The Recyclability Assessment Methodology (RAM)

Marwan Elsaifi

Associate Director

Fergus Mooney

Principal Consultant

Lizzie Smith

Principal Consultant

Hannah Worthington

Senior Consultant

Joanne Paring

Senior Consultant

What is the RAM?

The Recyclability Assessment Methodology (RAM) is a standardised, science-based framework introduced in the UK to assess the recyclability of household packaging in practice and at scale across the country. It helps identify whether and how packaging gets recycled in UK systems and is designed to enable eco-modulation of Extended Producer Responsibility (EPR) fees in order to incentivise more sustainable packaging design choices.

Developed in collaboration with industry stakeholders, the RAM underpins recyclability claims in the UK, as regulations shift toward making businesses more accountable for the end-of-life impact of their packaging.

The RAM allows for the grading of recyclability through five stages:

1. Classification
2. Collection
3. Sorting
4. Reprocessing
5. Application

This grading will then be used by PackUK, the scheme administrator for the UK’s Extended Producer Responsibility for packaging (pEPR) programme, to eco-modulate waste management fees for household packaging.

The latest version of the RAM, V1.1, was published in April 2025. Moving forward the document will be reviewed and updated annually following review by PackUK and the RAM Technical Advisory Committee. The aim of this latest version was to simplify the methodology and increase usability.

Who is affected by the RAM, and when?

The RAM applies to large producers with a turnover greater than ₤2 million that place more than 50 tonnes of packaging on the UK market annually. This includes UK businesses and any business outside the UK shipping or placing product on the UK market. However, the RAM only applies to household packaging. Therefore, it may be that not all packaging that large producers report will be affected.

Large producers must start using this method to assess packaging placed on the market from 1^st January 2025. The first data declaration using the RAM is due by 1^st October 2025. Producers will see the financial implications of the RAM in their 2026 waste disposal fee invoices. PackUK will issue these invoices directly to Producers from October 2026. These fees are additional to their PRN obligations.

RAM Timeline

What is the RAM aiming to do?

The RAM aligns to common collection, sorting, and reprocessing infrastructure provided by local authorities across the UK and will help businesses improve the quality of recyclable materials available on the market.

It was developed to reduce greenwashing, provide clear and consistent definitions of “recyclable”, and enable businesses and regulators to make evidence-based decisions on packaging design and compliance.

The RAM aims to achieve the following objectives:

1. Define recyclability based on actual UK infrastructure, not theoretical potential.
2. Guide businesses on which packaging formats and materials are collected, sorted, and reprocessed effectively at scale.
3. Standardise assessment criteria so that packaging recyclability can be consistently and fairly evaluated.
4. Support policy enforcement in alignment with the UK’s Packaging Extended Producer Responsibility (pEPR) programme.
5. Drive packaging design innovation by highlighting which formats or materials perform poorly in real-world recycling.

Ultimately, it aims to close the gap between design and reality, making sure that when businesses say that the packaging is recyclable, it actually is within the UK’s built and planned waste management infrastructure.

How the RAM fits into the UK’s pEPR framework

Under pEPR, producers will be financially responsible for the packaging they place on the market, including costs associated with collection, sorting, and recycling. The RAM determines whether the packaging is classified as recyclable or not, which directly influences:

• Modulated fees
• Reporting requirements
• Packaging design incentives

Take-Back Schemes

Unlike in the 2024 version, take-back schemes are included in the “collection” section of the 2025 V1.1 version of the guidance. These schemes offer a way to recapture materials and packaging types that are not included in kerbside collections. The standard for take-back schemes has been developed in alignment with the OPRL Takeback Protocol.

Producers using this collection route in their recyclability assessment must confirm that the take-back scheme meets the following criteria:

• be accessible to at least 75% of the UK population
• not conflict with local authority kerbside collections
• not be restricted to one brand or product
• not require a purchase to be made before an item can be deposited
• have full transparency that the collected material is recycled.

This aligns with proposals in the EU’s PPWR for systems for take back including reuse. We welcome this as it sets the foundation for building wide-scale reuse systems within the UK.

Streamlined Specifications

The criteria for additive weights, coverage of labels, adhesives, chemicals, and niche material specifics have been streamlined. While these adjustments aim to reduce complexity, there remains a possibility for reintroduction of the more stringent criteria in future versions of the RAM as the Technical Advisory Committee will conduct annual assessments for PackUK to review and adopt where necessary.

