RAM recap
PackUK will publish a new RAM version each year to keep criteria aligned with reprocessing capacity and industry developments. RAM v1.1 still applies to all packaging placed on the market during 2026, and will be invoiced next year.
RAM assessments cover household packaging (including glass drinks containers) and packaging commonly found in public bins.
The eco-modulation approach across Years 2 and 4 of pEPR as set out by PackUK is as follows:
| EPR Year 2 (2026/27) |
EPR Year 3 (2027/28) |
EPR Year 4 (2028/29) |
| 20% Penalty for Red Packaging |
60% Penalty for Red Packaging |
100% Penalty for Red Packaging |
What has changed in RAM 2027?
RAM 2027 brings mostly structural changes: it now spans two GOV.UK pages (an overview page and material-specific guidance), shows every possible rating upfront under each material heading, and provides clearer rules for reporting separate components versus integrated packaging. For materials capped at Amber, namely flexible plastics, wood, and ‘other’ materials, no material-specific guidance is provided.
Beyond formatting, several substantive changes stand out:
PFAS automatic red criteria is updated
No longer will packaging be Red if it contains “intentionally added” PFAS, but now packaging will only be Red where it contains over 1ppm of total PFAS, or in the case of food packaging, if it exceeds 25ppb for any individual or total PFAS. The latter threshold is specifically derived from the EU’s Packaging & Packaging Waste Regulation, highlighting an intent from PackUK to oversee greater UK-EU alignment. This also shifts from judging intent to judging measurable chemical content, pushing the conversation from recyclability toward material safety and chemical circularity more broadly.
Food contamination considerations return
RAM v1 originally flagged paper and fibre-based composite (FBC) packaging as Red if product residue such as food couldn’t be easily removed, but this was removed in RAM 1.1 in an effort to simplify it. RAM 2027 reinstates it in a narrower form: paper or FBC packaging designed to have food heated inside it is now Red, reflecting concerns around food contamination and practical recyclability.
Greater emphasis on packaging components
Trigger sprays with certain contaminants, and labels that won’t wash off in a 70–90 degree hot wash can now determine whether a rigid plastic clears Red, placing greater importance on packaging components beyond the predominant material type.
Flexible plastics remain capped at Amber
Flexible plastics remain unable to achieve a Green rating as RAM 2027 confirms they are not collected or recycled at scale via kerbside infrastructure, though the Simpler Recycling regulation mandates mandatory flexible plastics collections at kerbside in England from April 2027. Industry has pushed back on the cap, arguing it is counterproductive to creating a stable market that can encourage investment in further reprocessing capacity for this material.
Colour requirements tightened for PET bottles but not for HDPE
PET bottles are now Red unless clear or translucent light blue, a stricter bar than v1.1, which allowed Amber for dark blue, dark green, or brown. HDPE moves the other way, where clear or white packaging is only Red for direct printing (excluding batch codes or expiry dates), meaning colours that currently receive Amber (light blue, green, light tints, or opaque) can now theoretically reach Green, since they are no longer flagged as Red or Amber traits.
Key takeaways
RAM 2027 keeps the same red, amber, green framework as before, but tightens or loosens the rules depending on the material — from stricter PFAS and PET colour thresholds to a more lenient approach for HDPE. With the first reporting deadline falling on 1 October 2027, now is the time for producers to review how their packaging will be rated under the new methodology.
Need help understanding how RAM 2027 affects your packaging and pEPR fees? Visit our RAM web page to learn more about our assessment support, or enquire about our RAM service today and let our team guide you through the transition.
