Contaminant thresholds, material dimensions, and take-back schemes highlighted as key metrics to decide modulations for future packaging fees.
The Department for Environment, Food & Rural Affairs (DEFRA), in collaboration with the devolved governments, has updated its Recyclability Assessment Methodology (RAM) to help packaging producers evaluate the recyclability of their materials under the packaging Extended Producer Responsibility (pEPR) scheme.
Drawing on input from 150 organisations across the value chain, the RAM categorises packaging materials into red, amber, or green tiers based on their recyclability. These categories will determine modulation fees starting in 2026, Year 2 of the pEPR scheme. Producers using more recyclable materials will benefit from lower fees, while those with less recyclable packaging will face higher costs.
For 2025, base fees will apply uniformly to all packaging, with updated indicative fees released in October to help producers plan.
Material-specific rankings
The updated methodology now offers material-specific rankings, providing producers with granular criteria to assess their packaging.
More precise details on the thresholds for contaminants and non-recyclable components is offered. Fibre-based packaging with more than 15 per cent non-paper content is now categorised separately to those with lower proportions, while highly contaminated materials like glitter-coated or double-laminated boards automatically fall into the lowest recyclability tier. Formula for paper and non-paper content have also been added to this second draft.
Plastic flexibles - including bags, pouches and wrappers - also face red-tier ranking, as collection rates fall below 14 per cent. The RAM suggests take-back schemes as a potential way to improve the recyclability ratings of materials with low collection rates.
Paper and board, fibre based composite materials, and plastic also have been given specific guidelines for size, with materials under 40mm in any dimension requiring special classification as non-recyclable unless attached to larger components.
For materials like glass, aluminium, and steel, the RAM addresses factors like non-glass attachments and excessive non-metal content, which could downgrade recyclability. Both steel and aluminium have also gained new sortation requirements, with packaging required to not exceed 300mmm in any dimension.
Materials such as wood and ‘other’ are consistently labelled as red unless supported by take-back schemes.
Implications for producers
Producers will be required to assess the material composition of their packaging, align with RAM’s modulation sub-categories, and engage with recycling schemes or adapt designs to achieve green ratings. Failure to meet recyclability standards will result in higher costs under the pEPR scheme.
Producers and stakeholders can still influence the methodology by participating in the open survey until 27 November, ahead of the final RAM publication in December. This feedback period offers a chance to refine the system and address concerns before full implementation begins.
In October, pEPR regulations were laid before Parliament, formally creating a Scheme Administrator to oversee fee modulation and payments to local authorities. Recycling targets for all packaging material through to 2030 were also set.
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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?
There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.