The long-awaited details of the Recyclability Assessment Methodology (RAM) were finally released by DEFRA on December 23rd, 2024. With implementation just days away, producers now have clarity on how they’ll need to assess and report the recyclability of their household packaging from January 2025. The first EPR return which includes RAM assessments is due by the 1st October 2025

What’s Been Announced?

The RAM framework introduces a comprehensive five-stage assessment process that will determine whether packaging components receive a red, amber, or green rating. These ratings will directly influence the modulated fees producers pay under EPR from 2025 onwards, with more recyclable packaging attracting lower fees, making this a critical financial consideration for producers.

One of the most significant aspects of the methodology is its approach to component assessment. Packaging elements that cannot be easily separated by hand must be assessed together as a single unit. For instance, a plastic bottle with a firmly adhered label would be evaluated as one component, while a bottle with an easily removable sleeve would have each part assessed separately.

The Five Stages of Assessment

The assessment process follows a logical progression through five key stages:

1. Classification: Packaging must be categorized into one of eight material types: paper and board, fibre-based composites, plastic (both flexibles and rigids), steel, aluminium, glass, wood, or other materials. For combined units, classification is based on the predominant material by weight.
2. Collection: Assessment of whether the packaging is widely collected by local authorities (75% or more), has limited collection (50-75%), or requires take-back schemes.
3. Sortation: Evaluation of whether the packaging can be effectively sorted in materials facilities, considering factors like size, shape, and material detection.
4. Reprocessing: Assessment of whether the packaging can be effectively reprocessed using current UK infrastructure, taking into account contamination and material composition.
5. Application: Consideration of whether the recyclate produced can be effectively used in new products.

Immediate Implications for Producers

The timing of this announcement, just days before implementation, presents some immediate challenges for producers. However, the methodology itself provides clear criteria for assessment, which should help organizations prepare their packaging portfolios for evaluation.

Key points producers need to consider:

• Documentation requirements are substantial, with evidence needing to be maintained for 7 years
• The assessment of inseparable components as single units will require careful analysis of existing packaging designs
• Take-back schemes may offer a route to improved ratings for packaging not widely collected at kerbside
• Technical specifications for each material type are detailed and specific
• While some materials like glass (89% collection rate) and metal cans (100% collection rate) have clear assessment paths, others like flexible plastics (14% collection rate) will require careful consideration of take-back schemes or alternative solutions.

Looking Ahead

While the immediate focus will be on completing initial assessments, the longer-term implications of RAM are significant. The methodology creates clear incentives for improved packaging design, particularly around component separability and material selection.

The framework will be reviewed and updated annually by the Technical Advisory Committee (TAC), allowing it to evolve with technological advances and changes in recycling infrastructure. These reviews will ensure the methodology stays current with market conditions and innovations in packaging design and recycling capabilities. This means producers should view their initial RAM assessments as the beginning of an ongoing process rather than a one-time exercise.

The regular review cycle also presents opportunities for producers to influence future developments through early adoption of more recyclable packaging solutions. Companies that take a proactive approach to improving their packaging recyclability now may find themselves better positioned as the methodology evolves.

Practical Steps for Compliance

To prepare for RAM implementation, producers should:

1. Review their packaging portfolio to identify which components must be assessed together
2. Begin documenting separation tests and decisions
3. Gather technical specifications for all packaging materials
4. Set up systems to track and maintain RAM assessment evidence
5. Consider how RAM ratings might influence future packaging design decisions
6. Identify any packaging with ‘automatic red’ classifications (e.g., those containing SVHC substances or integrated electrical components)
7. For composite materials, calculate and document material percentages by weight

The Broader Impact

The introduction of RAM represents a significant step toward more sustainable packaging design in the UK. By directly linking recyclability to EPR fees, it creates a clear financial incentive for improvement. This could accelerate the trend toward more easily recyclable packaging and potentially drive innovation in packaging design and materials.

How PackTotal Can Help

For producers grappling with these new requirements, PackTotal’s packaging management system provides the essential foundation for RAM compliance. The system already handles the complex relationships between packaging components, accurately tracking which elements must be assessed together – a critical requirement for RAM.

Our system’s ability to track component relationships is particularly valuable for producers with complex packaging portfolios, where manual tracking of separable versus inseparable components would be time-consuming and error-prone. The robust database structure manages your complete packaging hierarchy while maintaining the required documentation trail for regulatory evidence – crucial for the seven-year record retention requirement.

We’re actively developing comprehensive RAM assessment capabilities to integrate seamlessly with these existing features. With modulated fees directly linked to RAM ratings, having a structured system for managing your packaging data and relationships isn’t just about compliance – it’s about protecting your bottom line.

Final Thoughts

While the late December release of the RAM details has created some pressure for producers, the methodology itself appears well-thought-out and aligned with broader EPR objectives. The focus on component separability and clear assessment criteria provides a practical framework for improving packaging recyclability.

For more detailed information about the RAM requirements and how to prepare for compliance, producers should refer to the guidance published on the UK government website.

Preparing Your Business for RAM

The key now is to establish robust systems for managing your packaging data and component relationships. Organizations that take a systematic approach to RAM assessment and documentation will be better positioned to optimize their ratings and manage their EPR costs effectively.

PackTotal provides the foundational data management capabilities you need, accurately tracking packaging components and their relationships while maintaining comprehensive documentation trails. As RAM requirements evolve, we’re developing additional features to support your compliance journey.

Want to ensure your business is ready for RAM? Contact us to discuss how PackTotal can help you prepare for these new requirements or to schedule a demo.