or UK Packaging EPR reporting? Contact us for expert support!
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