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 8^th April 2025, then the most recent version of the DEFRA Ram was released on 28^th 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

RECOUP officially launches the Seabin in Peterborough!

On Tuesday 11^th February, our Seabin was officially launched by the Mayor of Peterborough, Marco Cereste, on the River Nene at the RailWorld Wildlife Haven.

It was attended by guests from the Peterborough Little Wombles, the City Council, representative for the local MP, Sam Carling, and by one of the funders and RECOUP member, Viridor.

Steve Morgan appeared on live radio on BBC Radio Cambridgeshire and gave interviews for BBC Look East and Peterborough Telegraph.

The Seabin is part of RECOUP’s Litter Composition & Pathways Project, which is looking at using different approaches and technologies to understand the composition of litter, by building a comprehensive litter composition data set with the aim to provide evidence-based interventions to reduce litter pollution.

The focus of the project has been to analyse land-based litter, and the Seabin activity focusses on litter in an aquatic environment.

A Seabin is a floating bin that sits just below the water surface. It has a pump that draws in the water from a large radius which skims material off the top of the surface of the water and recovers it before it sinks.

There are two aims for the Seabin activity. One is to remove litter material at source, but another is to analyse the recovered material to understand what’s in it, including the presence of microplastics.

Guests were able to see the Seabin on the jetty and take part in a litter pick around the Seabin’s location to help clean up the local area.

We would like to thank all the guests for joining us on a cold and rainy morning to celebrate the launch, and for funding from Peterborough Environment City Trust (PECT) and RECOUP members Viridor, McDonalds and Ocado, to make it happen.

The Peterborough Telegraph article is here

RECOUP UK Plastic Packaging Collection Survey Outlines “Monumental” Challenge

Plastic resource efficiency and recycling charity, RECOUP, has launched its annual UK Household Plastic Packaging Collection Survey, which has outlined the monumental scale of the challenge ahead.

Whilst there have been incremental improvements across the board for kerbside service provision for plastic packaging, the scale to include other formats in collection services in a relatively short timescale is unprecedented, but one that is entirely achievable with the right drive, funding, planning and leadership.

With all UK local authorities collecting plastic bottles as part of their kerbside service in 2019, local authorities providing kerbside service provision for plastic pots, tubs and trays increased from 88% to 89% and 12% to 14% for plastic films and flexibles, the first increase after 6 consecutive years of decline. This means another 39 local authorities need to collect plastic pots, tubs and trays and 312 for plastic films and flexibles by March 2027 to comply with requirements – just over 2 years away.

Consistency of Inconsistency in Citizen Communications

Effective communications to citizens are an essential part of this process, and whilst local authorities are making significant efforts – 60% reporting they have an ongoing or continuous citizen communication campaign about plastic packaging recycling – packaging EPR funding needs to strengthen the resources to delivery these campaigns. The 2024 Survey found local authorities reported an average material reject rate of 14%, and helping to deal with issues such as contamination will be pivotal.

However, although Simpler Recycling in England and similar approaches in other nations will provide consistency of what can be placed for recycling, the 2024 Survey found there is a comprehensive inconsistency in messaging across the UK, both in the language used and instructions given.

For example, when looking at plastic bottle lids, 40% of local authorities ask for citizens to leave lids on bottles but 13% ask for them to be left off. 12% listed lids as separate target items, however, did not specify if they should be left on the bottle or not, 5% said that they can be either on or off the bottle, and the remaining 30% do not provide any guidance.

Other examples of instructions to residents will need to be adjusted to fit new policy requirements. 54% of local authorities ask for plastic bottles to be flattened or squashed, but with a DRS planned to be implemented in October 2027, this message might cause confusion as it is likely plastic bottles shouldn’t be presented in this way in a deposit return system.

The biggest common message is 85% specifying that items should be empty, rinsed and/or washed, with 53% asking for items to be disposed of loose and not bagged.

Steve Morgan, Head of Policy & Infrastructure at RECOUP, said: “Whereas the different instructions need to reflect local sorting and processing requirements, it’s in the benefits of consumers and all stakeholders to have simple, consistent national communications messages about how to present plastics for recycling. Packaging EPR and Deposit Return Schemes, through their respective Scheme Administrator and Deposit Management Organisation leadership, should build on the requirements of Simpler Recycling and provide the foundations and influence to enable one unified core set of messages about how to recycle.”.

Impact of the Emissions Trading Scheme (ETS)

Another key finding around communications in the 2024 RECOUP Survey wasn’t to residents but around local authority funding. With the focus on packaging EPR to provide the funding to collect and sort packaging, the impact of another policy needs greater awareness and urgent and robust plans to mitigate its impact.

The ETS is a market-driven mechanism that limits the emissions an involved industry is allowed to produce, with the intention to incentivise the development and uptake of decarbonisation technologies or practices to reduce emissions. The scheme is expanding to include waste incineration and energy from waste from 2028, preceded by a 2-year transitional period from 2026, and will significantly impact the dynamics of local authority funding. To reduce this impact, removing plastic packaging from residual waste will be key.

The 2024 RECOUP Survey found that around a third of local authorities (32%) said they were not aware of the upcoming expansion of ETS and its impact on incineration and energy recovery of local authority waste. Furthermore, when asked how prepared they felt for the changes to ETS on a scale of 1 to 10 (with 1 being not prepared at all, and 10 being fully prepared), 37% gave a score of 3 or below, indicating they do not feel confident about how it will operate. Only 12% gave a 7 or higher with no local authorities giving a score of 10.

The 2024 RECOUP UK Household Plastic Packaging Collection Survey report is available for RECOUP members to download, with the Data Summary available for non-members here.