In one of our earlier blog articles, we shared how eco-modulation as a concept was gaining momentum in the packaging sustainability sector, and how it was transforming the landscape of EPR fees across Europe.
We also explained how eco-modulation incentivises producers to prioritise sustainability by adjusting fees based on recyclability of products, driving innovative packaging designs. In essence, governments will determine EPR fees based on a product’s environmental impact and contribution to circularity: the less recyclable the material, the higher the fees; the more recyclable it is, the lower the fees.
As EPR laws vary by country, the goal of our series is to demystify the nuances of EPR in specific markets. To kick things off, we’re starting with a deep dive into EPR in the UK - one of the main focus areas of our current campaign (which we cover further towards the end of this article).
The EPR developments in 2024, alongside the knowledge that more updates will be rolling in, topped by the complex and evolving legislation governing UK EPR and RAM, have triggered a wave of questions across the packaging industry.
The consensus shared by our clients is that they are struggling to navigate the EPR UK ‘legislation jungle’. Brand owners want to understand the relationship between EPR UK and eco-modulation, including how the RAM applies. Furthermore, they are feeling the pressure of the upcoming deadline to submit their EPR UK reports, especially given the recent publication of the detailed requirements. This urgency adds to their need for clarity on the specific obligations that apply to them and the implications of non-compliance.
Our guide aims to break down these complex, moving parts into clear, actionable information, so brand owners understand what they need to do to stay compliant with both EPR and RAM. We also explain how our intuitive sustainable packaging management platform supports RAM compliance specifically for the UK market.
Lastly, we’ve turned the most frequently asked RAM-related questions from our clients into a helpful FAQ section, designed to clear up confusion and address some of the common rumours or myths surrounding RAM.
Keep reading to learn more about EPR and RAM in the UK, and the steps your brand needs to take to stay compliant.
Overall, the timelines vary depending on the size of an organisation.
January 2023: Companies are obligated to collect packaging data in line with EPR regulations
Large Organisations
2024 Data: By 1 October 2024: Submit data collected from 1 April to 30 June 2024.
2025 Data: By 1 April 2025: Submit data collected between 1 July and 31 December 2024. By 1 October 2025: Submit data collected from 1 January to 30 June (for the first half of 2025).
Small Organisations
2024 Data: By 1 April 2025: Have to collect and submit their 2024 data
2025 data: By 1 April 2026: Submit data collected from 1 January to 31 December 2025
Large Producers
Large Producers are required to report their packaging data biannually.
Small Producers
Small producers must report their packaging data on an annual basis.
The UK Government requires early data collection to allow companies to:
Anticipate Financial Liabilities
Collecting packaging data in advance enables companies to forecast potential modulated fees, providing a window to adjust materials or formats ahead of implementation.
Ensure Regulatory Readiness
Initiating data tracking now helps businesses establish robust reporting systems, minimising the risk of future non-compliance with EPR requirements.
Evaluate and Improve Sustainability
Early data gathering supports an internal assessment of packaging recyclability, allowing time to transition to more compliant and sustainable options before fees are enforced.
You may need to pay a late fee.
Company size dictates whether a UK organisation that supplies or imports packaging needs to comply with EPR laws
Small Organisations
An organisation falls under this threshold if it:
Large Organisations
An organisation falls under this threshold if it:
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This depends on the scale of your organisation.
Large Producers are required to report:
Small Producers are obligated to report:
PA Consulting and Defra.
Where is RAM UK Applicable?
England, Wales, Scotland and Northern Ireland.
What is RAM?
It's a framework/set of guidelines for evaluating how recyclable different packaging formats and materials are in the UK.
Why Is There a Need for RAM?
To provide a consistent and transparent way to assess the recyclability of packaging across the UK. This enables a common framework that all packaging can be assessed against.
Primary drivers of RAM include improving recycling rates, supporting a circular economy, and implementing elements of EPR regulations.
RAM is the modulating principle for the EPR scheme. The EPR sets the base fees which producers have to pay this year and then from 2026, they have to pay modulated fees which are impacted by how recyclable their packaging is.
RAM aims to incentivise recyclable packaging through potential modulated fees.
