The Recyclability Assessment Methodology (RAM): What Packaging Producers Need to Know

The Recyclability Assessment Methodology (RAM) is part of the UK’s proposed Extended Producer Responsibility (EPR) regulations for packaging. Currently at the second consultation stage, RAM is expected to require producers to assess and report the recyclability of their packaging from January 2025. This guide provides an overview of RAM, its potential impact, and how our data management services can support you as these requirements take shape.

What Is the Recyclability Assessment Methodology (RAM)?

The RAM has been developed by PA Consulting and Defra as a framework for assessing packaging recyclability in the UK. It evaluates each component based on the current recycling infrastructure, covering collection, sorting, and reprocessing potential. RAM assigns a Red, Amber, or Green (RAG) rating to each component, linking recyclability to EPR fees, ultimately encouraging producers to use more recyclable materials.

Red: Challenging to recycle, often due to problematic materials or designs.
Amber: Recyclable but may need specialised collection or reprocessing.
Green: Widely recyclable within the UK’s current systems.

Note: The RAM is currently not considering circularity, carbon footprint or composability, but primarily focussed on recyclability.

RAM Decision Tree

How RAM Fits into Extended Producer Responsibility (EPR)

RAM is a proposed part of the UK’s Extended Producer Responsibility (EPR) framework, which aims to shift the cost of managing packaging waste from taxpayers to producers. EPR hold producers responsible for the full lifecycle of their packaging, from design through to end-of-life disposal or recycling.

Read our EPR Guide

Under EPR, the RAM’s RAG classifications will directly impact fees, with non-recyclable packaging components likely incurring higher costs. Through this fee modulation, EPR incentivises sustainable packaging choices that align with a circular economy, reducing waste and improving recyclability.

Modulated Fees Calculation

How RAM Categorises Packaging

The RAM framework assesses recyclability through four main stages:

Classification: Identifies the material composition and separability of each component.
Collection: Verifies that components meet collection thresholds (widely collected by at least 75% of Local Authorities or limited collection by at least 50%).
Sortation: Confirms that packaging materials are sortable through industry methods, like Near Infrared (NIR) technology.
Reprocessing: Ensures the material can be reprocessed without disrupting recycling processes.
Application: Assesses whether reprocessed materials can be used in new products, replacing virgin materials and contributing to a circular economy.

Each of these stages guides producers in assigning a Red, Amber, or Green classification to packaging components. This classification then connects to the EPR modulated fee structure, applying fees based on recyclability levels for agreed-upon categories of household packaging materials.

Key Dates and Consultation Timeline for RAM

As RAM is still in the consultation phase, producers should be aware of the following timelines:

Current Stage (Second Consultation): As of November 2024, Defra is gathering industry feedback to refine RAM and ensure it aligns with industry capabilities.
Autumn (November-December) 2024: Final guidance expected based on consultation outcomes. It’s advisable to monitor updates, familiarise your business with data requirements and prepare your systems accordingly.
January 2025 (Proposed Implementation Date): If approved, RAM compliance will begin. Producers would need to categorise their packaging using the RAG system, which would then inform EPR fee calculations.
Early 2025 (Technical Advisory Committee): Alongside the RAM, there will be a technical advisory committee, to be appointed in early 2025, which will oversee an annual review of the RAM in line with the reporting schedules to ensure it reflects any changes in policy, infrastructure and technical capability.

Prepare for RAM with Clarity

At Clarity, we’re here to support Packaging Producers through the changes brought by EPR. Our Dynamic Data services, backed by our team of data experts and our Clarion data platform, help you simplify data reporting and ensure seamless EPR compliance.

We offer comprehensive support for RAM compliance, providing tools and guidance to help you track, assess, and report recyclability while the consultation process continues:

Data Collection & Classification: Working as an extension of your business we ensure your have all the necessary data and help you categorise packaging components according to RAM’s RAG criteria, setting you up for future compliance.
Guidance on Evolving Regulations: Stay informed on RAM developments with insights from our compliance experts, who keep you updated on the latest regulatory changes.

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