Recyclability Assessment Methodology (RAM) Consultation 1

Defra and the devolved governments are developing a new Recyclability Assessment Methodology (RAM) for use by producers to assess the recyclability of their packaging. This will apply to the Packaging Extended Producer Responsibility (pEPR) scheme.

In October a Defra newsletter announced a consultation on the draft Recycling Assessment Methodology (RAM) Guidance under the Packaging Extended Producer Responsibility (EPR).  The 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.  Version 1 of the draft RAM Guidance was available here when the consultation was open. 

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. The survey was accessible here and closed on 31st October 2024. 

Following the first survey, a second draft was shared on 21st November for additional testing and feedback. The aim was that PA Consulting would 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.

Due to the short timescale for responding, the REA contributed to the Biobased and Biodegradable Industry Association’s response letter to Defra.  This is available to REA members upon request (see contact details below).

Recyclability Assessment Methodology (RAM) Consultation 2

User testing of the draft RAM (v1) was completed in October and 150 organisations fed into this process, from eleven sectors across the value chain. Based on this feedback, government made the next iteration of the draft RAM (v2) available on .gov.uk on 21st November and invited feedback via an on-line survey, by 5 pm on 27th November 2024.

Defra wrote: ‘The RAM will enable producers to identify the appropriate modulation sub-category for their 2025 packaging placed on the market, based on current UK recyclability. Modulation will apply from year 2 (2026) of packaging EPR and will mean that fees are adjusted so more recyclable packaging pays a lower fee than less recyclable packaging. Base fees apply in year one and the latest illustrative base fees are provided on Gov.uk.’

‘The RAM also considers collection, sorting, reprocessing and application in determining the sub-category:
• The most readily recyclable packaging will receive a green modulation sub-category
• The less recyclable packaging will receive an amber modulation sub-category
• The least readily recyclable will receive a red modulation sub-category.’

After this second consultation deadline, Defra and the devolved administrations will review all feedback and update version 2 of the draft RAM, ‘taking stakeholder responses into account, prior to publishing the final version in December’.

Click HERE for REA’s response.

REA members who have questions or comments on the draft RAM guidance are welcome to contact Emily ([email protected]).