Packaging is one of the most visible sustainability challenges affecting manufacturers and, under Extended Producer Responsibility (EPR), it’s now a financial one.
The Recyclability Assessment Methodology (RAM) is central to this – and what it measures might surprise you.
Three experts across packaging, compliance and broader sustainability separate fact from assumption. Claire Robbins and Naomi Carlin from sustainable waste management company Biffa draw on their day-to-day experience helping manufacturers of all sizes navigate the complex legislation, while environmental journalist Lucy Siegle adds the consumer implications.
Claire Robbins, Head of Producer Compliance at Biffa, on the evolving legislative landscape and ripple effect:
“EPR is in its third year of reporting – and the financial reality is materialising.
“Large manufacturers will soon receive their first Notices of Liability (NOLs) based on modulated fees from PackUK. Annual costs vary based on volume and type of packaging but can range from £1,000 to £50 million. For producers who haven’t completed the RAM, that invoice may come as a shock.
“Producers handling household packaging must complete the Recyclability Assessment Methodology (RAM) using a red, amber, green rating. The result determines your modulated fee – multiplied by tonnage, per packaging type. The more recyclable your packaging, the less you pay.
“The wider supply chain is taking notice too, with RAM ratings now a commercial talking point. Retailers monitor performance closely and may reduce payments or cancel contracts with manufacturers whose packaging remains in the ‘red’ category. These retailers have a league table based on outgoing costs and how sustainable a partner is.
“If you haven’t started, act now. The RAM is updated annually – we’re currently using RAM 1.1. The latest version has now been released, called RAM 2027. The H1 submission deadline to the Environment Agency (EA) is 1st October 2026 but, as a compliance scheme partner, we need data (including the RAM results) by 28th August 2026.
“The H2 submission deadline is 1st April 2027 – but we ask for it 28th February 2027. Assessing your packaging now and identifying ‘red’ materials gives you more time to optimise.”
Naomi Carlin – Packaging Expert at Biffa – on the RAM’s nuances:
“Packaging is designed for the individual product so there’s no one-size-fits-all. The RAM is a strong indicator of how much work needs to be done to improve the recyclability of your packaging in the UK.”
What does the RAM look at?
“The RAM assesses packaging across four stages: collection, sortation, reprocessing and end market. It evaluates how a format performs across the real recycling system in the UK – and the red, amber, green rating reflects the limitations.
“That final stage is crucial. If there’s no end market for the material, the circular economy breaks down and the value of the earlier steps is lost.”
‘Recyclability’ isn’t what you think it is
“The RAM will be an ongoing challenge for manufacturers. It’s a complex assessment to complete, partly because ‘recyclability’ has a broad definition. It’s not just about packaging material – shape and size also matter. If an item is too small, it falls through the sorting screens.
“Packaging redesign can make a real difference. We worked with manufacturer Suntory Beverage and Food GB & Ireland to increase the recyclability of its Ribena bottles by significantly reducing the label size. It can now be recycled into the clear plastic waste stream and potentially become another bottle.
“Many manufacturers are switching from plastic to paper – a trend known as ‘paperisation’ – in response to consumer pressure. The trouble is, if the shape behaves like plastic at the sorting facility (because it’s 3D, for example) paper can be sorted into the plastic stream. Engaging a waste collector like Biffa at design stage helps you avoid these mismatches.
“Flexible plastics, such as those used for laundry detergent refills, raise a similar issue. They were brought to market to reduce plastic volume and weight but are mostly ‘multilaminate’ – comprised of several bonded layers – rather than from a single polymer, making them difficult to separate and recycle.
“But those layers serve a purpose: blocking moisture, keeping out oxygen, resisting punctures and extending shelf life in ways a single material simply can’t.
“In fixing one problem, you can create another – especially when the recycling infrastructure to process these materials is at an early stage and yet to operate at scale.
“Contamination complicates every stage of the RAM too. When general waste enters a recycling bin, it can contaminate the entire load – especially if it’s food or wet waste. At sortation, materials resembling something else contaminate batches. At reprocessing, it’s plastic laminated paper and card that can cause problems for repulping at paper mills.”
Assessment challenges
“The RAM is difficult to complete. The assessment uses highly technical language and requires data that might be new to you. Manufacturers often default to ‘red’ because they lack the proof to score ‘amber’ or ‘green’, driving avoidable costs.
“This is where a compliance scheme, paired with packaging technologists like us at Biffa, can alleviate the burden by providing packaging expertise and ensuring accurate, robust reporting.
“Larger businesses with packaging technologists and sustainability teams tend to be advantaged compared to smaller manufacturers, but size doesn’t guarantee accuracy. Incorrect specifications from a materials supplier can throw off your entire assessment.”
Collaboration is key
“We’re all on the same planet. When it comes to recyclability, you can’t win by competing. Manufacturers working together is an important first step. But the greatest environmental impact will come from businesses across different industries, throughout the supply chain, collaborating.
“Volume matters. The more businesses that flag the same material, the stronger the case for investing in infrastructure to recycle it. One manufacturer acting alone faces higher costs and limited impact. And what they deem waste could be feedstock for another – a circular solution that only arises through partnership.”
Lucy Siegle, an environmental journalist, adds:
“As consumers, we’re conditioned to check labels on packaging. It can tell us what went in but not what happens throughout the waste process. It’s understandable for manufacturers to assume that the RAM assesses material in a similar way.
“The RAM is a standalone system, examining the life cycle from collection to end market. Producers must prove their packaging is as recyclable as possible at every stage.
“In time, these changes will show up on the packaging consumers handle – raising the stakes for manufacturers.”
Five things manufacturers should do now:
- Complete your RAM assessment before the end of August (engaging a compliance partner as a priority)
- Review packaging specifications with your materials suppliers
- Remember the RAM is looking at more than materials – shape, size and construction impact your rating
- Don’t accept a ‘red’ rating – work with a packaging specialist like Naomi at Biffa to pinpoint why and the feasibility of redesign
- Collaborate with other businesses across industries to improve recyclability at scale – Biffa can facilitate this
Visit biffa.co.uk