Defra: Recyclability Assessment Methodology (RAM) Consultation

A recent Defra newsletter announced a consultation on the draft Recycling Assessment Methodology (RAM) Guidance under the Packaging Extended Producer Responsibility (EPR). RAM is a framework designed to evaluate the recyclability of primary and shipment packaging introduced to the market by producers. This assessment will inform the modulation of disposal fees starting in 2026, based on data from 2025. Currently, it remains unclear whether this methodology applies to non-household packaging, which does not incur disposal fees.You can access draft RAM Guidance here. 

PA Consulting developed the RAM on behalf of Defra in collaboration with industry representatives across the packaging value chain. They are seeking stakeholder feedback on the current RAM methodology and guidance. You can access the survey here. The survey closes on the 31st of October 2024. If you have questions or comments on the draft RAM guidance, please contact Claire at [email protected]. 

Following the survey, a second draft will be shared in November for additional testing and feedback. PA Consulting will finalise the RAM guidance and submit it to Defra by the end of November 2024. Defra is expected to approve the RAM and its guidance in December 2024, with a final version available for producers from January 2025.

The RAM will evaluate packaging using a traffic light system (Red, Amber, Green) to reflect its recyclability.

• • Red: Packaging that poses significant recycling challenges and is problematic for waste management systems.
  • Amber: Packaging that is recyclable but faces limitations in infrastructure support or contains items detrimental to the recycling process.
  • Green: Packaging that is widely recyclable within the UK’s current waste management systems.

The RAM assesses four elements of the recycling process to categorise materials:

1. 1. Collection: Whether local authorities or dedicated services collect the packaging.
   2. Sortation: The packaging’s design for large-scale sorting.
   3. Reprocessing: The ability to reprocess the packaging without quality issues.
   4. Application: The suitability of the reprocessed material to replace virgin materials.

The RAM guidance identifies specific packaging items that will automatically be categorised as ‘Red’, resulting in higher disposal fees. This list has been reduced from 13 packaging items to 7. These items include:

• • The packaging has integrated electrical componentry and/or batteries that would be classed as Electrical and Electronic Equipment (EEE) for example, boxes that include LED lights
  • Component is made of plastic containing Carbon Black pigment
  • Component is made of PVC (including non-PVC with PVC components)
  • Component is made of Polystyrene HIPS, expanded & extruded
  • Component is made of Compostable and degradable, including bio- or oxo-degradable
  • Component is made of Non-polyolefin foamed plastics e.g. non-PP and non-PE
  • Component is made of paper or board and has double sided lamination

In 2025, a flat base disposal fee will be charged per material. From 2026, fees will be modulated based on the recyclability of the packaging.