With the updated Recyclability Assessment Methodology (RAM) applying to packaging supplied during 2027, packaging producers will need to review how they assess and report packaging recyclability under packaging Extended Producer Responsibility (pEPR).
Published by PackUK, RAM 2027 introduces revised assessment criteria, updated material guidance and additional considerations that could affect how packaging is rated.
For producers managing large or complex packaging portfolios, preparing for these changes could involve reassessing existing packaging, gathering additional supplier information and identifying where recyclability ratings may change.
So, what has changed under RAM 2027, and what practical steps should producers take to prepare?
What is changing under RAM 2027?
RAM 2027 builds on the existing methodology, introducing changes intended to provide a clearer assessment of how packaging performs throughout the recycling process.
It applies to packaging supplied between 1 January and 31 December 2027. Producers must continue using RAM version 1.1 for the 2026 reporting year, including assessments submitted in 2027 relating to 2026 packaging.
Key changes include:
- Updated and expanded automatic Red criteria: RAM 2027 specifies PFAS thresholds and adds checks covering compliance with UK food-contact materials legislation and packaging formats subject to UK regulatory restrictions or phase-outs. Existing checks relating to substances of concern, printing inks and integrated electrical components also remain relevant.
- A revised assessment process: Packaging classification is now a separate step before assessing recyclability across four stages: collection, sortation, reprocessing and application.
- Updated material-specific criteria: Changes to assessment thresholds and requirements mean certain packaging formats may receive different recyclability ratings under RAM 2027. For example, PET bottles in colours other than clear or translucent light blue, and paper or board packaging with PVC or PVDC polymer dispersion coatings, have moved from Amber under RAM 1.1 to Red under RAM 2027. Paper, board and fibre-based composite packaging designed for food to be heated within it will also now receive a Red rating.
- Revised take-back scheme requirements: Producers relying on take-back schemes must meet specific eligibility and evidence requirements to support an Amber rating.
Producers should not assume packaging assessed under RAM 1.1 will automatically retain the same rating in 2027.
For more detail, read our previous article on PackUK’s updated RAM guidance.
How should producers prepare for RAM 2027?
Reviewing packaging data and assessment processes before January can help businesses identify gaps, prepare suppliers and understand potential future pEPR costs.
1. Review your existing packaging portfolio
Start by identifying which packaging falls within your RAM obligations and which formats may be affected by the updated RAM criteria.
Pay particular attention to packaging containing multiple materials, coatings, adhesives, printing inks or other components that could influence the assessment.
Check whether packaging must be assessed as separate components or as a whole item formed from integrated components. This is determined by the methodology’s rules and can affect the resulting rating.
It is also important to distinguish assessment from reporting. Assessing integrated components together does not necessarily mean reporting all their materials as a single material. Producers must still follow the applicable material reporting rules.
Reviewing existing assessments can help identify both packaging at risk of a less favourable rating and formats that may benefit from the revised guidance.
2. Check your packaging data and supporting evidence
Accurate packaging data is essential for completing RAM assessments, and the updated methodology makes it particularly important that producers have sufficient evidence to support their recyclability ratings.
Depending on the packaging material this may include:
- Material composition and individual packaging components.
- Packaging dimensions, weights and material classifications.
- Coatings, adhesives, inks and other additives.
- The presence of restricted substances, including PFAS where relevant.
- Supporting evidence demonstrating recyclability through applicable collection, sortation, reprocessing and application routes.
Under RAM 2027, packaging must be reported as Red where producers do not have evidence supporting an Amber or Green rating.
For businesses managing packaging supplied by multiple manufacturers, obtaining this information may require additional engagement with suppliers.
Identifying missing information early can help producers avoid unsupported recyclability ratings and improve the accuracy of their assessments.
3. Reassess packaging against the updated criteria
Once the necessary information is available, assess packaging using the RAM 2027 methodology.
Begin by checking the automatic Red criteria. If any apply, no further assessment is required. Otherwise, determine the correct material classification and follow the relevant assessment route.
Under the standard material assessment process:
- Packaging must achieve Green at every stage to receive an overall Green rating.
- An Amber result at any stage limits the overall rating to Amber, provided no stage is Red.
- A Red result at any stage results in an overall Red rating.
If you rely on a take-back scheme, check the specific rules. This route generally applies to packaging outside commonly collected or limited kerbside collection routes, with a specific exception allowing plastic flexibles to continue using take-back schemes alongside kerbside collection in 2027.
Qualifying schemes must meet accessibility, acceptance and traceability requirements. Simply offering a collection point is not enough: producers need evidence that the relevant packaging material progresses through the recycling process. Packaging qualifying through this route is rated Amber.
For businesses managing hundreds or thousands of packaging items, a consistent assessment process can help teams apply the methodology and identify where further investigation is needed.
4. Prioritise improvements and assess the financial impact
RAM assessments can help businesses identify opportunities to improve packaging recyclability and manage future costs.
Start by reviewing Red and Amber packaging, then consider whether changes to materials, coatings, adhesives or components could improve the outcome.
Under packaging EPR, RAM ratings help determine how household packaging waste disposal fees are modulated. Red-rated packaging attracts higher charges than more recyclable packaging within the same material category.
Combining packaging volumes, ratings and available fee information can help producers identify where improvements could have the greatest financial benefit.
A rating change affecting one high-volume packaging format could have a significant impact across a portfolio. This makes assessment data useful for packaging development, procurement and financial planning.
However, proposed changes should be checked against the relevant RAM criteria before assuming they will improve a rating. Cost forecasts should also use clearly identified fee assumptions and be updated as further information becomes available.
When must RAM 2027 data be reported?
RAM assessment results are reported alongside other pEPR packaging data.
The regulator deadlines for 2027 packaging data are:
- 1 October 2027: January–June 2027 data.
- 1 April 2028: July–December 2027 data.
Compliance schemes may set earlier member submission deadlines to allow time for checking and processing. Producers should factor these into their preparation plans.
Why is early preparation important?
RAM assessments need to remain accurate as packaging and assessment requirements change.
Producers must update assessments when packaging design, manufacture or composition changes, or when methodology changes are likely to affect the outcome. Assessments must also be updated where the result is likely to change for another reason.
Evidence supporting RAM ratings must be retained for seven years and made available to regulators if requested.
Establishing a clear process for managing specifications, recording assessments and reviewing changes can help businesses maintain accurate reporting and reduce the workload at submission time.
How can Clarity’s RAM Assess help you prepare?
Preparing for RAM 2027 may involve reviewing large volumes of packaging data, reassessing existing packaging and identifying opportunities to manage future pEPR costs.
Clarity’s RAM Assess is a purpose-built online platform designed to simplify the recyclability assessment process and support more informed packaging decisions.
RAM Assess helps producers:
- Automate recyclability assessments: Generate component-level Red, Amber and Green ratings across packaging portfolios, reducing the time and resources required for manual assessments.
- Identify opportunities for improvement: Highlight packaging receiving Red or Amber ratings and explore potential changes to improve recyclability.
- Forecast pEPR costs: Model the financial implications of modulated waste disposal fees and identify potential cost-saving opportunities.
- Simplify reporting: Manage packaging assessment data and export RAM-rated datasets to support pEPR reporting requirements.
- Manage complex packaging portfolios: Coordinate packaging assessments and decisions across multiple sites and teams.
With updated requirements approaching, a consistent approach to assessment and analysis can help businesses prepare their packaging data and prioritise their next steps.
Prepare your packaging portfolio for RAM 2027
Request a RAM Assess demonstration to see how Clarity can help you assess recyclability, identify improvement opportunities and model potential fee impacts.