While the likelihood of any re-introduction of stringent assessment criteria remains uncertain, this would likely be driven by negative impacts of a material on recycling rates and contamination from emerging materials, e.g. high-barrier papers. We may also see wider environmental impact metrics be considered in eco-modulated fees, however the prospect of this also remains uncertain.

Continued expertise in these areas remains essential for managing compliance, avoiding higher modulated fees, and harmonising with PPWR requirements and REACH regulations.

Clear Next Steps on Data Collection

This guidance is the long awaited clarity that the industry has needed and sets a firm steer on the regulator’s expectations for packaging placed on the UK market in the future. Following years of speculation and uncertainty, there is now an opportunity to embed workflow efficiencies around data collection into your processes to help unlock value creation opportunities across the business. Rethinking packaging design choices to avoid higher modulated fees can open the door to more widespread impact across your portfolio. Data collection sits at the heart of reporting and will support better decision making. However, it comes with considerable manpower and time demand. Many upcoming regulations will be asking for the same data, presented slightly differently, so it is important to act now to enhance existing processes and to embed new ones.

How the RAM compares to expected recyclability assessments in the EU under PPWR

The EUs equivalent to the RAM is expected to be published in 2027. We expect there to be significant overlap between the two methods as they are aiming for the same final outcome. The RAM has been developed with similar industry organisations and has drawn from European technical guidance as many UK MRFs share similar infrastructure to those in the EU. However, the devil is in the detail with this form of technical assessment, so we hope that the EU will use the UK’s RAM to inform their methodology to ensure alignment.

How will businesses use the RAM?

Businesses will use the RAM to:

1. Assess Packaging Recyclability
   • Verify if existing and/or proposed packaging components meet recyclability criteria in the UK.
   • Understand whether materials and formats are treated as recyclable under pEPR.
2. Guide Packaging Design Innovations
   • Design packaging that aligns with the recyclability criteria and preferable pEPR fee structures.
   • Avoid packaging formats that are recyclable in theory but unable to be processed in practice and at scale.
3. Support Compliance and Reporting
   • Accurately report recyclability in pEPR data submissions
   • Alignment with marketing claims (green claims)
4. Plan for Modulated Fees
   • Forecast and manage pEPR-related costs based on recyclability scores
   • Prioritise packaging improvements that reduce fee exposure
5. Benchmark and Compare Packaging Formats
   • Compare how different packaging options perform in terms of recyclability objectively
   • Adjust and iterate strategies accordingly

Businesses have the option to either use the public RAM guide to assess packaging or administer third-party recyclability assessments aligned with RAM.

What the RAM means for businesses

Roll out of the standardised recyclability assessment is representative of the global shift we are seeing from voluntary sustainability goals to mandatory regulatory compliance with financial implications. Businesses need to:

• Embed recyclability at the core of packaging design from the outset to ensure circularity and compliance.
• Evaluate existing packaging portfolios to identify which are non-compliant and/or have higher equivalent fees.
• Enable cross-functional collaboration within the sustainability, procurement, marketing, and compliance team to ensure alignment on the packaging design.
• Prepare for regulator, investor, and consumer queries around recyclability claims.

Fundamentally, RAM empowers businesses to take control of their packaging footprint with clear guidance, an evidence-based assessment, and regulatory alignment. It also sets the precedent that any packaging that is not compatible with the UK’s real-world recycling system will come with a cost.

RAM application process flow for businesses

How Anthesis Can Help 

Ensuring that regulatory compliance through 2030 and beyond does not drain your sustainability budget can be a daunting task. We can help businesses at every stage along the way, whether it’s data collection, calculation and assessment support, or scenario modelling, engaging with our packaging and EPR experts will help manage compliance risk, identify cost exposure, and free up your time.

It is essential to take a proactive approach to this impactful regulation as it will benefit your business in the long-term. Engaging with industry peers, trade associations, and other third parties to collate knowledge and reduce the burden of individual responses to the same challenges will be vital during this time to ensure your business is adequately prepared.

Anthesis supports businesses with packaging portfolio recyclability by leveraging our deep sustainability and regulatory expertise to help design packaging that meets both current and emerging requirements. We guide clients through material selection, design-for-recycling best practices, and alignment with national and international frameworks such as the UK’s RAM and RecyClass. Our tailored approach provides clear, actionable insights to improve packaging recyclability, reduce environmental impact, and ensure market compliance, right from the early stages of development.

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