Are you ready for the significant changes coming to packaging compliance in the UK? If you're a manufacturer or producer, the new Recyclability Assessment Methodology (RAM) will directly impact your operations, reporting requirements, and bottom line.
What manufacturers need to know
The UK government released the final version of the RAM in late 2024, creating a new compliance framework for businesses. If your company has an annual turnover exceeding £2 million and handles more than 50 tonnes of packaging in the UK, you'll need to assess and report the recyclability of your products under the Extended Producer Responsibility (EPR) regulations.
How your packaging will be rated
Under the RAM, your packaging components will receive one of three classifications:
Red: Difficult to recycle at scale – likely to incur the highest fees
Amber: Faces challenges in collection and recycling – moderate fees expected
Green: Widely recyclable in the UK – likely to incur the lowest fees
Starting October 2025, you'll need to report your packaging tonnage within these categories as part of your EPR submission.
Financial impact on your business
The introduction of Waste Management Fees (WMFs) represents a new cost centre for your business. While base fees begin in 2025, the government plans to implement eco-modulation based on RAM results from 2026.
Though specific fee structures haven't been announced, we know that:
- "Red" rated packaging will cost more than "amber" or "green" alternatives
- Fees will be modulated within material types (not across them)
- Final base fees for 2025-2026 will be released after April 2025
For financial planning purposes, these new fees should be factored into your product costing models and compliance budgets immediately.
Data collection challenges for your team
Prepare your technical and compliance teams for a substantial increase in data requirements. The whole RAM contains nearly 700 unique data points, including:
- Detailed adhesive specifications
- Precise label dimensions and materials
- Ink composition and coverage percentages
- Additives and treatments
- Material thickness measurements
This level of technical detail isn't typically maintained in product specification databases, meaning your team will need to engage extensively with suppliers to gather this information.
Strategic opportunities for your product design
Forward-thinking manufacturers are already reviewing their packaging portfolios to identify potential risks and opportunities:
- Consider redesigning packaging currently likely to receive "red" classifications
- Review your use of substances of high concern under UK REACH
- Evaluate alternatives to packaging containing PFAS (which automatically receives "red" status)
- Assess the cost-benefit of transitioning to more recyclable alternatives
Companies that act now can gain competitive advantage by reducing future compliance costs and strengthening their sustainability credentials.
Implementation timeline for your business
With the October 2025 submission deadline approaching, here's a recommended implementation plan:
- Immediate action (Q2 2025): Begin supplier engagement to collect technical packaging data
- Upon RAM update (expected April 2025): Confirm assessment methodology and finalise data collection
- Q2-Q3 2025: Complete assessments of your packaging portfolio
- September 2025: Prepare submission documentation
- October 2025: Submit required data to government
This timeline allows for the methodical collection of detailed information while accounting for the expected RAM update.
How to prepare your business today
Don't wait for the final RAM update to begin preparations. Your compliance team should:
- Create an inventory of all packaging components used across your product range
- Begin gathering available technical specifications for these components
- Identify information gaps that will require supplier engagement
- Develop a process for ongoing RAM assessments as part of your product development cycle
Taking these steps now will position your business for a more manageable transition to the new requirements and potentially lower your future compliance costs.
Source: https://www.circularonline.co.uk/category/environment-and-energy/