Liable producers. A producer is a liable producer in relation to an assessment year if, in the calendar year ending on the 31st December preceding the start of that assessment year, the producer:
23 December 2024: RAM was first published.
1 January 2025: Liable producers who supply household packaging must assess the recyclability of that packaging and report the results of the assessment to the environmental regulator.
What are the Key Reporting and Data Submission Timings under RAM?
Generally, RAM packaging data reporting is required twice a year at an interval of 6 months.
By October 2025: Packaging data from the first half of the year must be reported.
By April 2026: Packaging data from the second half of the year, packaging data must be reported.
(As stated on Defra’s guidance page)
2026: Modulated fees will apply (as stated in Article 64 of the law).
Note that EPR and RAM reporting cycles are synchronised because they are not separate entities.
RAM will be reviewed and updated where appropriate once a year, in line with reporting periods for EPR for packaging. This is to allow for innovation, evolving market conditions and regulatory changes.
Household packaging.
Article 11 of the law lists the exemptions to this:
How is the Recyclability of Packaging Evaluated under RAM?
RAM focuses on evaluating recyclability across the four packaging end-of-life stages.
That is Collection, Sortation, Reprocessing and Application. The goal is to transform waste material and replace virgin materials on an industrial scale.
How Many Categories of Material are Assessed by RAM?
10 materials.
Paper and Board, FBC* - Non LC**, FBC - LC, Plastic - Rigid, Plastic - Flexible, Steel, Aluminium, Glass, Wood, and Other.
*Fibre-based composite
**Liquid carton
Different kinds of packaging will receive different ratings - red, amber or green. This rating affects the disposal fee that will be charged for that packaging. This is also called ‘fee modulation’.
The calculation of these fees generally follows the structure:
Modulated Fee = (Weight of Material) × (Base Fee per Material) × (Recyclability Factor)
Breakdown of the Formula Components:
Weight of Material: Refers to the total tonnage of a specific packaging material that the producer has placed on the market during the reporting period.
Base Fee per Material: Each type of packaging material (such as paper, glass, plastic, or metal) is assigned a base fee. These base fees are set by the relevant regulatory authority and reflect the environmental impact associated with that material. Materials with higher environmental burdens typically carry higher base fees.
Recyclability Factor: This factor adjusts the total fee according to how recyclable the material is within UK waste systems. Readily recyclable packaging will be assigned a lower factor (e.g., 0.5), reducing the total fee. Conversely, materials that are difficult to recycle will be assigned a higher factor (e.g., 2.0), resulting in increased costs.
On 1st April 2025, at the Joint Stakeholder Forum, the Department for Environment, Food and Rural Affairs (Defra) shared new details on the evolving RAM – the framework that will influence how producers are charged under EPR.
The proposed fee modulation system will use a tiered approach to encourage recyclable packaging and phase out less sustainable materials over time.
According to the proposal:
Red-rated packaging (low recyclability) will face increasing penalties:
Amber-rated packaging is proposed to maintain the standard base fee.
Green-rated packaging may benefit from a discount, funded by the surplus from higher Red fees.
Ultimately, the overarching goal of this modulation system is to accelerate the shift within the industry towards the use of fully recyclable packaging by making unrecyclable materials increasingly costly for producers.
It's crucial to keep in mind that the modulation factor timeline is likely to undergo further changes before the final policy statement is officially released. Businesses should stay informed about these developments as they plan their future packaging strategies.
The purpose of this fee modulation structure is to provide a financial incentive for producers to adopt more sustainable packaging choices. By linking fees to recyclability, the system encourages producers to minimise environmental harm and aligns with the UK’s strategic objectives for a circular economy.
The most recent indicative base fee levels were published in September 2024, with fees varying by material type and adjusted to reflect each material’s environmental performance.
The result of the recyclability assessments for each packaging component can be grouped in 3 different categories: Red, Amber or Green.
Red packaging: triggers the highest fees as it's the most difficult packaging to recycle at scale, due to its design or materials.
Amber packaging is recyclable but may pose obstacles during collection and sorting.
Green packaging is largely recyclable in the current UK infrastructure and attracts the lowest fees.
