RAM 2027: The Updated UK Recyclability Assessment Methodology for pEPR Fee Modulation

On 1 July 2026, PackUK – the scheme administrator for the UK’s packaging Extended Producer Responsibility (pEPR) regime – published RAM 2027. This is the updated Recyclability Assessment Methodology that large producers must use to assess the recyclability of household packaging placed on the UK market during 2027.

The methodology assigns every item of packaging a red, amber or green (RAG) rating, and those ratings directly determine the modulated waste disposal fees producers have to pay under pEPR. For any business supplying household packaging into the UK, RAM 2027 is the framework that will shape both compliance obligations and cost exposure in the next reporting year.

 

How RAM Fits Into UK pEPR

Under the UK’s packaging EPR scheme, large producers are legally required to assess the recyclability of the household packaging they supply and report the results to the environmental regulators. The methodology is straightforward: less recyclable packaging is more expensive. Red-rated materials attract the highest disposal fees, amber-rated materials incur moderate fees and green-rated materials (those that move cleanly through the UK’s established recycling system) carry the lowest. This mechanism, known as fee modulation, was implemented in the 2026 reporting year and is now a central feature of producer compliance.

RAM 2027 builds on version 1.1, published in April 2025, and is the first update under a new annual review cycle set out in the RAM Roadmap. A critical point for producers is the distinction between the two versions: RAM 2027 applies only to packaging supplied in 2027 and does not affect 2025 or 2026 reporting. Producers must continue to use RAM version 1.1 to assess recyclability for the 2026 reporting year, while familiarizing themselves with RAM 2027 ahead of the next cycle.

 

The Four Stages of Assessment

RAM 2027 assesses packaging across eight material categories: paper or board, fiber-based composites, plastic (flexibles and rigids), steel, aluminum, glass, wood and other materials. Each item or component is evaluated at four sequential stages of the recycling process:

1. Collection: whether the packaging is captured through the UK’s operational recycling system, typically curbside collection by local authorities.
2. Sortation: whether it can be effectively separated at a materials recovery facility, with a general size threshold of at least 40mm in two dimensions.
3. Reprocessing: whether it can be turned into usable recyclate without contamination from problematic components.
4. Application: whether the recovered material can re-enter the supply chain in a meaningful way.

The logic is cumulative rather than averaged. An item must be rated green at every stage to receive a final green rating; it must be green or amber at every stage for a final amber rating. However, if it is rated red at any single stage, the item is rated red and no further assessment is needed. This “weakest link” approach means that a single problematic component (e.g. an incompatible label adhesive, a barrier coating, an undersized closure) can pull an otherwise recyclable item into the red category.

 

The Expanded “Automatic Red” Criteria

One of the most significant changes in RAM 2027 is the tightening of the automatic red criteria. This refers to packaging that is deemed non-recyclable within pEPR regardless of its technical recyclability, because using it would create legal, chemical or system-level barriers to safe recycling. Under the updated methodology, packaging is automatically rated red if it contains:

• Integrated electrical components or batteries (e.g. boxes with LED lights)
• More than 1 ppm of total PFAS (individual or sum), with a tighter threshold of 25 ppb for PFAS in food packaging.
• Substances of concern exceeding limits under UK REACH, including SVHCs, persistent organic pollutants, biocides and CLP-classified substances.
• Printing inks not compliant with the European Printing Ink Association charter.

It also receives a red rating when it comes to:

• Food contact packaging that does not comply with applicable UK food contact materials legislation.
• Packaging formats already subject to UK regulatory restrictions or phase-outs, even where technically recyclable.

 

Classification: Components Versus Whole Items

Before assessing recyclability, producers must classify their packaging correctly, because the classification directly affects the outcome. RAM 2027 distinguishes between components assessed separately and whole packaging items formed of integrated components.

A component is assessed separately if it is distinct from the main body and must be removed to use the product without being reassembled, a tear-off strip or a wine cork, for example. In contrast, integrated components that cannot be separated, are not intended to be removed or are smaller than 40mm but can be reattached (such as a bottle cap) are assessed as part of the whole item, using the predominant material by weight.

Under this distinction, a plastic label that would be rated red as a separate flexible component can be rated green when assessed as an integrated part of a glass jar, because the assessment takes the predominant material (the glass) as the basis. Understanding classification is therefore essential to producing an accurate and cost-optimal assessment.

 

What This Means for Producers Supplying the UK

For producers, RAM 2027 reinforces a direction of travel that has been clear since fee modulation began: packaging design decisions now carry direct financial weight. The materials most affected are the difficult-to-recycle formats: flexible plastics, which cannot currently be rated green at all and default to red unless a compliant take-back scheme is evidenced, multilayer composites and any packaging carrying barrier coatings, incompatible adhesives or problematic colorants such as carbon black that defeats near-infrared sorting.

Producers must retain evidence supporting each RAG rating for seven years and provide it to regulators on request. Assessments must be updated when packaging design or composition changes, or when the methodology itself changes in a way that affects the outcome. Given the annual update cycle, tracking which version applies to which reporting year is now a continuous compliance task rather than a one-off exercise.

 

Conclusion

RAM 2027 does not overhaul the UK’s approach to recyclability assessment, it rather sharpens it. The refinements to material rules and definitions are intended to reduce ambiguity and align ratings more closely with how packaging actually performs in the UK recycling infrastructure. For businesses supplying household packaging into the UK, the next steps are clear: understand which RAM version applies, classify packaging correctly and remove any features that trigger red ratings before the 2027 reporting year begins.