OPINION: The publication of the RAM 2027 statutory guidance marks another important milestone in the UK’s EPR reforms. The methodology is undoubtedly clearer, more structured and easier to navigate than previous versions. However, as attention shifts from implementation to outcomes, an important question remains: can RAM 2027 deliver the change that modulation is intended to achieve?
The principle behind modulation is straightforward. Packaging that is difficult to recycle should attract higher costs, while packaging that is recyclable should be rewarded, with the RAM providing the mechanism for making that distinction.
But has that principle been fully reflected in the assessment of fibre-based packaging products?
The UK has one of the most established paper and card recycling systems in the world, supported by a domestic paper industry that plays a critical role in manufacturing and the circular economy. The success of that system depends not only on high recycling rates, but on maximising fibre recovery and maintaining the quality of recovered fibre, so that it can be used again and again.
A packaging format may appear technically “recyclable” while still creating significant challenges for the standard recycling process. Non-paper components, whether obvious or less visible, such as laminates, coatings, metallisation, inks, varnishes and adhesives can reduce fibre recovery, increase reject volumes, add processing costs, consume more energy and affect the quality of recycled fibre. These impacts are well understood by paper recyclers and have informed packaging design guidance for many years.
This is particularly important for fibre-based composite (FBC) packaging. FBC formats are often presented as paper-based because fibre is the main visible material, but their recycling performance can be significantly affected by plastic layers, barrier coatings, aluminium, adhesives or other non-paper components. In practice, these materials can reduce fibre yield, increase reject rates and create operational challenges for standard paper mills. If the RAM treats FBC in the same way as simpler paper and card packaging, it risks rewarding formats that are recyclable in theory, but materially weaker, uneconomic and often rejected in real recycling conditions.
This raises an important question about whether the RAM methodology is fully aligned with the objectives of modulation.
The issue is not only whether FBC can enter a recycling stream, but whether it delivers comparable fibre recovery and quality outcomes once it reaches a standard paper mill. Where non-fibre layers are difficult to separate, the material may generate more rejects, contaminate recovered fibre or require additional processing. That creates a clear distinction between packaging that is collected as paper and card, and packaging that genuinely supports high-quality paper recycling. RAM2027 would be stronger if it reflected that distinction more explicitly.
There are wider implications too.
Although some fibre-based composite packaging formats may be more effectively recycled if directed to specialist facilities, the reality is that collection systems and limited specialist mill capacity mean many are likely to be directed to standard paper mills. In those settings, plastic, aluminium or barrier layers can reduce fibre recovery and increase reject material and therefore costs for disposal with the impact of the paper mill effectively paying twice – once for the material and again for disposal of items it cannot process. A methodology designed to deliver environmental improvements should therefore consider not only whether a material can be recycled in theory, but how it performs within the infrastructure most likely to receive it.
There is also a reputational dimension.
Paper and card packaging has earned its strong credentials because it is widely collected, widely recycled and supports circular material use. That reputation depends on maintaining high-quality recycling outcomes. If packaging with significantly different recycling performance is treated in the same way by the RAM, it becomes harder to distinguish between packaging that performs well in practice and packaging that is simply recyclable in principle.
RAM 2027 represents progress, but it also highlights the next challenge for EPR.
The question is no longer whether packaging can be recycled, but whether modulation is rewarding the packaging designs that deliver the greatest environmental benefit. If it is intended to encourage better design, stimulate innovation and improve circularity, it must be capable of distinguishing between packaging that supports high-quality fibre recovery and packaging that compromises it.
Ultimately, the success of EPR will not be judged by how much packaging is classified as recyclable, but by whether it changes behaviours. As it stands, EPR cannot fully reward better design, encourage innovation or maximise the value of materials recovered through recycling.
For fibre-based products, being recyclable should be the starting point, not the finish line. The real test is not whether fibre can be recovered, but whether EPR creates the incentives needed to maximise recovery and deliver the outcomes it was designed to achieve.
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