Recyclability assessment methodology: supplementary guidance
Read additional information that clarifies the Recyclability Assessment Methodology (RAM) if you’re an obligated producer of household packaging waste under Extended Producer Responsibility (EPR) for packaging.
This guidance provides clarification on various points in the Recyclability Assessment Methodology (RAM). It does not replace or supersede the RAM.
The RAM will be updated once per year. This document may be updated more frequently if further clarifications are needed.
Producers who must report household packaging waste under Extended Producer Responsibility (EPR) for packaging should read this information alongside guidance on the RAM when carrying out their recyclability assessments.
Read RAM guidance on:
The RAM is also available in Welsh (Cymraeg).
Reviewing your assessment
You must keep your recyclability assessments under review and update them or carry out further assessments if:
- the design, manufacture or composition of the packaging changes
- the RAM changes in a way that is likely to affect the outcome of the assessment
- there is likely to be a change to the outcome of the assessment for any other reason
Reporting obligated RAM packaging
You should use the following submission codes when reporting RAM packaging in the ‘Report packaging data’ (RPD) service:
- Household packaging (HH)
- Commonly binned packaging (PB)
- Glass Household drinks containers (Glass HDC)
Online marketplace operators
Household packaging supplied by online marketplace operators is not exempt from recyclability assessment obligations.
Read guidance about who is affected by EPR for packaging.
Drinks containers you must assess
Only household drinks containers made of glass are liable for disposal fees and therefore subject to recyclability assessment obligations.
Medical packaging
Medical packaging is defined under EPR for packaging as immediate or outer packaging on:
- medicinal products
- veterinary medicinal products
- medical devices
Immediate packaging is the container or other form of packaging that is immediately in contact with the medicinal product.
Outer packaging is any packaging into which the immediate packaging of the medicinal product is placed.
If you’re uncertain whether a product counts as medical, check with the Medicines and Healthcare products Regulatory Agency (MHRA). They publish guidance that explains how to tell if your product is a medicine.
Medical packaging must be reported under different codes:
- RED - medical
- AMBER - medical
- GREEN - medical
Fees for medical packaging which are assessed as GREEN - Medical or AMBER - Medical will be modulated in accordance with these RAM ratings.
Medical packaging assessed as RED must be reported as RED-Medical unless it is not possible to use more recyclable packaging due to legal rules and restrictions - referred to as RED by Virtue of a Regulatory Requirement (RBVORR).
If your product is RBVORR, you should report it as AMBER-Medical.
You must provide evidence to support your recyclability assessment in both cases, if you report your product as:
- AMBER-Medical as it’s RBVORR
- RED-Medical because RBVORR does not apply
Distributors
Distributors should carry out recycling assessments on packaging at the point they supply it. For example, an unfilled box or roll of printed labels. If distributors are unable to provide evidence, the packaging must be reported as RED.
Automatic RED or RED-Medical RAM ratings
You must assess all obligated packaging. If you cannot provide evidence for your household packaging unit or component, it is an automatic red.
If you do not know the material composition of packaging or components
As a producer, you are obligated to report data, including recyclability assessments, that is as accurate as reasonably possible.
If you are unsure of the material composition of your packaging or packaging components, it is your responsibility to obtain this information from your suppliers.
Recyclability labelling
The RAM does not include guidance on recyclability labelling. There are no legal obligations in relation to recyclability labelling for packaging under EPR for packaging.
Assessing packaging with 2 or more packaging components
Where household packaging is comprised of 2 or more individual packaging components, a RAM assessment should only be conducted for each packaging component separately if they are easily separable by hand.
They should be assessed together if they are only separable by mechanical sortation, by using tools or if one component is an undersized component.
Assessing labels
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
- as the predominant material by weight
Reusable and refillable items
You are only required to report household packaging that is reusable or refillable packaging the first time it is supplied.
Collection rates
You should use the collection rate percentages set out in the RAM when carrying out your RAM assessments. You should not take collection rate percentages directly from WRAP data.
Limited Collection packaging examples
The only items of packaging that meet the Limited Collection criteria at present are:
- lids from glass jars – 74%
- shredded paper – 73%
- Tetra and liquid food and drink cartons – 66%
Consumer take-back schemes
Obligated producers are not required to be members of On-Pack Recycling Label (OPRL) or their chosen takeback scheme.
