Recyclability Assessment Methodology Support

The RAM aims to standardise the evaluation of packaging recyclability, ensuring that producers are accountable for the environmental impact of their packaging and are incentivised to design more recyclable products.

The RAG rating system directly influences the fees producers pay under packaging EPR regulations. Packaging rated as Red incurs higher fees due to its recyclability challenges, while Green-rated packaging benefits from lower fees, encouraging the use of recyclable materials.

Producers must comply with the Recyclability Assessment Methodology (RAM) from the H2 2025 packaging EPR submission period onwards. RAM assessments must be completed and submitted alongside household packaging data from this reporting period.

A temporary relaxation applied to H1 2025. Under Regulatory Position Statement (RPS) 350, published on 27 June 2025, regulators confirmed they would not take enforcement action where RAM assessments were not submitted with H1 2025 household packaging data by the 1 October 2025 deadline.

From H2 2025, full RAM compliance is required.

Currently, only large producers are required to assess their packaging using the RAM. However, small businesses are encouraged to adopt these practices to enhance sustainability and prepare for potential future regulations.

Improving packaging recyclability involves selecting materials compatible with existing recycling systems, simplifying designs to reduce complexity, and avoiding materials that are difficult to recycle. But recyclability is just one piece of the puzzle.

Our expert Packaging Technology Consultancy service goes further, helping businesses assess, refine, and enhance their packaging strategies to lower pEPR costs and achieve a green RAG rating. Whether you’re looking for a basic recyclability assessment, detailed material analysis, or a full packaging redesign, we offer tailored solutions to meet your goals.

Our team of expert consultants can also provide advanced support through:

• Life Cycle Assessments (LCAs) – Evaluate the full environmental impact of your packaging from cradle to grave, identifying opportunities for improvement.
• Environmental Product Declarations (EPDs) – Deliver transparent, credible reporting to support your sustainability commitments and communicate environmental performance.

For bespoke advice and to keep your business at the forefront of sustainable packaging, contact us today or visit our Packaging Analysis services webpage to learn more.

There is currently no official RAM template from Defra. However, producers must base their assessments on Defra’s published guidance, which includes:

• The core methodology for recyclability assessment
• Material flow maps
• Common packaging format examples

These resources help assign accurate Red, Amber, or Green (RAG) ratings based on how packaging is treated within UK recycling systems.

How Valpak can support you

RAM reporting requires more detailed data and introduces a new recyclability assessment step, both of which can be time-consuming and complex. Our streamlined RAM Data service reduces this burden:

• Data collection: We gather, verify, and format detailed packaging data, using our approved packaging group methodology to fill any gaps where needed.
• Recyclability assessment: We can carry out RAM assessments in line with Defra’s guidance, applying RAG ratings across your packaging range.
• Submission ready data: We prepare data at the required level of granularity, including material splits by red, amber, and green categories.

We offer three service levels to suit your business’s needs, from full support to light-touch verification. Packages are tailored based on the data you have, and the level of reporting accuracy or cost forecasting you require. Enquire to find out more.

Packaging that includes additional components such as labels, tamper-evident features, or colourants must be assessed based on its real-world recyclability within the UK waste system. The assessment considers the packaging in its typical form when presented for recycling by consumers.

• Labels:
  If a label is easily separable and does not interfere with the recyclability of the main packaging material, the item may still achieve a favourable RAG rating. However, large, full-sleeve, or non-detachable labels made from incompatible materials may negatively affect the rating.
• Tamper-evident features:
  Seals, tear strips, clips, and similar components must be assessed where they may hinder the recycling process or are made from incompatible materials. These features can contribute to an Amber or Red RAG rating depending on their impact.
• Colour and material composition:
  The colour and opacity of packaging can affect recyclability. For example, darker or highly opaque plastics are more difficult to detect and sort within UK recycling systems and may result in a lower RAG rating.

RAM assessments must reflect how the packaging is typically placed on the market and disposed of, ensuring the classification aligns with practical recyclability outcomes.

Technical packaging formats must be assessed in line with how they are managed within UK recycling infrastructure. These formats can present specific recyclability challenges:

• Triggers and pumps:
  These components are typically made from multiple materials, such as metal springs within plastic housings, which can complicate recycling. If the trigger or pump cannot be easily separated and recycled independently, it is likely to receive a Red RAG rating due to material complexity.
• Aerosols:
  Metal aerosols are widely collected across UK kerbside recycling schemes. Where aerosols are fully empty and safely depressurised, they may achieve a Green or Amber RAG rating, depending on collection coverage and reprocessing capability.
• Multi-component packaging:
  Where packaging consists of two or more individual components, a separate RAM assessment should be carried out for each component that is easily separable by hand.

If a component cannot be easily separated by hand, it should be assessed based on the predominant material type. The recyclability rating should reflect how the packaging is most likely to be presented and processed within UK recycling systems.

In all cases, producers must retain clear, evidence-based justification for the assigned RAG rating as part of their packaging EPR submission records.

Packaging that falls under the scope of the Deposit Return Scheme (DRS) does not require a separate RAM assessment. These items, such as certain beverage containers, are managed through a different recovery pathway and are not subject to the RAM RAG-rating requirements.

However, it is important for producers to identify and separate DRS-eligible packaging from other packaging formats in their data submissions. While DRS packaging is excluded from RAM reporting, it remains subject to wider pEPR (packaging Extended Producer Responsibility) obligations and must still be accounted for in total packaging data.