Recycling assessment methodology: how to assess your packaging waste
An overview of the recycling assessment methodology (RAM). Under extended producer responsibility for packaging, large producers must report the recyclability of some packaging materials
This is draft guidance, shared for illustrative purposes. It is not official GOV.UK guidance. It is subject to change. Do not act based on this guidance.
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From 1 January 2025, large producers who must report packaging data under EPR for packaging will have to collect data about the recyclability of some of their packaging waste.
Find out about EPR for packaging. This collection of guidance includes information on who is affected, what data to collect and how to report
To do this, they’ll have to categorise their packaging waste using the recycling assessment methodology (RAM).
Different kinds of packaging receive different ratings - red, amber or green. This rating affects the (fee or cost) that will be charged for that packaging. This is sometimes called ‘fee modulation’.
You must assess all your packaging.
This is an overview of the RAM. There is separate technical guidance that explains how to assess and rate materials [LINK NOT WORKING].
Who has to do this
Only large producers must report their recycling assessment data.
Find out about small and large producers.
What packaging you must assess
A large producer only needs to collect and report RAM data if it is responsible for packaging that falls into either of these categories:
- household packaging
- packaging that is commonly placed in public bins
Large producers who are only sellers of packaging do not need to supply recycling assessment data.
Outputs: the red, amber, green scale
Packaging will fall into one of 3 categories:
- red packaging is difficult to recycle at scale, and higher fees will be charged
- amber packaging is recyclable but needs either specialist infrastructure or may be reprocessed with some reduction in quality or efficiency
- green packaging is widely recyclable
How this will affect what you pay (‘modulation’)
Full details of how fees will be modulated will be published in 2025.
What you must report in 2025
You need to submit recycling assessment data about all packaging that you reporting under EPR for packaging that is either:
You must enter them on the packaging data file that you submit. There are more details on how to do this in the guidance that explains how to create your file for EPR.
If you need help assessing your packaging
If you do not know what the packaging you put into circulation is made of or are missing other technical details you need to make the assessment, contact the manufacturer.
You can also contact compliance schemes for help with recording recyclability data and other packaging data. Compliance schemes will charge a fee for this.
An official register of compliance schemes will be published by PackUk in 2025.
Updates to the RAM
The RAM will be updated once a year, in line with the reporting periods for EPR for packaging.
Who decides these ratings
There will be a Technical Advisory Committee (TAC) which oversees the annual review of the RAM in line with reporting schedules.
If you want to challenge or amend a rating
If you have a material that you think should be considered recyclable or you believe a material has the wrong classification, contact the TAC.
You will need to supply evidence for your claim.
Details of this process will be published early in 2025.
How to assess your packaging
There are 5 steps to assessing packaging
- classifying - what do you have to assess, a packaging unit or the separate part of a unit?
- collection - do local authorities or other collection services pick this up?
- sorting - can this unit or component be sorted at scale?
- reprocessing - can it be reprocessed easily and without harm?
- application - is it free of any contaminants that could cause problems in the recycling process?
There are more details on each step below.
This outlines the process. There is separate technical guidance that explains how to apply these steps to each category of packaging material [LINK NOT WORKING], and gives the outputs you need to record.
1. Classifying - what do you have to assess?
The first step is to work out what exactly you must assess.
How to divide packaging units
This is often a whole packaging unit - for instance, you might assess a cardboard box using the criteria given under ‘paper or board’.
However, there may be several components to a single packaging unit. If these components can be separated by a consumer without using too much force or using tools, then you must assess them separately.
Categories of material
There are 9 categories for materials. These are often called ‘specified materials’.
- paper and board
- fibre-based composite materials
- plastic (flexibles)
- plastic (rigids)
- steel
- aluminium
- glass
- wood
- other
[LINKS WILL GO TO SUBSECTIONS OF OTHER DOCUMENT]
Each unit or component should be assessed under one of these categories.
If your unit or component is made up of more than one of these materials, assess it under the category that makes up most of its weight.
There is separate guidance on materials[LINK NOT WORKING] that has more detail. It tells you how to apply the following steps to each category of material. Use that guidance to assess whether your packaging unit or component is red, amber or green.
Drinks containers
For glass containers, other parts that come away easily should be assessed separately from the glass body.
This includes things like metal lids and screw tops. It does not usually include labels that cannot be removed without effort or tools. These should be assessed as part of the container.
For steel, aluminium and PET containers, include all the other parts in the total weight. Report the drinks container as whatever material makes up most of the weight.
Materials that are exempt
Some packaging is exempt:
- reused packaging, unless it has been imported into the United Kingdom
- any packaging exported from the United Kingdom by the producer
- medical packaging
Deposit items are also exempt, if they’re covered by a relevant schemes.
A list of relevant schemes will be published in 2025.
Automatic reds (‘problematic packaging’)
Some packaging and components of packaging always count as ‘red’ on the scale.
You must class as red packaging with:
- integrated electrical componentry or batteries that would be classed as Electrical and Electronic Equipment (EEE) - for example, boxes that include LED lights
- substances of very high concern (SVHC)
- inks excluded by the EuPIA, as noted in the Exclusion Policy for Printing Inks and Related products.
- Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)
2. Collection - do local authorities or other collection services pick this up?
Once you’ve established what packaging unit or component you’re assessing, first assess whether it is collected.
There are three kinds of collection, each with its own standard to meet.
Kerbside collection
The material or component must be collected at kerbside by more than 75% of local authorities across the UK.
Limited collection
The material or component must be collected at kerbside by more than 50% of local authorities across the UK.
Take-back schemes
The material or component is collected by a dedicated take-back scheme.
The scheme must:
- be accessible to more than 75% of the UK population
- not conflict with local authority kerbside collections
- not be restricted to one brand or product
- not require a purchase before an item is recycled
- be completely transparent that the item is recycled
3. Sorting - can this unit or component be sorted at scale?
Sorting, or ‘sortation’, is splitting packaging waste into separate waste streams for reprocessing.
You must assess whether the unit or component can be efficiently sorted at scale. There is information to help you with this in the sections on individual materials.
The RAM is focused on sorting at industrial scale at material recycling facilities. Kerbside sorting, for example consumers splitting their waste into different recycling bins, currently has no bearing on the RAM.
4. Reprocessing - can it be reprocessed easily and without harm?
Reprocessing means making new materials (‘recyclate’) from a waste stream. For example, drink cans would go into a aluminium waste stream, where they’d be processed into clean aluminium.
Each material requires a different technology to reprocess, and there can be different technologies for a single material. All these technologies have different tolerances for contaminants.
You must assess whether the unit or component can be reprocessed easily, without causing risk of harm, introducing technical challenges or compromising the quality of the stream and its output. There is information to help you with this in the sections on individual materials.
5. Application - can the recycled, reprocessed material be used in place of virgin material?
At the end of recycling and reprocessing there will be new material, which will be put an end use - for example, recycled cans become aluminium which then is then used to make more cans.
This final stage asks you to assess whether this new material can be put to use effectively. The use does not have to be the original use. There is information to help you with this in the sections on individual materials.