The Complete Guide to UK Packaging EPR & RAM (2026 Edition)

Published date: 01 June 2026

UK packaging regulations are going through their biggest change in decades as consumer priorities are evolving and compliance isn’t just about hitting recycling targets. The UK generates millions of tonnes of packaging waste every year, so now the shift puts the responsibility on the business, which can mean increased reporting, more fees, and reputational risks if they aren’t compliant.

That’s where RAM and EPR come in. Simply put, EPR determines who pays the extra costs associated with the collection and disposal of waste, and RAM helps determine how much they pay in the future. Together, EPR and RAM encourage better recyclable packaging design and ensure businesses are compliant.

What is Extended Producer Responsibility (EPR)?

EPR is legislation designed to put the responsibility of household packaging waste management fees onto the producer, rather than local authorities, which, up until 2024, was the standard. This means, if your business creates packaged products in the UK which will end up in recycling or waste bins at a customer’s home, you are likely liable to pay the EPR fees.

These regulations apply to ‘large producers’, including:

All obligated UK organisations that import or supply packaging
Individual businesses, subsidiaries, or groups
Businesses with an annual turnover of £1 million or more, based on your most recent annual accounts up to 7th April
Businesses that were responsible for importing or supplying more than 25 tonnes of packaging to the UK market the previous year
Businesses that carry out any of the packaging activities

If you are a ‘small producer’, you must collect data about:

Any packaging activities such as selling, filling, or importing
The class of any packaging
What your packaging is made of
The weight of each packaging material in kilograms
Plastic and paper bags you supplied in England

The core objectives of EPR are to reduce packaging waste, improve recycling rates, encourage sustainable packaging design, and increase producer accountability.

What Are the EPR Base Fees for Packaging?

The base fees for packaging EPR Year 2 (2026-2027) are as follows.

Material	Base Fee (£)
Aluminium	266
Fibre-based composite	461
Glass	192
Paper and board	196
Plastic	423
Steel	259
Wood	280
Other	259

The base fees represent the foundational cost per tonne of packaging material that obligated producers must pay to cover the net cost of collecting, sorting, and recycling. From 2026, the government will apply eco-modulation using RAM to adjust what you actually pay based on the recyclability rating of your packaging.

Which Businesses are Affected?

Many companies may assume only manufacturers are affected by EPR – this is incorrect. EPR applies to:

Brand owners
Importers
Packers/fillers
Online retailers
Distributors (in some circumstances)

However, EPR fees are only relevant to large producers. Small producers don’t have to pay the costly disposal fees, but if the business meets the small producer threshold (listed above), you must still register with the relevant environmental regulator and report your annual packaging data.

What is Recyclability Assessment Methodology (RAM)?

RAM stands for Recyclability Assessment Methodology and is an evaluation system which will apply a modulation to the packaging EPR fees based on the recyclability of the material. This means some materials will be more expensive to use than others based on their rating.

RAM was introduced as a framework so that companies could no longer make inconsistent recyclability claims. There is no longer the theoretical question of ‘can this be recycled?’ but rather: ‘can this be collected, stored, and recycled within current UK systems?’. Alongside EPR, these regulations drive packaging design improvements.

How RAM Works

The RAM methodology focuses on evaluating the recyclability of materials, including the full range of requirements across the packaging end-of-life stages. It considers factors such as collection, sortation, and reprocessing capabilities.

There are 5 stages of RAM, each requiring relevant evidence.

1. Classification

This stage assesses the whole packaging units and components against the RAM, especially when multiple materials are involved. Components that can be easily separated by hand are assessed individually, and inseparable multi-material packaging is assessed on its predominant material.

2. Collection

Collection assesses whether the packaging is widely available for recycling throughout the UK systems. Packaging can qualify through:

Widespread kerbside collection (75% of local authorities)
Limited collection (50%+)
Approved take-back schemes with strict accessibility and recycling criteria

3. Sortation

Sortation evaluates whether packaging can be accurately identified and separated into the correct recycling stream at materials recovery facilities (MRFs). It takes into consideration factors such as size, shape, colour, and material composition in order to be sorted effectively.

