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PackUK tightens ‘automatic red’ criteria in RAM 2027 update

PackUK tightens ‘automatic red’ criteria in RAM 2027 update

PackUK has published the latest update to its Recyclability Assessment Methodology (RAM) for 2027.

The updated methodology, referred to as RAM 2027, follows what PackUK described as significant consultation with industry and builds on version 1.1 of the RAM, which was published in April 2025.

Assessment outcomes under the RAM determine whether packaging is classed as red, amber or green – ratings which directly influence modulated fees under Extended Producer Responsibility for packaging (pEPR).

PackUK said the latest version is intended to improve clarity, consistency and accessibility for producers carrying out assessments, while strengthening the link between recyclability ratings and how packaging is managed in practice across UK recycling systems.

PackUK clarified that RAM 2027 applies only to packaging placed on the market in 2027, and will not affect 2025 or 2026 reporting obligations. The first reporting window under the updated framework will close on 1 October 2027.

Changes to RAM

RAM 2027 includes a number of refinements to material rules, definitions and assessment guidance following engagement with producers, trade associations and technical specialists.

The updated methodology was developed with support from the RAM Technical Advisory Committee (TAC), alongside material specialists and data gathered from recycling facilities.

Among the most notable changes are updates to the “automatic red” criteria – packaging formats or materials that will automatically be deemed difficult or unsuitable for recycling.

These now include packaging containing more than one part per million (ppm) of total PFAS, with a tighter threshold of 25 parts per billion (ppb) for food packaging.

Packaging containing substances of concern above limits set under UK REACH legislation, including Annex XIV and XVII substances, substances of very high concern (SVHCs), persistent organic pollutants (POPs), Biocidal Products Regulation (BPR) substances and those classified under CLP, will also automatically receive a red rating.

Non-compliance with UK food contact materials legislation has also been added as an automatic red trigger, as have packaging formats that are already subject to UK regulatory restrictions or phase-outs.

PackUK said the changes are designed to reduce ambiguity in producer assessments and provide greater confidence in the methodology’s practical application.

The scheme administrator added that RAM 2027 better reflects “real-world recycling outcomes”, linking design decisions more closely to what can actually be collected, sorted and reprocessed at scale.

Robbie Staniforth, Chief Policy and Impact Officer of Ecosurety, commented on the update: “Releasing the revised methodology now gives time for us to recodify our members’ packaging, and to explain what these changes might mean for their costs, well ahead of reporting deadlines in October 2027.

“Most of the changes are clarifications and simplification, such as, explaining the evidence base for deciding whether an item of packaging is “commonly collected” or not.

“However, there are some tweaks that we are pleased to see, particularly around ensuring that technical recyclability factors align more closely with real-world practices.”

Modulated fees for pEPR

Under pEPR, producers must assess household packaging against the methodology, with green-rated packaging attracting lower fees because it is considered widely recyclable through existing UK infrastructure.

Amber-rated packaging may face challenges in collection, sorting or reprocessing, while red-rated packaging is considered the least recyclable and will incur the highest fees.

The methodology was first introduced as part of the wider pEPR reforms aimed at shifting the full net cost of household packaging waste management onto producers.

Since the final RAM was confirmed in late 2024, the methodology has become increasingly central to producer compliance, with the modulated fee model being implemented in the 2026 reporting year.

PackUK has previously said the RAM will be reviewed annually to reflect innovation, regulatory developments and changes in recycling infrastructure.

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