RAM version 1.1 Guide

Your guide to the new RAM rules and how to comply

The UK's packaging waste landscape has recently become significantly clearer. The update in May 2025 of the Recyclability Assessment Methodology (RAM) to v1.1 aims to improve recycling consistency across packaging producers and materials. PackUK, the scheme administrator for the UK’s packaging EPR (pEPR) scheme, carried out a RAM simplification sprint in February to reduce the complexity of the RAM and increase producers’ ability to fully complete RAM assessments this year.

The regulatory reality: what's changed

Since 1 January 2025, RAM v1.1 has been available for large producers. That means companies handling over £2 million turnover and 50+ tonnes of packaging annually. But here's the crucial update many businesses have missed: following the regulatory changes, H1 2025 RAM reporting is now optional, with the deadline of 29 August 2025. However, H2 2025 reporting remains mandatory, with submissions due by 27 February 2026.

This breathing space is welcome news for businesses grappling with complex packaging portfolios. Consider a rapidly growing beauty brand shipping thousands of products monthly, or an events company managing everything from promotional materials to catering packaging. The simplified timeline allows proper preparation rather than rushed compliance.

The new methodology categorises packaging across eight material types: aluminium, fibre-based composites, glass, paper/board, plastic, steel, wood, and other materials. Each receives a Red, Amber, or Green classification that will directly impact Household Packaging Waste Disposal fees from 2026 onwards.

What RAM v1.1 actually simplifies

The updated methodology addresses real-world challenges that businesses faced with the original framework. Key improvements include removing the retained residue condition for paper/board packaging that previously triggered automatic Red ratings. This is excellent news for food retailers whose cardboard packaging might have minor contamination. The 40% label coverage condition for plastic bottles has also been removed, benefiting beverage companies and online retailers shipping products in labelled containers.

For e-commerce sellers managing diverse product ranges, from electronics packaging to cosmetics boxes, the clearer guidance means fewer grey areas and more consistent assessments. A builder's merchant, for instance, can now more easily assess everything from cement bag packaging to smaller hardware item containers using standardised criteria.

The assessment process demystified

RAM v1.1 follows a logical five-stage process:

Classification categorises materials into the eight defined categories. Collection assesses whether packaging is widely collected (75% of UK local authorities) or has limited collection (50% coverage). Sortation evaluates whether materials can pass through current sorting facilities, typically requiring items to be at least 40mm in two dimensions. Reprocessing determines if materials can be effectively recycled in existing systems, whilst Application assesses market demand for the resulting recycled materials.

The rating outcomes are straightforward:

Green: Widely recyclable in the current UK infrastructure

Amber: Generally recyclable but faces some challenges

Red: Difficult to recycle at scale due to specifications

Escalating costs

Also announced in June was the approach to eco-modulation of fees for 2026/27, 2027/28 and 2028/29. A significant escalation factor applied to base fees for packaging assessed under RAM as Red. This starts at 1.2 in 2026/27, rises to 1.6 in 2027/28, and in 2028/29 will be 2.0. Conversely, fees for packaging assessed under RAM as Green will be reduced using the additional income from Red.

The cost of doing nothing

Here's where the financial reality bites. Unassessed packaging automatically receives a Red classification and will attract higher HPWD fees in 2026. Although the 2025 base fees published in June were nearly all reduced from December 2024 estimates, companies still face substantial costs for the management of their packaging within the household system. Adding costs for 2026 by not assessing packaging or by using ‘difficult to recycle at scale’ (red) packaging where alternatives exist will look like increasingly poor business decisions.

A fashion retailer shipping garments in mixed-material packaging could see significant fee variations between properly assessed Green-rated recyclable mailers versus Red-rated complex multi-layer alternatives. For businesses already operating on tight margins, these differences matter.

Automatic red flags to avoid

Certain packaging characteristics trigger automatic Red ratings: integrated electrical components, substances of very high concern (SVHCs), non-compliant inks, and PFAS materials (except for aluminium, steel, and glass). Technology companies shipping products with electronic components in packaging, or cosmetics brands using certain chemical treatments, need particular attention here.

ERP UK's practical solution

ERP UK's LAMB data service provides access to the RAM Checking Tool with expert support, while their Full RAM service offers complete assessment outsourcing. With 30+ years of compliance expertise serving over 700 businesses, ERP UK transforms regulatory burden into manageable, actionable insights.

The data-driven approach ensures accurate classifications backed by robust methodology. That’s crucial when fees depend on precise assessment. For businesses lacking internal expertise or resources, this partnership approach offers both compliance certainty and strategic value.

Timeline and next steps

The implementation timeline is clear:

RAM v1.1 is now live!

• H1 2025 reporting deadline: 29 August 2025 (RAM assessments encouraged but optional)
• First HPWD (Household Packaging Waste Disposal) invoices: October 2025
• H2 2025 reporting deadline: 27 February 2026 (RAM assessments mandatory)
• First HPWD (Household Packaging Waste Disposal) invoices with eco-modulated base fees: H2 2026 (timing TBC)

Large producers must split plastic packaging by flexible and rigid categories for H1 2025 submissions, a detail that could affect manufacturers using both film wrapping and rigid containers.

The bigger picture

This isn't just about regulatory compliance. RAM v1.1 represents the UK's commitment to circular economy principles, shifting packaging waste costs from taxpayers to producers while incentivising sustainable design choices.

Smart businesses view this as an opportunity, not a burden. By understanding recyclability implications early, companies can influence packaging design decisions, potentially reduce long-term costs, and demonstrate environmental leadership to increasingly conscious consumers.

The rules have changed, but the tools are available, and the timeline is manageable. The question isn't whether to comply, it's how quickly you can turn these regulatory requirements into a competitive advantage.

How can ERP UK help?

We help businesses of every size.

ERP UK provides leading expertise, data-driven solutions, and take-back programmes that simplify EPR for organisations navigating increasingly complex environmental regulations.

Related services

ERP UK's Packaging EPR for Large Producers: Recyclability Assessment Methodology (RAM) - visit the webpage here

Extended Producer Responsibility - visit the webpage here

About ERP UK

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E-mail: uk@erp-recycling.org

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