4. Reprocessing

Reprocessing considers whether packaging can be successfully transformed into usable recycled material. Packaging designs that are contaminated or include incompatible materials can make recycling more difficult.

5. Application

The application stage assesses whether the recycled material produced can be successfully used in new products without excessive material loss or quality issues. Strong end markets and practical reuse opportunities are important for packaging to be considered as genuinely recyclable.

Understanding Red, Amber, and Green RAM Ratings

Each packaging material which falls under EPR legislation comes with its own base fee per tonne, which is modulated on its own traffic light rating system. This means each rating defines how recyclable that product is.

Green – Widely Recyclable

The packaging that falls under the Green rating is easily collected, sorted, and processed in standard UK recycling systems. Green packaging materials qualify for the lowest compliance costs and the smallest base fees.

Amber – Limited Recyclability

The packaging that falls under the Amber rating is recyclable, but presents certain challenges. This may include requiring specialist infrastructure, or the reprocessing stage of recycling may impact the quality of the material. Amber packaging attracts moderate fees.

Red – Difficult to Recycle

The packaging under the Red rating is either not commonly recycled, is difficult to sort, or cannot be handled effectively at scale by the current UK setup. Red packaging attracts the highest fee penalties in order to incentivise businesses to redesign their packaging.

How RAM Impacts EPR Fees

The RAM doesn’t just assess how recyclable packaging is; it directly influences fees producers pay under the EPR scheme. Every packaging material is subject to an EPR base fee per tonne, which is then adjusted according to its RAM rating.

Fee modulation for 2025-2026 works as an Amber rating as the base fee, and green and red ratings are adjusted to be more or less than this. E.g.:

RAM Rating	2025	2026	2027
Green	Base fee	Potential fee reduction	Potential fee reduction
Amber	Base fee	Base fee	Base fee
Red	+20%	+60%	+100%

This suggests that green-rated packaging could receive a reduction in 2026, and red could cost significantly more. The final rates are subject to confirmation, which is being introduced in phases throughout 2025-2027. For businesses, RAM is about much more than sustainability; it’s about improving a packaging format from Red to Amber or Amber to Green that could help reduce future EPR liabilities. It also demonstrates your commitment to a more sustainable future.

Common Packaging Features that Reduce RAM Scores

Certain packaging design choices will lower your RAM performance as they interfere with the stages involved. By identifying and removing these factors early, you can improve your recyclability ratings and future EPR costs.

Multi-Material Packaging

Packaging that is made from multiple bonded layers (e.g. plastic and aluminium, or aluminium and paper) is difficult to separate and is therefore often treated as a single, non-recyclable unit and can’t be efficiently reprocessed.

What to do: Instead of multiple materials, switch to single-material alternatives where possible or redesign layers so that they can be separated during use.

Complex Packaging Components

Items with multiple attached parts such as windows, sleeves, inserts, liners, etc. can reduce recyclability if they can’t be separated easily by hand.

What to do: Redesign the packaging to a simpler structure where any components can be removed cleanly before recycling.

Adhesives and Coatings

Strong adhesives, full-surface glueing, and certain coatings can contaminate recycling streams or prevent materials from being effectively repurposed.

What to do: Use recyclable-compatible adhesives and minimise coatings if they are not essential.

Small Components

If your packaging has very small components, they can often be missed during automated sortation.

What to do: Avoid any unnecessary small components.

Contamination-Prone Packaging

Food residue, inks, or chemical contamination can reduce recyclability even if the base material is technically recyclable.

What to do: Design your packaging so that it can be easily emptied, cleaned, or separated from contaminants.

How Businesses Can Improve Packaging Recyclability

The RAM and EPR regulations can be daunting, but there are ways your business can improve packaging recyclability and reduce EPR fees as much as possible.

