All about Recyclability Assessment Methodology (RAM)

In anticipation of the October 2025 submission, DEFRA have been actively addressing issues and updating the RAM, which includes a new fee modulation system and the final version 1.1 RAM Publication. Before detailing the new updates to the RAM, it is important to understand the fundamental components. 

Who is obligated?

Although the UK EPR packaging regulations have extended to small producers, the RAM currently only applies to large producers. Large producers are producers with an annual turnover that exceeds £2 million and handle 50 tonnes or more of packaging per year. Regarding packaging, the RAM only applies to household packaging, which means any primary or shipment packaging that is likely to be disposed of in household or public bins. While this applies to most household packaging, there are some exemptions such as drinks containers made from PET, aluminium or steel, any other drinks containers that form part of a UK DRS, reusable packaging and exported packaging.

What is the RAM?

The RAM is an assessment tool that uses a variety of factors to categorise materials into a traffic light system. The RAM traffic light system categorises packaging into Red, Amber or Green based on its recyclability. Green packaging is widely recyclable, Amber is packaging that is recyclable but needs specialist infrastructure, or the reprocessing may impact quality or efficiency, and the Red category is packaging that is difficult to recycle at scale. The important question is now to understand how the categories are determined.

The RAM is detailed in crucial steps:

1. Classifying: Process of defining whole packaging units and their components against RAM under specified categories such as Paper or Board. If components are easily separated by consumers, i.e. removable lids, then you must assess them separately.
2. Collection: Once classified, it must be determined which of the three kinds of collection, based on % coverage of collection by local authorities, the packaging will fall into: Kerbside (75%), Limited collection (50%) or a Take-back scheme.
3. Sorting: The assessment looks at whether the packaging unit or component can be efficiently sorted at scale across a range of criteria.
4. Reprocessing: Assess whether the packaging can be reprocessed easily and without significant impacts
5. Application: This refers to factors which may affect the quality of recyclate produced or cause unnecessary secondary material loss in the recycling process.

Within the process of assessing packaging and materials, there are certain cases where a specific type of material or situation will classify that packaging as Red or Amber. For example, packaging that contains PFAS will be automatically classified as Red (except for that made of aluminium, steel or glass). Additionally, under the newest 1.1 RAM version, any household packaging within the scope of the RAM requirement which has not been assessed or where the details required to undertake an assessment are not available is now considered automatically Red. With considerations for affected producers, DEFRA has altered some of these conditions and published additional details in all the initial classifying categories, such as Paper and Board, Plastics, Glass, etc. An example of a few of the crucial amendments includes, but is not limited to:

• Paper and Card and FBC (carton and non-cartons): packaging with food and other residue will no longer be classified as automatically Red
• PAE, UV-cured varnish and inks with mineral oils are no longer classified as Amber.
• Rigid and flexible plastics as well as glass: requirements for label coverage, additives, and seals have changed. 

This process of assessment and classification will then determine the category of packaging in the traffic light system, which will then determine the EPR fees that correspond with that category. 

Fee modulation

In 2026, producers must pay the EPR base fees determined by the RAM assessments. On the 1st of April 2025, DEFRA held an online seminar that detailed the new structure of the fee modulation system. The RAM fee modulation is now based on a timeline structure where the Red category of materials will be charged a premium of the base fees (that will increase each year), the Amber categories will be charged the EPR base fee, and the Green categories will be charged a discounted fee. The increase in the Red category fees will cause a greater discount for the Green category fee. Under the new changes, the RAM Fee timeline could be as follows:

• 2026: Red fees will be 1.2x the Base Fee
• 2027: Red fees will be 1.6x the Base Fee
• 2028: Red fees will be 2.0x the Base Fee

As of April 2025, DEFRA have announced that the next version of base fees will be published by the end of June 2025, that producers will need to pay in 2026. In preparation for the first RAM submission in October 2025, producers are advised to seek additional guidance on how the RAM will impact their businesses and UK EPR compliance.

The rapid rate at which EPR regulations are evolving can be frustrating for businesses that seek to make sense of how they might be affected by a potential law. Ecoveritas has and will continue to keep track of and interpret EPR regulations, along with other environmental laws impacting packaging, textiles, electricals, batteries, and wider sectors. Our exclusive Global EPR Matrix offers a unique insight into EPR laws that should educate you about your business’s obligations.

Get in touch with us today to learn more about our RAM and other services. Please speak to one of our advisors today on +44(0)1865502176 or email us at info@ecoveritas.com.