Regulatory Position Statement for Packaging RAM Reporting

Introduction

On Friday 27th June, the regulators published a Regulatory Position Statement (RPS) which makes the Recyclability Assessment Methodology (RAM) reporting optional for H1 2025 data.  This follows industry feedback about the limited time and resource in preparing for RAM.

What is RAM?

RAM requires Packaging Large Producers to assess the recyclability of household packaging supplied.  RAM will be used to modulate the Household Packaging Waste Disposal (HPWD) costs from 2026 to 2029.

What are the key points of the RPS?

1. The Environment Agencies will not take enforcement action if;

• • The RAM assessment is not reported for the H1 2025 data; or
  • The RAM assessment for H1 2025 is reported by 1^st April 2026. 

Please note;

1. All other H1 2025 data requirements must be reported by the legal deadline of 1^st October 2025.
2. The H2 2025 data must be reported by 1^st April 2026 for the RPS to be relied upon.

2. Large Producers who supply household packaging will need to split plastic packaging by flexible and rigid plastics in the H1 2025 data submissions.

1. RAM assessment reporting will be mandatory for the H2 2025 data submissions.

If Packaging Large Producers do not report their RAM assessment for the H1 2025 data, PackUK will treat a producer’s H2 2025 RAM assessment as sufficient evidence of the producer’s packaging recyclability for the whole year of 2025.  The RAM assessment obligations for H1 2025 will be extrapolated from the H2 2025 data.  Producers should consider the best approach to take as the RAM assessment for the

2025 data will affect the Household Packaging Waste Disposal costs invoiced in October 2026 by PackUK.

How can ERP help?

We assume that most producers will wish to ensure the significant HPWD costs are based on the fullest set of data as possible.

Therefore, ERP UK are ensuring our members can report their H1 2025 data in our online portal, with or without the RAM assessment.

Additionally, ERP UK’s Data Services Team will continue with the services set up to support producers with the RAM reporting requirements.

Want to know more?

Visit our Packaging EPR for Large Producers: Recyclability Assessment Methodology (RAM) page here

Related services

Extended Producer Responsibility for packaging: ERP UK is an expert in Extended Producer Responsibility (EPR). If you have you been directly affected by the UK’s EPR reforms – we can help!

Visit our EPR webpage for further details

Packaging compliance: Our packaging compliance scheme simplifies all aspects of environmental compliance for companies handling packaging. Our solution helps you to accurately collect and submit your data as well as ensure that the amount of recycling you are responsible for is achieved.

Visit our packaging webpage for further details

Data services: Our data service team produces accurate data reports, which ensure that companies stay compliant, helping reduce their costs. We will work with you to understand your business, products, packaging flows and raw data. Our team undertakes these complex tasks on your behalf to ensure you’re submitting accurate data to comply with the legislation.

Visit our Data Services webpage for more details

About ERP UK

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Contact us today:

Telephone: +44 (0)20 3142 6452

E-mail: uk@erp-recycling.org

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