RAM V1.1: 7 Key Rules UK Packaging Producers Must Follow

June 23rd, 2026

RAM is the framework that determines whether your household packaging is rated Green, Amber or Red. Those ratings are not just an environmental label. From 2026, pEPR fees are modulated based on recyclability. Red-rated materials attract a 1.2x fee multiplier in 2026/27, rising to 1.6x in 2027/28 and 2.0x by 2028/29. Green-rated packaging pays less.

The RAM V1.1 guidance UK for the Recyclability Assessment Methodology (RAM) introduces critical updates that packaging producers must understand under UK packaging EPR (pEPR). First published by PackUK in December 2024 and updated through April 2026, the guidance directly affects how packaging is assessed, how recyclability ratings (Green, Amber, Red) are applied, and how modulated pEPR fees are calculated.

This blog revisits the Recyclability Assessment Methodology (RAM) fundamentals, unpacks the supplementary guidance published on GOV.UK, and sets out seven key rules every packaging producer should understand before their next Environment Agency submission. Understanding these updates is essential to avoid unnecessary costs and ensure your data is accurate, defensible and compliant.

Why This Matters Now

Reports must be submitted to the Environment Agency on or before 1^st October each year, for the period from 1^st January to 30^th June in that year and on or before 1^st April each year, for the period from 1^st July to 31^st December in the previous year.

If you haven’t carried out your RAM assessments and therefore submitted as Red, you may be incurring more costs than you need to.

PackUK has also confirmed a roadmap to 2030, with annual updates covering rigid plastics guidance, printing inks, fibre-based composites and food contamination. Bioplastics and compostables are under review for potential inclusion from 2029. The update cycle will be July each year. The next version RAM 2027 will apply to packaging supplied in 2027.

The 7 Essential Points from the RAM V1.1 To Remember

1. Automatic Red Ratings: When They Kick In

Some packaging components receive an automatic Red rating regardless of material type. This is set out clearly in the RAM V1.1 guidance published on GOV.UK.

Such as packaging or components with intentionally added;

integrated electrical components or batteries that would be classed as Electrical and Electronic Equipment (EEE) - for example, boxes that include LED lights
any of the substances of very high concern (SVHC) above the specified thresholds set out under UK REACH
inks that are not manufactured in compliance with the EuPIA Exclusion Policy for Printing Inks and Related products
any household packaging within scope of the RAM which has not been assessed or where the detail required to undertake an assessment isn’t available

2. Multi-Component Packaging: Separate or Together?

RAM assesses multi-component packaging based on how easily the components can be separated by hand. If a consumer can separate them without tools or effort, each component is assessed individually. If they cannot, the packaging is assessed as a single unit, this distinction matters. Producers should map their multi-component formats carefully and consider whether design changes could unlock better ratings.

3. Attached labels

Where labels are attached to another component and are not easily separable by hand they are to be assessed collectively with the predominant material.

Attached labels are defined as labels applied to packaging with adhesives that prevent the label from being easily removed by the consumer.  This means that the label will remain attached throughout the sortation process and should be assessed, together with the component it is attached to and as the predominant material by weight.

However, this may vary depending on the component in which the label is attached, and should therefore be assessed on a case-by-case basis.

4. The 40mm Size Threshold

For paper, board, fibre composites and rigid plastics, there is a 40mm size in at least two dimensions threshold for green sortation ratings. Components smaller than 40mm in their smallest dimension may not be reliably sorted at materials recovery facilities. The RAM V1.1 guidance reflects this in the rating.

Small components, should be checked against this sortation requirements. It is a detail that is easy to overlook but could shift a rating from Green to Amber.

5. Specific Collection Rate Percentages

To meet the widely collected at kerbside criteria, an item of packaging or component must be collected by 75% of local authorities

These are worth checking carefully. Fibre-based composites such as Tetra cartons, for example, sit in the Red category unless there are dedicated take-back schemes available that meet the specified criteria of the take-back protocol, liquid food and drink cartons (fibre-based composite) are currently collected by 66% of local authorities,

This reflects real-world collection infrastructure rather than theoretical recyclability.

Producers using these materials should factor the collection rates into their assessment expectations. A material that is technically recyclable may still carry an Amber rating if the collection infrastructure doesn't support it at scale.

6. Takeback Scheme Evidence

Producers who want to claim an Amber rating on the basis of a takeback scheme face a specific evidence burden. Producers must have evidence that collection points such as an in-store takeback point, or at a household waste recycling centre are accessible to at least 75% of the UK population or households within a 5-mile radius. This must be verified using mapping software and population density overlays.

That is a high bar. A takeback scheme that covers major urban centres but misses rural populations may not meet the threshold. Producers also need to show that the takeback scheme carries no brand or purchase restrictions, meaning any consumer can use it regardless of where they bought the product.

If you are relying on a takeback scheme to support a rating, the evidence package needs to be robust and up to date.

7. Record-Keeping: The Seven-Year Rule

RAM assessments must be retained for seven years. This is not a suggestion. It is a legal requirement under pEPR, and it applies to all supporting evidence, including supplier documentation, takeback scheme mapping and any testing data used to support a rating.

Producers should have a clear process for storing and retrieving RAM records. In the event of an audit.

RAM V1.1 Things to Remember: When Should You Review Your RAM Assessment?

PackUK's guidance is clear: producers should review their assessments whenever packaging composition changes, when RAM methodology is updated, or when the likelihood of a different outcome changes such as with annual RAM guidance revision. That last point is important. If a material that was previously Amber is now Red under the updated guidance, waiting until the next scheduled review could be expensive.

A growing number of producers are reassessing packaging formats proactively, before costs crystallise.

How Can ERP UK Help?

ERP UK's packaging compliance and data services are designed to help producers keep their RAM assessments and submissions accurate, defensible and audit ready. From reviewing your packaging data against the latest RAM V1.1 guidance to submitting to the Environment Agency our team works with large producers across every sector.

Whether you are preparing for your next submission or reviewing existing assessments in light of the PackUK supplementary guidance, we can help you understand your position and take the right steps.