These categories adjust the base fee applied to each material, providing financial incentives to minimise waste and encourage the adoption of recyclable materials.
Starting from 1 January 2025, obligated producers supplying household packaging are required to evaluate the recyclability of that packaging and submit the assessment results to the environmental regulator.
The RAM is the methodology organisations use to assess the recyclability of each material component of the household packaging they supply.
RAM is an essential aspect of the EPR concept and the key method for calculating modulated fees/their associated fees. Moreover, RAM’s, Red, Amber and Green classifications will influence EPR fees.
How Does Recyda’s Software Support EPR and RAM Compliance in the UK?
Our software simplifies the management of new EPR UK requirements by digitising the requirements, enabling companies to apply their entire portfolio to the new rules and gain transparency and visibility into their financial obligations. We also support businesses identify potential overpayments and explore cost-saving opportunities.
We're pleased to announce that our platform now fully supports the UK RAM guideline, enabling producers to efficiently assess the recyclability of their packaging ahead of crucial EPR reporting deadlines.
The Benefits of Digitising Your RAM Compliance
Our digital implementation of the RAM guidelines provides a streamlined way to comply with what is commonly viewed as a complex and evolving regulation.
More benefits include:
Cost Savings Insight: Ability to identify packaging designs that help you gain insight into what triggers higher EPR fees and uncover key cost drivers - allowing you to realise potential savings before high fees - due to eco-modulation - in the UK come into effect.
Time and Resource Optimisation: There are hundreds of requirements when totalled across different packaging materials and components. Our intuitive system relieves you of the stress of manual evaluation by automatically assessing all your packaging components and translating your data into the appropriate Red/Amber/Green categorisation.
Scalable Review Capability: While manual assessments are stressful, time-consuming, and more prone to errors, our software efficiently evaluates multiple SKUs simultaneously.
Ongoing Compliance Support: RAM will update regularly, and you will need to stay updated. Our ruleset is constantly updated to reflect the latest regulatory changes. This ensures your packaging data meets all compliance requirements ahead of reporting deadlines.
Packaging Strategy Development: Use assessment insights to prioritise packaging redesign efforts where they’ll have the greatest impact.
Decision-Making Empowerment: Our detailed reports clearly explain why your packaging received its specific rating, empowering you to make informed, data-driven decisions.
All in all, by integrating RAM assessments directly into your packaging development workflow, you can make informed decisions that align with both regulatory requirements and your sustainability goals.
As I understand it, we need to evaluate each SKU and categorise them into Red, Amber and Green groups. Does a separate assessment need to be made for each item we sell in the UK?
If the Consumer Sales Unit (CSU) or component consists of separate components or materials, each item of packaging or component needs to be assessed and reported.
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What would be the consequence if I don’t evaluate all my items by October 2025?
According to Defra’s Q&A that was published and shared internally, if producers cannot complete a RAM assessment of packaging placed on the market by the H1 2025 reporting deadline, all packaging components will be flagged as red. That means the maximum price will be required to be paid.
In addition, the law - The Producer Responsibility Obligations 2024 - also provides these non-compliance measures:
I heard there’s a RAM update coming in April 2025. Do you know how often the RAM will be updated after that? I’m a bit concerned that we might need to re-evaluate our entire packaging portfolio every time there’s a change.
Defra released a Circular Economy Roadmap, which is subject to change. On it we see after the RAM update is published in April, there is a scheduled RAM update in October 2025.
What impact could the modulation have on each packaging component?
Impact Assessment*
Red-rated packaging (low recyclability) will face increasing penalties:
Amber-rated packaging pays the standard base fee.
Green-rated packaging will get a discount on the base fee, proportionate to the excess fees generated from less recyclable ("Red") packaging.
The goal? To accelerate the shift toward fully recyclable packaging by making unrecyclable materials more costly to use.
*Not finalised yet, Defra published this guidance to its stakeholders on the 1st of April.
We’ve written a report to support you in navigating the significant regulatory developments in 2025. Whether you are a brand owner or another stakeholder across the packaging value chain, you will benefit from learning how to support your business in staying compliant and maintaining a sustainable competitive edge. our report covers:
Future-proof your packaging and ensure compliance by downloading our full report here.