Recyclability Assessment Methodology
Recyclability Assessment Methodology
Recyclability Assessment Methodology (RAM) – Introduction
The Recyclability Assessment Methodology (RAM) will evaluate packaging to ensure that it can be recycled and transformed into new products. All packaging that is placed on the UK market and reported as household waste in 2025 will be reviewed using details on the RAM. From 2026, modulated fees will be applied accordingly to each packaging format.
Packaging will be rated as either green, amber or red. Green suggest that the packaging has a recognised path for collection, sorting and recycling and will have lower fees applied than less recyclable materials, which will be rated amber or red. Producers will need to report their data from October 2025 with fees being applied from 2026 onwards.
RAM v1.1 – Observations
Following work and consultations during 2024, an initial draft copy of the RAM was released in December 2024. At this point, DEFRA listened to some of the comments from RECOUP, from RECOUP members, and from other organisations.
There then followed an initial launch to trade bodies of a draft final version on 8th April 2025, then the most recent version of the DEFRA Ram was released on 28th April 2025. Comparing the most recent releases; no significant changes to anything in the ‘plastics’ sections, from the draft version 1.1 which we had seen, and the final 28 April version. Minor changes include the removal of the ‘boxes’ around the items marked for ‘2025 assessment’, which now form part of the main text.
However, there are more than a few outstanding queries and questions, which we have communicated to DEFRA, on the latest version.
One pressing issue is the materials or combinations which have been removed from the RAM for ‘2025 assessment’. This means that the following are now deemed acceptable: the comparison is with RECOUP Recyclability By Design guidelines (RBD) for plastic packaging recyclability:
Attached label or sleeve over 40% (bottle) 60% (PTTs) of surface area
- Amber in RBD
PET trays with PE seal layer
- Red in RBD
HDPE items with fillers eg. Talc, CaCO3
- Red in RBD
Attached labels or sleeves comprised of paper
- Amber in RBD
Of the comments submitted by RECOUP following the initial ‘version 1’, we were pleased that DEFRA accepted some RECOUP recommendations, including;
– RAM classifies any PET pot/tub/tray with anti-blocking agents as amber – rendering basically any tray manufacturers entire portfolio as amber!
RECOUP shows de-nest in Green column, Anti-block in centre column. Anti-block in the masterbatch is acceptable. We have a statement to this effect written for us by Faerch.
This instruction was removed from RAM v1.1
– RAM states “if an item of packaging or component contains any of the following it is classified as red: attached label adhesives which are not removable in an 80°C hot wash”
This is too generalised. Protocols show different polymers react differently. For example: PET Bottles recommendation is 70°C – 90°C. For flexibles, both PP and PE, the recommendation is 40°C.
This instruction was removed from RAM v1.1
However, outstanding queries as yet unanswered by DEFRA include;
Flexible
– Specific barrier layers (SiOx, AlOx etc.) removed from ‘red’ list. Although OK in small quantities, this omission may result in higher quantity used, which the recycling industry may find difficult to cope with. The list of barrier layers needs some research but should be re-introduced, possibly as ‘Amber’ with a note concerning maximum quantity.
– Polyolefin film – minimum 80% PO mono- reduced from minimum 90% PO mono. “Any….. below this threshold are classified as red.” No indication of the % required for classifying as ‘green’ or classifying as ‘amber’
Rigid
– ‘Inks that bleed’ removed. This is a fundamental of all recyclability guidelines. We are aware of new technology – washable inks – in development; is this the reason?
Conclusion
We are unsure where DEFRA obtained information to make some of the changes. This obviously did not come from the recycling industry.
RECOUP remain open to discussion with DEFRA regarding the queries above. We talk with both The BPF and OPRL regularly to ensure we are in agreement.
Recyclability Guidelines
The RAM does not replace recyclability guidelines. The RAM was written as an instrument to enable fees to be charged for packaging.
RBD is produced by talking to members; and accept the advice from recyclers on what happens now. This is what makes it different to other instruments which look at what might happen with new ‘state of the art’ equipment in a few years.
For any help or advice please contact Paul East at paul.east@recoup.org