From 1 January 2025, liable producers who supply household packaging must assess the recyclability of that packaging and report the results of the assessment to the environmental regulator.

To do this, you will need to assess packaging you supply using the recyclability assessment methodology (RAM).

Different kinds of packaging receive different ratings - red, amber or green. This rating affects the disposal fee that will be charged for that packaging. This is sometimes called ‘fee modulation’.

You must assess all household packaging you supply, excluding drinks containers within scope of the Deposit Return Scheme (DRS).

This is an overview of the RAM. There is separate technical guidance that explains:

• how to assess and rate individual materials - use this to find red, amber or green ratings for your packaging materials
• definitions and background - this explains the stages of recyclability and some technical terms

Who has to do this

Only large producers (also known as ‘large organisations’) must collect and report their recyclability assessment data. Find out about small and large producers.

What packaging you must assess

You only need to collect and report recyclability assessment data if you supplyare responsible for household packaging.

Drinks containers covered by the DRS

Drinks containers in scope of the DRS are not subject to a RAM assessment.  These:

• are made wholly or mainly from aluminium, steel or PET plastic
• have a capacity of between 150 millilitres and 3 litres
• are likely to be used once or for a short period of time

Categories of material

There are 8 categories for materials. These are often called ‘specified materials’.

• paper and board
• fibre-based composite materials
• plastic - there is separate guidance for rigid plastics and flexible plastics
• steel
• aluminium
• glass
• wood
• other

Each unititem of packaging or component should be assessed under one of these categories.

If your unit or component is made up of more than one of these materials, assess it under the category that makes up most of its weight.

Separate guidance explains how to apply the RAM to each category of material. Use that guidance to assess whether your packaging unit or component is is red, , amber or  or green.

Drinks containers

For glass containers, other parts that come away easily should be assessed separately from the glass body.

This includes things like metal lids and screw tops. It does not usually include labels that cannot be removed without effort or tools. These should be assessed as part of the container.

Outputs: the red, amber, green scale

In addition to the material category, packaging will fall into one of 3 sub-categories:

• red packaging packaging has specifications that make it difficult to recycle at scale
• 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
• green packaging packaging is widely recyclable in the current UK infrastructure

Materials that are exempt

Some packaging is exempt from a recyclability assessment:exempt:

• reused packaging, unless it has been imported into the United Kingdom
• any packaging exported from the United Kingdom by the producer
• drinks containers made of polyethylene terephthalate (PET) plastic, steel or aluminium
• drinks containers for which a deposit is payable and is within scope of a DRS which is in operation
• non-household packaging

Automatic reds (‘problematic packaging’)

Some packaging and components of packaging always count as red on the scale.

Items of packaging or components must be classified as red if they contain any of the following above the limit of detection:

• integrated electrical components or batteries that would be classed as Electrical and Electronic Equipment (EEE) - for example, boxes that include LED lights
• any of the substances of very high concern (SVHC) above the specified thresholds set out under UK REACH
• inks that are not manufactured in compliance with the EuPIA  Exclusion Policy for Printing Inks and Related products
• perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) that have been intentionally added
• any household packaging within scope of the RAM which has not been assessed or where the detail required to undertake an assessment isn’t available

If perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) have been intentionally added to packaging, this is also an automatic red. However, this does not apply if the predominant material is aluminium, steel or glass.

How this will affect what you pay (‘modulation’)

Full details of how fees will be modulated will be published in 2025.

What you must report in 2025

You need to submit recyclability assessment data about all household packaging thatplaced youon supply.the market.

You must enter the results of your assessment on the packaging data file that you submit to the regulator through the report packaging data service. There are initial details on how to do this in the guidance that explains explains how to create your file for EPR. More details will be published closer to the date you must report.

If If you need help assessing your packaging

If you do not know what the packaging you supply is made of or are missing other technical details that you need to complete the assessment, contact the packaging manufacturer.

You can also contact a third party provider for advice on your EPR packaging obligations including making and reporting the results of your recyclability assessments. Third party providers are likely to charge a fee for this.

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