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PackUK releases updated assessment methodology for pEPR

PackUK has released the second version of the recycling assessment methodology (RAM) for extended producer responsibility for packaging (pEPR).  

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The RAM assesses the recyclability of household packaging via a red, amber or green system.  

The recyclability of the packaging will inform the modulation of disposal fees from 2026 onwards, based on the household packaging supplied to the UK market in the previous calendar year. 

The updates are based on a RAM “simplification sprint” carried out by the pEPR scheme administrator in February this year to reduce its complexity and increase the viability of producers being able to fully complete their assessments in 2025. 

The sprint involved gathering feedback from stakeholders on the first iteration of the RAM and offering up simplifications, which have now been included in the updated assessment criteria.  

The previous version of the RAM was released in December 2024 and was thought to be the final iteration.  

Robbie Staniforth, member of the steering group of PackUK and director of innovation and policy at Ecosurety, said: “It is pleasing to see the methodology has finally been released after years of discussion about recyclability.  

“The team at PackUK have been working at some pace to complete and publish this work after years of delays by previous governments.  

“Those delays earlier in the process will mean packaging producers have a tough task ahead to rate each of their household items by this October.”  

The latest update (RAM 1.1) simplifies the first version and removes a number of the previous requirements for the assessment of different packaging materials.  

Paper and cardboard 

RAM 1.1 has removed the requirement that packaging be classified as red if it contains any retained product residue that cannot be removed by hand.  

This would include items such as 3D food baked on and attached to the paper or board. 

The requirement for the packaging to be classified as amber if it contains any of the following has also been removed:  

  • Polyamid epichlorohydrin (PAE)  
  • Ultra Violet (UV) cured varnish greater than 4g/m2 with 100% coverage 
  • Inks containing mineral oils 

Fibre-based composite materials (liquid and non-liquid cartons) 

For the reprocessing of fibre-based composite materials, the update has also removed the need to class packaging as red if it is likely to retain product residue that a consumer cannot remove by hand.  

Plastic packaging
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This includes both liquid and non-liquid cartons.  

These also no longer need to be classified as amber if they contain PAE.  

Flexible plastics 

For sortation, flexible plastics are no longer automatically classed as red if they contain carbon black pigment in inks and labels covering more than 50% of the total surface area. 

Rigid plastics (sorting) 

When it comes to the sortation of rigid plastics, they also no longer need to be classed as red if they have an attached label or sleeve of a different material or polymer type covering more than the following:  

  • For bottles, an attached label or sleeve exceeding 40% of the total surface area 
  • For pots, tubs, and trays, an attached label or sleeve exceeding 60% of the total surface 

The requirement to class rigid plastics as red if the carbon black pigment in inks and labels covers more than 50% of the total surface area has also been removed. 

Rigid plastics (reprocessing) 

For the reprocessing of rigid plastics, the requirement to assess attached label adhesives which are not removable in an 80°C hot wash has been removed.  

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Polyethylene terephthalate (PET) bottles ware no longer classified as red if they contain nanocomposite additives.  

PET tray items do not have to be classified as red if they contain PE seal layers.  

The requirement to classify high-density polyethylene (HDPE) items as red if they contain additives that increase the density of HDPE above 0.995 g/cm3 has been removed.  

This would have included Talc, CaCO3 and other fillers contained in the plastic itself and did not apply to any inks used.  

Rigid plastics (application) 

Attached labels or sleeves comprised of paper would originally cause the rigid plastic to be classed as amber.  

While they are technically capable of being recycled, they make the reprocessing more complicated, can reduce the quality of recyclate produced or cause unnecessary secondary material loss. 

PET bottles are no longer classified as amber if they contain heavy colours. 

Polypropylene (PP) items do not need to be classified as amber if they contain:  

  • Heavy colours 
  • Clarifier additives 
  • Attached labels or sleeves comprised of paper 
  • Inserts comprised of PET (light) 

Glass  

For the application of glass, attached labels covering more than 60% of the total surface area will no longer cause the packaging to be marked as amber.  

Like in the case of rigid plastics, while they are technically capable being recycled, they may make the packaging more complex to reprocess, can reduce the quality of recyclate produced or cause unnecessary secondary material loss. 

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