Recyclability Assessment Methodology (RAM)
Need to know
- From 1 January 2025, obligated producers must assess the recyclability of the household packaging they supply using the RAM, available here. Full government guidance can be found here.
- The RAM assessment outputs are classified by a RAG categorisation. The RAG category assesses how the material packaging unit would pass through the stages of recyclability: (1) Classification, (2) Collection, (3) Sorting, (4) Reprocessing, (5) Application.
- Green: packaging is widely recyclable across the UK.
- Amber: packaging may involve challenges during collection or sorting; may require specialist infrastructure during reprocessing; the output quality of the recyclate may be affected; or there may be secondary material loss.
- Red: packaging is difficult to recycle at scale in the UK. This includes integrated electrical components or batteries, substances of very high concern (SVHC), and PFAS substances.
- The RAG category of the material packaging unit will be used to determine the Fee Modulation Category. Modulated fees will be introduced in Year 2 (2026/27).
Should know
- Each material packaging component that can be separated by hand must be assessed separately in the RAM; components not easily separable will be assessed collectively, based on the predominant material. Examples of this can be found in the slides above.
- In spite of how they are assessed in the RAM, each packaging component (i.e., each unique material type) must be separately reported within the Report Packaging Data (RPD) online service. Examples of this can be found in the slides above.
- The RAM will be updated on an annual basis, to reflect regulatory changes in the collection and packaging reforms.
Actions
- From 1 January 2025, obligated producers must assess the recyclability of their packaging using the RAM. Defra recommend that this should be completed as soon as possible.
- Assessment data, alongside tonnages, for H1 2025 must be reported within RPD by 1 October 2025.
- Any questions or challenges can be sent to eprcustomerservice@defra.gov.uk, or to a relevant compliance scheme.
Illustrative Base Fees (v3)
Need to know
- Under the pEPR scheme, packaging disposal cost fees are charged to producers by cost per tonne across 8 packaging categories. NB: aluminium, steel and PET plastic drinks containers in scope of a Deposit Return Scheme (DRS) are excluded.
- Aluminium: 435
- Fibre-based composite: 455
- Glass: 240
- Paper or board: 215
- Plastic: 485
- Steel: 305
- Wood: 320
- Other: 280
- Iterations of illustrative base fees have been published in August, September, and the latest in December, to provide estimates for producers. The third version has reduced the previous ranges to a single estimated figure per category, which can be viewed here and are referenced above.
- Further illustrative base fees may be released if updated reporting data results in significant changes to current estimates.
- The final base fees are due to be published by July 2025. The final fees will use the full set of Reporting Packaging Data for 2024 submitted by obligated large producers by 1 April 2025.
Should know
- The latest illustrative base fees have been calculated using the adjusted Report Packaging Data for H1 2024 and the final scenario in Defra’s Local Authority Packaging Cost and Performance Model (LAPCAP), which calculates the estimated disposal cost payment to be made to local authorities (LAs).
- These fees remain an estimate: their calculation does not include data from producers who haven’t yet reported or those who have reported after 19 December 2024, or account for seasonal differences which may lead to increased packaging reported in H2 2024.
- Base fees will apply to Year 1 (2025/26) payments, invoiced in October 2025. Modulated fees will be introduced from Year 2 (2026/27). An update on modulated fees is expected in due course.
- An impairment cost of 6% may be added to the final invoice. BRC and other industry bodies are seeking clarification and will share further information when available.
- Producer invoices will be used to pay LAs to cover the disposal costs of the collection, handling, treatment and disposal of household waste across the 8 categories from November 2025. Updated LA payment estimates will be released in April 2025.
Actions
- Obligated large producers must report packaging data for 1 July to 31 December 2024 by 1 April 2025.
- The Scheme Administrator will issue invoices to obligated producers in October 2025.
If you have any comments or questions on the RAM, illustrative base fees, or anything else relating to pEPR, please get in touch with Naomi Brandon-Bravo.
