The Recyclability Assessment Methodology

Instrument and regulatory function

The Recyclability Assessment Methodology (RAM) is the technical method used in United Kingdom packaging extended producer responsibility to classify the recyclability of obligated household packaging. Its legal significance comes from SI 2024/1332: duties to assess and report packaging, and the scheme administrator’s use of packaging-sustainability information in calculating disposal fees. PackUK publishes the methodology, the material rules, the decision tree and supplementary interpretations.

The RAM is an economic and reporting instrument, not a communication instrument. It asks whether packaging is collected, whether it can be sorted at scale, whether it can be reprocessed using established infrastructure, and whether it yields usable secondary material without unacceptable losses or contaminants. Its outputs affect fees. They do not, by themselves, require a consumer-facing label.

Scope of the assessment duty

Only producers classified as large organisations are required to collect and report RAM data. The obligation concerns household packaging, packaging that commonly ends up in public bins, and glass household drinks containers. Non-household packaging falls outside the RAM reporting duty, although other extended producer responsibility obligations may still apply to it. Reused packaging, exports and specified deposit-return drinks containers are subject to exclusions described in the guidance. PET plastic, steel and aluminium household drinks containers are excluded from the RAM because they are intended to fall within the deposit-return scheme; glass drinks containers remain within the RAM unless and until the treatment of those containers changes under an operating deposit scheme.

The identity of the regulated producer follows the supply activity. Brand owners commonly assess filled branded packaging; importers assess imported packaging for which they are responsible; distributors may need to assess unfilled packaging when they supply it; and online marketplace operators are not exempt merely because third-party sellers use their platform. Where the producer does not hold the necessary design information — composition, coating, adhesive, label coverage or other relevant detail — it is required to obtain adequate information from suppliers. Packaging that cannot be evidenced or assessed can receive an automatic red rating.

Classification of units and components

Each packaging unit or component is assigned to a specified material category. The categories identified in the draft material underlying this page are paper and board, fibre-based composites, plastic, steel, aluminium, glass, wood and other; the supplementary guidance consulted for this page enumerates paper and board, plastic (flexibles), plastic (rigids), glass, fibre-based composites and other, and the eight-category list has not been individually confirmed against the RAM 1.1 text. Plastic is analysed through separate rigid and flexible criteria in either presentation.

Components that are easily separable by hand are generally assessed separately. Components that remain attached through collection and sorting, or that require tools or mechanical separation, are assessed together under the predominant material by weight, with the resulting output applied to the material reporting required by the Regulations.

The red, amber and green scale describes operational recyclability. Green indicates packaging that is widely recyclable in current United Kingdom infrastructure. Amber captures packaging that encounters collection or sorting limitations, depends on specialist reprocessing, reduces reprocessing efficiency or output quality, or causes secondary-material loss. Red captures packaging that is difficult to recycle at scale or that fails a decisive stage. Certain intentionally added substances, incompatible features and missing evidence can produce an automatic red result. Medical packaging is treated through corresponding medical codes — the supplementary guidance refers to red-medical, amber-medical and green-medical outputs — with a specific treatment where a red design is unavoidable because another regulatory requirement precludes a more recyclable alternative; that specific treatment has not been confirmed against the RAM 1.1 text.

Assessment is design-specific. Labels, sleeves, adhesives, barriers, pigments, closures, residues, dimensions and the manner in which components separate can each alter the result even where the base material is commonly recycled. Attached labels that are not easily removable are assessed with the component to which they adhere. Producers are required to retain assessment records for seven years, and to review an assessment when the packaging changes, when the RAM changes in a way likely to affect the outcome, or when another material fact indicates that the outcome is no longer reliable.

Versions, dates and annual change control

RAM version 1.1, published in April 2025, remains the applicable method for packaging supplied during 2026. PackUK published RAM 2027 on 1 July 2026 for packaging supplied during 2027. The annual naming convention carries operational consequences, because a later methodology is not to be applied retrospectively to an earlier reporting year. The version used, the decision path followed, supplier evidence, test reports and the date of assessment consequently form part of the compliance record.

For packaging supplied in 2026, PackUK identifies half-year submission deadlines of 1 October 2026 for the first half and 1 April 2027 for the second half. RAM data is used in the first modulated disposal-fee assessment year to differentiate packaging by recyclability.

Regulatory position statements issued during the initial 2025 implementation period moderated enforcement in respect of specified early submissions. Those statements did not abolish the underlying assessment duty or the other packaging-data obligations, and they are addressed to the enforcement discretion of the issuing regulator rather than to the content of the law. The applicable position is that of the producer's own environmental regulator.

