Analysis of new Environment Agency packaging data has revealed that almost two-thirds (61.8%) of flexible plastic packaging assessed under new recycling assessment rules received the lowest rating in 2025.
Reconomy, which undertook the study, warns this could see many producers hit will higher pEPR fees.
What is RAM?
Known as ‘RAM’, which stands for Recyclability Assessment Methodology, these rules are now an established part of EPR packaging (pEPR) reporting, under which obligated producers are responsible for paying household packaging waste disposal fees.
These fees are calculated by PackUK using the packaging data reported by producers, with the amount due set out in a Notice of Liability. Fees are paid directly to PackUK in line with the payment instructions and deadlines provided.
Fees will continue to reflect the material and weight of packaging supplied, but a ‘fee modulation’ will begin in the second year of the scheme.
RAM v1.1 applies to packaging supplied during 2026 and will be used to determine fee modulation in year two of pEPR. Defra has since published updated RAM 2027 guidance, which applies to packaging supplied from 1 January to 31 December 2027.
Defra told Food Manufacture that these new rules are intended to introduce clearer material-specific rules, new automatic red categories, stronger evidence requirements, and a greater focus on real-world recyclability across collection, sorting, reprocessing and end markets.
RAM places packaging into a traffic light system (red, amber, green), with packaging deemed more recyclable attracting lower fees and less recyclable packaging higher fees.
Fee modulation redistributes costs between packaging types but does not increase the overall cost of the scheme, according to Defra.
Red-rated packaging will cost 20% more per tonne than amber-rated packaging. Large producers responsible for a high proportion of red-rated packaging could therefore face higher overall bills.
How will flexible plastics be impacted under RAM 2027?
Concerns from the sector have been recently aired to Food Manufacture over questions about how this will impact films used in food packaging and fears that these regulations may result in some recyclable packaging actually costing packaging developers more.
When asked about this, Defra said that plastic (flexibles) packaging (including food contact films) is not collected at kerbside for recycling and is not sorted or reprocessed at scale within household packaging infrastructure.
Plastic (flexibles) packaging should be rated red, unless packaging can meet take-back scheme evidence requirements. If packaging can meet these evidence requirements producers can rate plastic (flexibles) as amber.
Some plastic films and food packaging may be affected where they contain materials or substances that create recycling or contamination issues, such as PFAS, certain multilayer structures, or non-compliant food contact materials.
Defra acknowledged that some producers may face higher costs if their packaging receives a poorer RAM rating i.e. red, but noted that the aim is to incentivise redesign towards packaging that works better in the real recycling system.
Acting early
Environment Agency packaging data shows that total packaging tonnage across all materials reported by large UK producers fell by 1.2% in 2025, declining by approximately 135,000 tonnes to 10.97 million tonnes, from 11.11 million tonnes in 2024.
The largest reductions by weight were recorded in plastic, which fell by approximately 52,300 tonnes, and glass, which declined by around 51,600 tonnes. Steel packaging fell by 25,500 tonnes and fibre composite by 12,200 tonnes. Aluminium increased by approximately 8,700 tonnes, while paper and card remained broadly unchanged.
The fall in reported tonnage could be an indicator that some producers began changing their packaging ahead of the first pEPR assessment year, which kicked off 1 April 2025, and the issuing of the first invoices in October 2025.
“pEPR represents a major shift in how the costs of packaging waste are handled. With nearly two-thirds of the flexible plastic assessed under RAM receiving a red rating, many producers could face higher per-tonne charges when modulated fees are applied,” said Richard Hardstaff, sales development manager at Eurokey by Reconomy.
“We recommend that businesses reassess their packaging to understand their potential fee exposure and identify opportunities to reduce weight and improve recyclability. Those that act early will be better placed to manage their fees and contribute to a more circular economy.”
