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 are required to begin assessing their household packaging using the RAM starting from 1 January 2025, with the first data submission due by 1 October 2025, covering the period from January to June 2025.

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 seals, or potential product residues, must be assessed based on its real-world recyclability within the UK waste system.

• Labels: If a label is easily separable and does not interfere with the recyclability of the main packaging (e.g., paper labels on plastic bottles), it may still be considered recyclable. However, large or non-detachable labels may downgrade the RAG rating.
• Tamper-evident features: Components such as seals, tear strips, or clips should be considered if they hinder the recycling process or are made of incompatible materials. These may contribute to an Amber or Red rating depending on impact.
• Residues: Packaging that typically contains food or product residues, especially if these are hard to remove, can affect recyclability. For example, packaging that is not effectively recyclable without rinsing or that contaminates recycling streams may be assigned a lower rating.

It is important to consider the “as presented for recycling” condition, meaning how the packaging is typically disposed of by consumers.

Technical packaging formats should be assessed in line with how they are handled within UK recycling infrastructure. These formats often present unique challenges:

• Triggers and pumps: These components are usually made of multiple materials (e.g., metal springs inside plastic housings), which complicates recycling. If the trigger cannot be easily separated and recycled independently, the whole item may be rated Red.
• Aerosols: Metal aerosols are widely collected but must be empty and depressurised to be recycled safely. If this is the case, and they are commonly collected by kerbside schemes, they may qualify for a Green or Amber rating depending on further regional processing.
• Multi-material assemblies: If packaging consists of several components with differing recyclability (e.g., a plastic bottle with a metal closure), the least recyclable component may determine the overall rating, especially if not detachable.

In all cases, evidence-based justifications for the RAG rating should be retained as part of the submission process.

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.