RAM reworked: A breakdown of the latest Recyclability Assessment Methodology updates

In anticipation of PackUK officially releasing the latest version of the Recyclability Assessment Methodology (RAM) at the end of April, they have published a technical draft of the changes.

These changes have been implemented as a result of industry consultation, stakeholder feedback and requests for clarity around elements of the guidance. Here, we delve into what’s changed from December’s version.

What do these changes mean for you?

Whether you are a packaging producer, a packaging designer or retailer, the clarification of these elements of the RAM mean that we can offer more clarity on your submission and possible future eco-modulation costs. The update offers:

• More precise and predictable outcomes for material classification
• Reduced reliance on costly testing or ambiguous criteria
• Better alignment with how materials behave in real-world waste streams

RAM exemptions for all DRS containers at go-live

Wording that exempts producers of single-use drinks container packaging that’s to be within the scope of Deposit Return Schemes (DRSs) being introduced across the UK within the next few years has been expanded to enable RAM exemptions for any in-scope materials beyond PET, steel and aluminium. This is likely to accommodate potential scope divergence across the UK, for example the Welsh Government’s current plans to include glass within its DRS.

Automatic ‘RED’ list

The previously automatic RED list is now clearly defined – with triggers including PFAS, EEE, SVHCs, and non-EuPIA inks. Crucially, if the predominant material is aluminium, steel, or glass, then PFAS presence does not lead to an automatic RED classification.

Simplification of criteria

Several material-specific RED and AMBER classifications have been removed, particularly those requiring additional testing or relating to design-for-recyclability assumptions. For example:

• Carbon black in inks on flexible plastics is still a RED factor – but focus has shifted to consider its presence in masterbatch content.
• Product residue is no longer considered a RED classification trigger by default across all material types. However, glass packaging still includes a specific trigger for “designed-in contamination,” where residue is expected as part of the design.
• PAE additives and certain UV varnishes no longer require testing to avoid AMBER ratings.

Clarifications on labels and sleeves

In plastics (both rigid and flexible), previous requirements relating to the size and material of sleeves, labels, and inserts have been amended. This includes:

• Removed stance that bottles and pots/tubs/tray with labels and sleeves covering over 40% and 60% respectively = RED.
• Removed criteria that stated adhesives insoluble in 80c water = RED.
• Heavy white is no longer seen as a problematic colour in PP plastic packaging.

Sortation rules for steel

Items over 300mm are now RED unless they are foldable or part of a take-back scheme, acknowledging sortation challenges at scale.

Wood and “other” materials

A clear stance has now been taken: where no national collection or sortation exists at scale, RED classification applies at all stages.

How Valpak can support you – ‘We’ve got this’

We’ve already incorporated RAM v1.1 into our recyclability assessment tools, packaging reviews, and audit preparation processes. That means:

• If you’re a Valpak member, you’re already covered – our systems reflect the new requirements.
• Need advice on packaging format changes? Our expert teams are ready to help you ensure compliance and comprehensive data submissions, along with how you can optimise for future recyclability.
• Confused about specific classifications? We’ve created detailed material-by-material decision trees to walk you through the updates.

Valpak’s RAM Service:

We have developed a range of targeted and RAM specific services to ensure you are fully covered. By using our tools and expertise, businesses can take control of their packaging Extended Producer Responsibility (pEPR) obligations, optimise packaging, and cut costs:

Educational resources: Help your team understand and implement sustainable packaging practices, through tools such as our RAM Decision Trees and other online tools.

Packaging Technology Consultancy: Insights into the latest innovations and sustainable packaging solutions to improve your RAM rating, reducing your pEPR costs and improving your environmental impact.

Data services: Assistance with accurate data collection and reporting to ensure compliance with RAM requirements.

Consultancy services: Not sure about your RAM scores? We can conduct a one-time assessment of your packaging components or review your in-house assessments for accuracy and peace of mind.

Visit our RAM webpage to find out more or call our expert team on 03450 682 572 for guidance on next steps.