2025 brings a new packaging data reporting requirement, under the packaging Extended Producer Responsibility (pEPR), for large producers placing household packaging or packaging that commonly ends up in public bins on the market: the recyclability assessment obligation.
The Recyclability Assessment Methodology (RAM) is the tool provided by PackUK (the pEPR scheme administrator) for producers to use, to meet this recyclability assessment obligation. The output of RAM will be used to modulate the pEPR disposal fees, a new fee under pEPR applicable to household packaging and packaging that commonly ends up in public bins. This disposal fee covers the cost of local authority collection and sorting of packaging waste, which previously under the old Producer Responsibility regulations was not accounted for. The RAM and corresponding modulated disposal fee are central to the pEPR reform, incentivising improved packaging choice and design through a focus on recyclability, initially with long term ambitions to focus on a range of environmental considerations.
During the RAM’s development, Defra welcomed stakeholder engagement, with several drafts shared before Christmas 2024, encouraging industry feedback and comments. Combining these insights, PackUK published the first version of RAM on the 23rd December 2024 for producers to utilise when completing their October 1st packaging submission. V1.1 of RAM is set to be widely released by end of April 2025 with some further clarifications, however, remains largely the same.
Several key challenges and practicalities are set to impact deliverability of the existing RAM methodology. In comparison to previous packaging data requirements, RAM introduces a significant step change in data intensity, requiring producers to capture substantially more granular packaging information.
Across packaging materials, the data points vary greatly, with in-depth considerations of material formats and sub-materials, packaging design inclusive of size, colour and density, as well as information on additives, adhesives, fillers, agents, lamination, inks or varnishes. For producers who previously collated packaging waste reports based upon the packaging activity and main material type, this can be an overwhelming jump.
This data is gathered from across the supply chain, demanding increased transparency and often met with hurdles such as language barriers and data inaccuracy. Collating this level of data from multiple, often hundreds of suppliers, could be challenging. For many producers, this means building or upgrading systems and processes to ensure accurate packaging data capture. However, under the pressure of the compliance deadline, it raises concerns over business readiness. Alongside these practicalities, a lack of visibility on the true financial impact of modulation has also limited the ability to plan and budget effectively, with some producers flagging concerns around achieving compliance under RAM.
To help with the recyclability assessment obligation, a number of tools have been developed to provide producers with a simple and straightforward way to determine a “red, amber, green” (RAG) status as per the Government’s RAM stipulations.
