PackUK Updates Packaging Recyclability Assessment for pEPR

A Simplified System for Assessing Recyclability

PackUK has launched an updated version of its Recyclability Assessment Methodology (RAM) for the UK’s extended producer responsibility (pEPR) scheme. This latest edition – referred to as RAM 1.1 – introduces key simplifications aimed at making it easier for packaging producers to evaluate how recyclable their materials are.

The RAM continues to classify household packaging as red, amber, or green depending on its recyclability. This classification will play a major role in determining how disposal fees are modulated from 2026 onward, based on the packaging producers place on the UK market during the previous year.

Why the Change?

In February, the pEPR scheme administrator carried out what was described as a “simplification sprint.” The goal was to reduce complexity and ensure more producers could realistically complete their recyclability assessments by 2025. The changes reflect industry feedback gathered during this sprint.

Key Adjustments by Material Type

Paper and Cardboard

• The need to automatically label packaging as red due to product residue that can’t be removed by hand has been dropped. For example, baked-on food no longer automatically renders packaging unrecyclable.
• Items with PAE (Polyamide epichlorohydrin), heavy UV varnishes, mineral oil-based inks, and fibre-based composites no longer need to be marked amber.
• Fibre composites that may retain residue are no longer classified as red solely for that reason.

Plastics

• Flexible Plastics (Sorting): 

1. 1. Flexible packaging with carbon black ink or labels covering over 50% of the surface area no longer has to be classed as red.

• Rigid Plastics (Sorting): 

1. 1. Bottles with labels or sleeves covering more than 40% of the surface, and pots/tubs/trays exceeding 60%, are no longer automatically red.
   2. Labels with carbon black covering more than 50% no longer trigger a red classification.

• Rigid Plastics (Reprocessing): 

1. 1. Adhesives on labels that don’t come off during an 80°C wash no longer affect the classification.
   2. PET bottles with nanocomposite additives and PET trays with PE seal layers are no longer red.
   3. HDPE items with additives like talc or CaCO3, which previously bumped density above 0.995 g/cm³, no longer automatically fall under red.

• Rigid Plastics (Application):

1. 1. Paper labels or sleeves no longer result in amber classification for rigid plastics.
   2. PET bottles with heavy colours and PP items with clarifiers, heavy colours, paper labels, or PET inserts are not considered amber by default.

Glass

Glass packaging with labels covering more than 60% of the surface area will no longer be classed as amber. While such labels can complicate recycling, they are not enough to affect recyclability classification alone.

Looking Ahead

These changes aim to simplify compliance for producers while still supporting the broader goals of the pEPR scheme – boosting recycling rates and encouraging sustainable packaging design. With clearer rules and fewer obstacles, businesses can focus on adapting their packaging with confidence.

Producers are encouraged to familiarise themselves with RAM 1.1, as mandatory recyclability assessments under the updated methodology are already in effect from 2025.

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