Packaging Audit

You first need to understand your current packaging portfolio under the RAM criteria. To do this, you should review:

Material composition (mono vs multi-material structures)
Component breakdown (closures, labels, coatings, liners)
Existing recyclability claims vs evidence available
Current supplier data and technical documentation

This audit will tell you where your business’s packaging is failing due to design complexity or lack of evidence.

Simplify Material Structures

One of the easiest and most effective ways to improve your RAM ratings is to simply reduce the complexity of your materials. Multi-layer or bonded materials are much harder to sort and reprocess, which results in lower classification. Instead, you should:

Replace composite structures with single-material alternatives
Reduce unnecessary laminations or barrier layers
Choose packaging formats that align with existing UK recycling streams

Single-material packaging will perform better across the RAM stages.

Improve Separability

If multi-component packaging is a non-negotiable for your business, a simple packaging redesign should make separation easy during end-of-life. Design changes may include:

Ensuring labels, sleeves, and closures can be removed cleanly
Avoiding permanently bonded components where necessary
Design for hand separation where possible

Components that can’t be separated easily are more likely to be assessed as lower-performing under RAM and therefore incur higher fees.

Improve Supplier Data

RAM is driven by evidence that businesses provide, and even the technically recyclable packaging can fall under a lower rating if the supporting data is missing or incomplete. That’s why you should always:

Maintain supplier declarations and material specifications
Collect recycling test data where available
Obtain reprocessor acceptance statements for key materials
Document participation in take-back or recycling schemes where relevant

The right evidence can massively reduce your fees.

Conduct RAM Reviews Early

RAM should be considered at the design stage in order to reap the most benefits and the lowest costs. Considering this framework after the packaging has been finalised can lead to further costs, missed deadlines, and less efficient processes. When initially designing your packaging, you should:

Integrate RAM assessment into design approval workflows
Test packaging changes before full production
Reassess packaging whenever materials or suppliers change
Use RAM scoring as a design constraint, not a post-check

Making these early RAM-driven decisions can have a huge impact on the final rating and fees.

Work with Packaging Specialists

The legislation around RAM and EPR can be overwhelming, to say the least. By working with a UK packaging specialist like Challenge Packaging, you gain expert advice and knowledge when it comes to packaging design that balances product protection, sustainability, compliance with UK legislation and standards, and cost-efficiency.

At Challenge Packaging, we can help you:

Assess current packaging against RAM requirements
Identify redesign opportunities to improve recyclability ratings
Reduce material complexity and improve compliance confidence
Support more sustainable, cost-efficient packaging decisions

Contact us today to review your packaging strategy, ensure your materials are ready for EPR, and design packaging that is efficient, protective, durable, and incurs as few fees as possible.

Common Questions About EPR and RAM

What is the difference between EPR and RAM?

EPR (Extended Producer Responsibility) is the financial system where producers pay for packaging waste management rather than local authorities. RAM is the assessment of how recyclable packaging is, which then influences EPR fees.

Does recyclable packaging automatically get a green rating?

No. “Recyclable” is not enough on its own. RAM assesses real-world UK collection, sorting, reprocessing, and end-market viability, so packaging can still be rated Amber or Red even if it is technically recyclable.

What happens if I can’t provide recyclability evidence?

If sufficient evidence can’t be provided to support your RAM assessment, the packaging will likely be assigned a higher rating, with some resulting in a Red classification by default.

Do labels affect RAM ratings?

Yes. Labels are assessed as part of the overall packaging unit and can impact recyclability, especially if they are non-separable, cover large surface areas, or interfere with sorting or reprocessing.

How often should RAM assessments be reviewed?

RAM assessments should be reviewed whenever packaging is changed, materials are updated, or the RAM methodology is revised. Regular reviews are expected to ensure ongoing compliance with current guidance, which often changes yearly.

Are reusable or refillable packages assessed differently?

Yes. Reusable and refillable packaging is subject to different reporting and assessment considerations, including how reuse cycles and return systems are defined and evidenced under the regulations.