Different kinds of packaging will receive different ratings – red, amber or green. This rating affects the disposal fee that will be charged for that packaging – a process which is known as “fee modulation”.
All packaging reported as “household waste” that is placed on the market by liable producers in 2025 will need to be assessed via the methodology, in order to modulate fees from 2026 onwards.
Green implies the packaging is both recyclable and there is adequate collection and recycling infrastructure in the UK and will therefore attract a lower fee than amber or red types.
Red packaging has specifications that make it difficult to recycle at scale, while amber packaging may experience challenges during collection and sortation, requires specialist infrastructure for reprocessing, the efficiency and output quality of reprocessing is affected or there is some secondary material loss
Released last week (23 December 2024), this is the final version of the RAM. It was confirmed a few days after the release of the third round of pEPR base fees for producers. The final fees will be confirmed in July 2025.
Head of advisory services at Ecourety, Jess Barton, said: “The release of the RAM is a critical step towards ecomodulation of waste management fees that reflect the recyclability of packaging. Producers will now need to work hard in 2025 to truly understand their packaging in order to apply the RAM and pay the correct fees.”
The RAM will be reviewed and updated where appropriate once a year by a Technical Advisory Committee (TAC), in line with reporting periods for EPR for packaging. Defra said that this process is to allow for innovation, evolving market conditions and regulatory changes.
Steve Gough, CEO at Valpak described the announcement as a key component in the move towards implementation of pEPR: “This announcement gives packaging producers the clarity needed to plan ahead. Armed with a comprehensive definition of green and red – recyclable and non-recyclable – materials, producers are now able to focus on collating the necessary data to meet their obligation.
“Those preparing for pEPR face two major challenges – sourcing and recording data, followed by analysis of packaging materials with a view to reducing non-recyclable packaging. For large businesses, collecting and submitting data is a vast task, so Valpak’s advice for those beginning the journey is to focus initial efforts on the areas offering the greatest reward.”
Full information on the RAM can be found here.
‘Helping businesses make effective choices around design’
OPRL has embraced the publication of the RAM. Its interim managing director, Jude Allan, described it as valuable clarification both for businesses and for labelling.
Allan said: “The arrival of eco-modulation in 2026 will introduce a financial incentive to reduce packaging or to opt for easily recyclable materials. The RAM provides a standard guide on the recyclability of different packaging materials and formats. The methodology will produce a red, amber or green output, which relates to the ease of recycling at scale. This will help businesses to make effective choices around design, as well as supporting consistent messaging to householders across the UK.
“Clear messaging will be crucial for the success of pEPR – without consumer engagement, lower volumes of waste will be collected, leading to higher costs for producers. To date, OPRL’s labelling metrics have been the only independently assessed system available. Now that the RAM has been published, we will update our Recyclability Assessment Tool to ensure that we fully align with the RAM. Our members will then have access to a truly UK-wide system.”
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