RAM 2027 Roadmap

UK Packaging EPR Changes, Key Dates & Recyclability Strategy

The RAM 2027 Roadmap marks a significant evolution in UK packaging EPR compliance, as the regulatory landscape continues to accelerate following two full years of pEPR reporting. Businesses must now prepare for how packaging decisions made in 2026 will directly impact future fees, with the Recyclability Assessment Methodology (RAM) playing an increasingly central role. Modulated fees are becoming more influential each year, with a widening cost gap between highly recyclable and poorly recyclable packaging. With the UK’s £1.5 billion annual packaging waste disposal costs now being redistributed based on recyclability ratings, understanding what lies ahead is essential for effective cost control, compliance, and long-term packaging strategy.

What is RAM and why does it matter for pEPR?

The Recyclability Assessment Methodology provides the framework for evaluating how recyclable your packaging truly is. It's not simply about whether packaging can theoretically be recycled. RAM assesses the entire journey: from collection systems and sorting infrastructure to reprocessing capabilities and end markets.

RAM evaluates packaging across eight material types (aluminium, fibre-based composites, glass, paper/board, plastic, steel, wood and other materials) through a five-stage process: Classification, Collection, Sortation, Reprocessing and Application. Each stage must meet specific criteria for packaging to achieve a favourable recyclability rating.

This matters because RAM assessments directly determine your modulated fees under pEPR. Packaging that scores RED on recyclability attracts significantly higher fees. Packaging designed with recyclability in mind benefits from reduced costs. As modulation becomes more stringent each year, these differences become increasingly significant.

For large producers (businesses with £2 million or more turnover handling 50 tonnes or more of packaging annually), who report household packaging, RAM assessments are now fundamental to financial planning.

Packaging that remains unassessed receives an automatic 'Red' classification, attracting escalating penalties: 20% more than the base fee in 2026/27, 60% more in 2027/28, and double (100% more) than the base fee in 2028/29. This means the cost of inaction compounds rapidly, with unassessed packaging attracting the highest possible pEPR fees.

The PackUK RAM Roadmap: Your guide to 2025-2030

The RAM Roadmap 2025-2030, published by PackUK on 1 October 2025, provides essential visibility on planned developments. The roadmap outlines annual policy alignment reviews, publication timings, materials updates and industry engagement through the quarterly RAM Technical Advisory Committee.

The current version, RAM v1.1, became effective on 1 January 2025 and included important improvements following feedback from producers and compliance schemes. These included removing the retained residue condition for paper and board packaging, and eliminating the 40% label coverage condition for plastic bottles. These changes made it easier for certain packaging formats to achieve better recyclability ratings.

Crucially, RAM 1.1 will remain in place for all H1 and H2 2026 reporting.

RAM 2027 takes effect from 1st January 2027 and will be applicable to H1 and H2 2027 reporting.

Releasing the revised methodology well in advance is important.  Producers need months to change their data systems to support accurate reporting – changes to packaging used on their products can take even longer – so forward visibility of the details of changes (short term) as well as the direction of travel (medium term) is essential to provide large producers with greater clarity and more time to plan, redesign and invest.

Importantly, this is part of the massive changes involved in the UK moving to EPR for packaging starting to settle into an annual cycle of review by the RAM technical advisory committee and material experts (as RAM 2027 takes effect they will be starting to plan RAM 2028).

We anticipate tweaks rather than major modifications – but of course, following the release of RAM 2027, ERP UK will issue a summary, outlining the key changes to our members and data service customers.

pEPR Reporting Roadmap: Key dates

January 2026: Data collection begins

From 1 January 2026, amended pEPR regulations come into force. Producers must start gathering Nation of Sale data and Self-managed Organisation Waste data. This information will be required for reporting by 1 April 2027 and 1 August 2026 respectively. Therefore, the time to establish robust data collection processes is now, not when deadlines approach.

July 2026: RAM 2027 release

PackUK is expected to publish the RAM 2027 methodology in July, setting updated recyclability criteria that will apply from January 2027. This gives businesses a six-month window to assess implications, review packaging specifications and make necessary adjustments before the new methodology takes effect.

The 2026 focus includes updates to core definitions, reconsideration of criteria removed from RAM v1, improvements to language clarity and a review of Fibre-based Composites guidance.

August 2026: Mid-year reporting

Large producers face their mid-year reporting deadline on 1 August 2026, covering January to June packaging data. This includes mandatory self-managed organisation waste data, representing an expansion of reporting requirements compared to previous periods.

Summer 2026: Labelling updates

Potential updates on mandatory labelling requirements are expected during summer 2026. Clear, accurate labelling helps consumers make informed recycling decisions and supports the broader objectives of the circular economy.

Summer 2026: Notice of Liability

The 2026 Notice of Liability will be issued during summer 2026 (the exact date is yet to be confirmed by PackUK), providing producers with their fee obligations based on packaging data submitted and RAM assessments applied. This represents the financial reality of your packaging decisions throughout the year.

Remember that producers maintain PRN (Packaging Recovery Note) obligations alongside their Notices of Liability. PRNs will usually be procured by your compliance scheme if you are registered with one or will need to be self-fulfilled if you have registered directly with the appropriate authority.

November 2026: Regulatory amendments

Potential future regulatory amendments may be debated in parliament during November. These discussions will shape the longer-term direction of packaging regulations and provide insight into what lies beyond 2026.

December 2026: 2027 fee structure

Illustrative 2027 base fees will be published in December, including separate fees for rigid and flexible plastic for the first time. This differentiation reflects the distinct recycling challenges and infrastructure requirements for different plastic formats.

Beyond 2026: What the RAM roadmap reveals

2027: Technical refinements

The 2027 RAM review will focus on rigid plastics guidance, printing inks specifications, security tags and food/cosmetics contamination guidance. These technical reviews will help businesses understand how specific packaging components affect recyclability assessments.

2028: The DRS decision point

If the Deposit Return Scheme is not operational by 2028, drinks containers made from PET plastic, aluminium and steel will become subject to pEPR obligations. This represents a significant potential shift in compliance requirements for beverage packaging producers.

2029: Bioplastics and compostables

A major review is scheduled for 2029 to assess the inclusion of bioplastics and compostables in RAM. Currently, these materials are not considered recyclable due to their interference with sorting and recycling systems. This review could fundamentally change how such alternative packaging materials are assessed.

Packaging compliance: How ERP UK can help

At ERP UK, we simplify Extended Producer Responsibility compliance through expertise, data-driven solutions and comprehensive support.

Our team understands the complexities of RAM assessments, modulated fees and the broader pEPR landscape. Whether you're managing a straightforward packaging portfolio or navigating complex multi-material formats across multiple markets, our team can help you: understand the regulations and how they apply to your products and activities; get registered; collect, check and report the right data; meet upcoming deadlines; and stay informed about further changes to the legislation.

Get in touch with ERP UK today to discuss your UK packaging compliance needs:

Contact us today:

Telephone: +44 (0)20 3142 6452

E-mail: uk@erp-recycling.org

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