Recyclability assessment methodology: how to assess your packaging waste

From 1 January 2025, liable producers who supply household packaging, packaging that commonly ends up in public bins or household drinks containers made of glass 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’.

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

 Recyclability assessment data: June 2025 regulatory position statement

The environmental regulators have issued a statement on collecting and reporting data under the RAM.

This only applies to Recyclability Assessment Methodology (RAM) data collection and reporting. It does not apply to any other data you must collect and report for EPR for packaging.

Read PackUK’s statement on recyclability assessment. This links to regulatory position statements from each of the four regulators. Check the statement from your regulator to understand how this affects your data submission.

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 supply household packaging., packaging that commonly ends up in public bins or household drinks containers made of glass.

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

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 red, amber or green.

Outputs: the red, amber, green scale

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

• red 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 is widely recyclable in the current UK infrastructure

Materials that are exempt

Some packaging is exempt from a recyclability assessment:

• 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 and they have been intentionally added:

• 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
• 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

Medical thispackaging

Medical willpackaging affectis whatimmediate or outer packaging on:

• medicinal products
• veterinary medicinal products
• medical devices

Immediate packaging that is in immediate contact with the product.

Outer packaging is any packaging into which the immediate packaging is placed.

You can find out more about medicinal products in the Human Medicines Regulations 2012.

If you payare (‘modulation’)uncertain whether a product counts as medical, check with the Medicines and Healthcare products Regulatory Agency (MHRA). They publish guidance that explains how to tell if your product is a medicine.

FullMedical detailspackaging must be reported under different codes:

• red - medical
• amber - medical
• green - medical

If you assess your medical packaging as red - medical and that it must be red - medical because of howa feesregulatory willrequirement, then it can be modulatedreported as amber - medical. You must have evidence for this.

If you assess your medical packaging as red - medical and this is not because of a regulatory requirement, it will be publishedsubject to modulation in 2025.the same way as other red-rated packaging materials.

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

Find out about modulated disposal fees.

What you must report in 2025

You need to submit recyclability assessment data about all household packaging that you supply.

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 how to create your file for EPR for packaging.

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.

RAM versions and updates

The RAM will be reviewed and updated annually. This is to allow for innovation, evolving market conditions and regulatory changes.

The update will happen in the autumn before the reporting year it applies to.

This version of the RAM: 1.1

This is RAM version 1.1 (April 2025). This simplifies the first version, which was published in December 2024. Major changes are noted in the appropriate section.

Who decides these ratings

There willis be a RAM Technical Advisory Committee (TAC) whichthat willadvises advise PackUK on the annual review of the RAM. The TAC is an advisory body made up a broad cross section of the packaging value chain. It willsupports support PackUK to assess any planned changes to the RAM.