Relationship between the RAM output and on-pack instructions

A RAM output and a consumer label answer different questions. The RAM is designed for statutory reporting and fee calculation across a technical chain of collection, sortation and reprocessing. OPRL is a private consumer-communication scheme operating its own labelling rules, collection thresholds and instructions. OPRL stated in October 2025 that green or amber RAM results will correspond to an OPRL "Recycle" label in most instances and that red results will correspond to "Do Not Recycle" in most instances, while identifying named formats for which the two systems diverge. The statutory RAM assessment and the voluntary OPRL label decision are accordingly separate determinations, each with its own evidence base.

The same distinction applies to free-form claims. A green RAM rating may support evidence that packaging is recyclable in current infrastructure, but it does not of itself establish that an unqualified claim is clear and not misleading in respect of the whole package in its actual sales context. Conversely, the absence of a consumer label does not relieve a large producer of the RAM reporting duty. The statutory assessment, the voluntary scheme determination and the substantiation for any consumer claim are linked but distinct records.

Enforcement

The Environment Agency, Natural Resources Wales, the Scottish Environment Protection Agency and the Northern Ireland Environment Agency regulate producer compliance in their respective nations. They may audit records, inspect methodology and take enforcement action under their published policies. The 2024 Regulations provide criminal offences and civil sanctions for failures such as non-registration, deficient record keeping and missing or late reports. Available responses include warnings, compliance notices, enforcement undertakings, fixed and variable monetary penalties and prosecution; offences under the framework are punishable by a fine. These sanctions attach to the regulatory data and fee duties, and not to the absence of a RAM rating on pack.

Primary sources

• Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332 — Open source
• PackUK, Recyclability assessment methodology: supplementary guidance — Open source
• Defra and PackUK, Recyclability assessment methodology: stages of recyclability and definitions — Open source
• PackUK, Recyclability Assessment Methodology (RAM) v1.1 (publication notice) — Open source
• PackUK, PackUK announces the Recyclability Assessment Methodology (RAM) roadmap — Open source
• PackUK, Recyclability Assessment Methodology (RAM) package of support — Open source
• Environment Agency, Extended producer responsibility for packaging (pEPR): recyclability assessment obligations — RPS 350 — Open source
• PackUK (departmental page) — Open source
• PackUK, RAM 2027 publication notice (1 July 2026) — no stable primary URL verified

Note on sources and verification

Two matters are expressly unconfirmed. First, the list of eight RAM material categories set out above — paper and board, fibre-based composites, plastic, steel, aluminium, glass, wood and other — was not individually confirmed against the text of RAM version 1.1. The supplementary guidance consulted for this page enumerates a shorter list which separates rigid from flexible plastic and does not name steel, aluminium or wood as distinct headings. Both enumerations are recorded above and the discrepancy is not resolved here. Second, the treatment of medical packaging is confirmed only to the extent that the supplementary guidance refers to red-medical, amber-medical and green-medical outputs; the specific treatment where a red design is unavoidable because another regulatory requirement precludes a more recyclable alternative was not confirmed against the RAM 1.1 text.

The two quoted PackUK statements on labelling, and the seven-year record-retention period, were read from the supplementary guidance page cited. The publication of RAM version 1.1 in April 2025, the publication of RAM 2027 on 1 July 2026, and the 2026 submission deadlines of 1 October 2026 and 1 April 2027 are taken from the verification record underlying this page; the RAM v1.1 news page consulted gives the publication date as 29 April 2025 and describes that version's application to packaging placed on the market from 1 January 2025, with a first reporting deadline of 1 October 2025, and no source retrieved for this page states in terms that version 1.1 governs packaging supplied during 2026. No stable primary URL was verified for the RAM 2027 publication notice.

The scope exclusions for reused packaging, exports and deposit-return containers, the automatic red outcome for unevidenced packaging, the description of the amber and red criteria, and the enumeration of civil sanctions and offences are carried from the draft material underlying this page and were not read from the Regulations or the methodology text. No section number of SI 2024/1332 is cited above, because none was confirmed.

The analysis would change on publication of a further RAM version, on amendment of SI 2024/1332 in respect of the assessment or reporting duties, on a change in the deposit-return treatment of glass drinks containers, or on the withdrawal or replacement of the regulatory position statements referred to.

Last verified: 19 August 2026.