Collection points
Your chosen takeback scheme must have collection points or a postal or doorstep pick up scheme available to at least 75% of the UK population. You must provide evidence of this.
Evidence of recycling
You must ensure your chosen takeback scheme can provide evidence that the material has been sent for recycling and not for disposal. PRN accredited reprocessors are recommended.
Chemical contaminants
The RAM is based on industry standards and value-chain engagement to identify chemical contaminants, such as per- and polyfluoroalkyl substances (PFAS), urea and formaldehyde, that impact on the sortation, reprocessing and application of recycled material.
The RAM uses the phrase ‘intentionally added’ to distinguish between
- products made with the listed chemical contaminants
- packaging that’s been processed using these materials but is not intended to contain these contaminants, for example recycled plastic packaging
Processing aids containing PFAS that are used during the packaging manufacturing process but are not intended to be in the final product, are not considered as intentionally added.
Assessing size criteria at sortation (including scrunching)
Products made from the following materials must measure 40mm or more in at least 2 dimensions to be assessed as GREEN at the sortation stage:
- paper and board
- fibre-based composites
- rigid plastics
Your assessment must be based on the state in which the item of packaging can reasonably be expected to end up in the recycling system and cannot take into account consumer behaviour. For example, if a user scrunches a product when disposing of it, changing its dimensions.
Paper and board
Siliconised paper
Both linerless labels and 2-ply (peel & read) labels use silicone. Any siliconised paper would receive a RED RAM rating unless a takeback scheme which meets the requirements of the RAM takeback protocol is used.
Plastic (Flexibles)
Labels
The reference to flexible plastics containing paper in the RAM guidance includes attached paper labels.
The adhesive limits that determine whether a flexible plastic is classed as AMBER under the application guidance, for example 3% for polyethylene (PE) and 5% of polypropylene (PP), are in line with CEFLEX guidelines.
Lidding films
Lidding films (welded and non-welded) on trays are easily separable by hand and should be assessed separately as flexible plastic.
Plastic (Rigids)
Collection
The examples of rigid plastic bottles, tubs, and trays are provided in the RAM to illustrate how the rules apply to common packaging types. You should classify rigid plastic packaging according to the packaging format it most closely represents. This could include packaging such as large format caps, closures and lids and made from a plastic polymer type commonly accepted at kerbside such as PET, PP and HDPE.
Attached components
Attached rigid plastic components to a packaging unit, if not easily separable by hand, count as part of the polymer content for a material and would therefore be assessed collectively as part of the main packaging unit.
Attached components made of other materials that are separable by hand should be assessed separately. For example, cardboard or FBC sleeves with a tear off strip around a wrapped pot, or a soaker pad attached to a plastic tray.
Opacity
White plastic is considered opaque. This opacity guidance applies to all rigid plastics, including caps.
Glass
Acid etching
Acid etching and coating of glass packaging does not change the glass or its ability to be sorted and is therefore not considered as part of a recyclability assessment.
Other
Compostable material, such as compostable film and envelopes would come under the ‘Other’ category.
Testing
Suppliers should follow international standards for testing or use industry-agreed standards, such as CEPI Recyclability Test Method v.2 with 4Evergreen.
The test results must be completed for each component being assessed under the RAM.
If test results show specific packaging materials classified as RED can be processed within current recycling infrastructure, you can submit these results to the RAM Technical Advisory Committee as evidence to change the RAM output.
Any change to a rating would depend the packaging meeting all other criteria for either an AMBER or GREEN rating.
Keeping records
You are required to keep records of recyclability assessments for seven years.
Compliance monitoring and enforcement
The environmental regulators will monitor producers for compliance with recyclability assessment obligations. This includes undertaking on- and off-site audits and taking enforcement actions in accordance with their respective enforcement and sanctions policies.
Technical Advisory Committee
PackUK has established a RAM Technical Advisory Committee (TAC) which will inform ongoing annual iterations of the RAM.
The RAM TAC provides technical advice on the environmental sustainability of packaging and supports PackUK to deliver iterations of the RAM. The RAM TAC will also assess selected technical queries and issues relating to packaging materials and advise PackUK of the outcome of their technical assessment.