The Recyclability Assessment Methodology (RAM): What Packaging Producers Need to Know

The Recyclability Assessment Methodology (RAM) is a part of the UK’s Extended Producer Responsibility (EPR) regulations for packaging. Producers must assess and report the recyclability of each material component of their household packaging using this methodology. This is a requirement for packaging activities from January 2025. Non-household packaging is not included in this requirement.

This guide offers an overview of RAM, its potential impact, and how our data management services can help you navigate these evolving requirements.

What Is the Recyclability Assessment Methodology (RAM)?

The RAM has been developed by PA Consulting and Defra as a framework for assessing household packaging recyclability in the UK. It evaluates each component based on the current recycling infrastructure, covering collection, sorting, and reprocessing potential. RAM assigns a Red, Amber, or Green (RAG) rating to each component, linking recyclability to EPR fees, ultimately encouraging producers to use more recyclable materials.

Red: Challenging to recycle, often due to problematic materials or designs.
Amber: Recyclable but may need specialised collection or reprocessing.
Green: Widely recyclable within the UK’s current systems.

Note: The RAM is currently not considering circularity, carbon footprint, recycled content or composability, but primarily focused on recyclability.

RAM Decision Tree

How RAM Fits into Extended Producer Responsibility (EPR)

RAM is a part of the UK’s EPR framework, which aims to shift the cost of managing household packaging waste from taxpayers (traditionally funded by Council Tax) to the producers of packaging. EPR holds producers responsible for the full lifecycle of their packaging, from design through to end-of-life disposal or recycling.

Read our EPR Guide

The RAM’s Red, Amber or Green classifications will directly impact fees, with non-recyclable packaging components likely incurring higher costs. Through this fee modulation, EPR incentivises sustainable packaging choices that align with a circular economy, reducing waste and improving recyclability.

Modulated Fees Calculation

How RAM Categorises Packaging

The RAM framework assesses recyclability of household packaging waste through four main stages:

Classification: Identifies the material composition and separability of each component.
Collection: Verifies that components meet collection thresholds (widely collected by at least 75% of Local Authorities or limited collection by at least 50%).
Sortation: Confirms that packaging materials are sortable through industry methods, like Near Infrared (NIR) technology.
Reprocessing: Ensures the material can be reprocessed without disrupting recycling processes.
Application: Assesses whether reprocessed materials can be used in new products, replacing virgin materials and contributing to a circular economy.

Each of these stages guides producers in assigning a Red, Amber, or Green classification to packaging components. This classification then connects to the EPR modulated fee structure, applying fees based on recyclability ratings for agreed-upon categories of household packaging materials.

Key Dates and Consultation Timeline for the RAM

Though the RAM is in its early stages, it is now active and forms a part of EPR reporting from H1 (Jan-Jun) 2025 for household packaging. Below is a timeline of recent updates relating to the RAM:

Early 2025 (Technical Advisory Committee): Alongside the RAM, a technical advisory committee (TAC) has been appointed, which will oversee an annual review of the RAM in line with the reporting schedules to ensure it reflects any changes in policy, infrastructure and technical capability.
January 2025 (Implementation Date): RAM compliance begins. Producers need to categorise their household packaging using the RAG system, which will inform EPR fee calculations.
Autumn (November-December) 2024: Final guidance based on consultation outcomes. Defra gathered industry feedback to refine the RAM and ensure it aligns with industry capabilities. It’s advisable to monitor updates, familiarise your business with data requirements and prepare your systems accordingly.

Prepare for RAM with Clarity

At Clarity, we’re here to support Packaging Producers through the changes brought by EPR. Our Dynamic Data services, backed by our team of data experts and our Clarion data platform, help you simplify data reporting and ensure seamless EPR compliance.

We offer comprehensive support for RAM compliance, providing tools and guidance to help you track, assess, and report recyclability while the consultation process continues:

Data Collection & Classification: Working as an extension of your business we ensure your have all the necessary data and help you categorise packaging components according to RAM’s RAG criteria, setting you up for future compliance.
Guidance on Evolving Regulations: Stay informed on RAM developments with insights from our compliance experts, who keep you updated on the latest regulatory changes.

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