On 1 July 2026, the latest methodology for assessing the recyclability of packaging was released; six months before packaging producers will have to apply it to their packaging.
Beyondly’s Alex Hilton. Director of Policy & Public Affairs, was orchestrator of the original RAM while positioned at PackUK, so now speaks with us to reflect on what these updates mean for now, and the future…
How does it feel, after putting the RAM out into the world, to see your work evolve without you?
I was nervous initially, mostly for PackUK, about how they would best approach the changes necessary to improve it without upending guidance people are just getting their heads around. It’s great to see something I put so much time and effort into be improved and sharpened and I like the new layout, as well as the fact that PackUK have listened to stakeholders and incorporated user feedback into the changes, rather than ploughing ahead with purely technical improvements.
What do you see as the key messaging for development of the RAM moving forwards?
Clarity is king here. That doesn’t necessarily mean simpler, or conversely more complex, but ensuring gaps are filled and direction of travel for future iterations and priorities are indicated in good time. Aligning with real world is so important, but frankly very difficult, when there is no single version of the truth. But PackUK can engage more deeply with MRFs and reprocessors, to gather more accurate data on recycling at scale, capacity, yield and end markets information. This to ensure that the RAM is based on facts rather than lobbying.
Section 64 of the Regulations outline further areas of development of the RAM; what have we learnt from RAM 2027 about the future?
We’ve been given future direction on recycling content and excessive packaging, and the focus on these as areas of automatic red ratings. PackUK has given little useful information to support producers in their preparations for this, but I think it gives us insight into the current willingness to align with international regulations, notably PPWR.
You mentioned PPWR there. With PPWR’s August go-live date rapidly approaching, are we expecting further alignment of the RAM with European recycled content targets?
We can see in RAM 2027 a definite attempt at aligning with PPWR across different areas, such as substances of concern, the influence of EU recycling standards on rigid plastics in this version of the RAM, as well as the inclusion of recycled content and excessive packaging in the future.
I think it’s fair to say that further alignment is a given in the near future; we just need to make sure that the UK’s domestic recycling infrastructure is taken into account when aligning, and the Government don’t just lift and shift and hope, especially in the case of recycled content.
Let’s move our focus to how the different materials have been treated in this update. PackUK have stated that there has been a focus on providing clarity and not completely overhauling the RAM. Which materials are the winners and losers in RAM 2027?
None of the materials are losers because the goal of the RAM is to drive development and innovation of packaging towards recyclability and the circular economy, using the current status quo as the basis for this. That being said, there are some key changes, or not-changes to be aware of.
Despite Simpler Recycling coming into force in March this year, FBC liquid cartons are still set at maximum Amber for two reasons.
Firstly, the kerbside collection rate hasn’t met the 75% needed to be classified as ‘widely collected’, but there are still 6 months left of the year for collections to increase to exceed this target, so there is the potential for an update later in the year. We will await any news from PackUK on this.
Secondly, the RAM states that FBC liquid cartons are not reprocessed at scale within existing recycling infrastructure, so even if collections increase, without reprocessing infrastructure increasing in tandem, it will remain capped at Amber.
From the release of the first version of the RAM, the plastics industry has been keen to increase the data points for rigid plastics; this comes back to my clarity point, and because of so many polymers in the market, restricting the RAM has increased ambiguity and has been unhelpful in fully assessing plastics. RAM 2027 sees an expansion or amendment of data points to more accurately reflect the actual reprocessing of rigid plastics, along with alignment with unofficial EU standards.
Flexible plastics on the other hand have moved the other way in order to simplify RAM 2027, as flexible plastics can only be rated as Red, outside of using a tack-back scheme, and all the data points have been removed. One pro of this approach is it is time saving for those who use flexible plastics, as there is no data to collect. However, conversely, by removing these data points there is no data at hand for the future when flexible plastics could be rated Green due to an increase in collections or reprocessing infrastructure. I would suggest keeping record of the flexible plastic data points from v1.1 and using these as a basis for the future, as and when data points are reintroduced.
The final winner is glass, by removing the application data points (swing tops, non-glass attachments, colour criteria) we are ensuring that the majority of glass will be rated as Green, reflecting its high recyclability and circularity.
Before we finish, what are your closing comments or thoughts for producers who may still be struggling with the RAM?
The RAM is ultimately an opportunity for those producers who can take the opportunities it affords, and the environment will be rewarded with less waste, the UK with higher recycling rates and a more circular economy, and producers and their customers with lower fees and bills at the check-out.
However, if you are still struggling, now is the time to speak with your supply chain and Compliance Scheme, like Beyondly. They can help demystify your packaging, whilst PackUK and the regulators take a more lenient approach to compliance and data gaps. Shop around for a supply chain that works for you; there are plenty of suppliers who are engaged and willing to give you compliant and cost-effective packaging. Beyondly has high-quality data services, insights, and supply chain support services, to remove the pain. We pride ourselves on our friendly and effective customer service, and if you’re also operating in Europe, get prepared and speak to our team about our PPWR support service.
Call 01756 794951 or email solutions@beyond.ly to speak with the Beyondly team.