PackUK has redrawn the recyclability criteria that determine packaging disposal fees under pEPR, adding PFAS limits for the first time and restricting PET bottle colours to clear or translucent light blue. The RAM 2027 materials assessment guidance is the first version issued under PackUK as scheme administrator rather than by Defra, and replaces version 1.1 (from April 2025).

The updated methodology will apply to all household packaging (other than drinks containers subject to DRS) placed on the UK market from January next year, with the first reporting window closing at the start of October 2027. The new specification has been developed with the scheme's Technical Advisory Committee alongside material specialists and recycling facility data.

The colour ratings determine the level of fee required by the scheme's eco modulation policy. Packaging rated red pays a disposal fee of 1.2 times the base rate in 2026-27, rising to 1.6 times in 2027-28 and double the base rate by 2028-29. Green packaging receives a discount funded from the premium collected on red, while amber stays at the base fee. The total disposal bill across all producers is designed to remain the same, with any material that changing colour under the new methodology shifting costs between producers.

New automatic red criteria

The biggest structural change is a new first step requiring producers to check whether their packaging falls into an automatic red category before any further assessment. Several of these criteria are entirely new.

Packaging containing more than one part per million (ppm) of total perfluoroalkyl and polyfluoroalkyl substances (PFAS) - individual or sum - now receives an automatic red rating. Food contact packaging faces a tighter threshold of 25 parts per billion (ppb) for any individual or total PFAS. Given the breadth of PFAS use in grease-resistant coatings, particularly on fibre-based food packaging, this change will require producers to obtain compositional data from suppliers that many may not currently hold.

Non-compliance with UK food contact materials legislation has been added as a separate automatic red trigger, as have packaging formats already subject to UK regulatory restrictions or phase-outs, including certain single-use plastic packaging. Substances of concern exceeding limits under UK REACH, substances of very high concern (SVHCs), persistent organic pollutants (POPs) and those falling under biocides and CLP regulations also now trigger automatic red status.

Plastics face tighter rules on colour and printing

Rigid plastic packaging faces the some of the more substantial changes, particularly PET bottles and thermoforms.

PET bottles can now only achieve a green rating at the application stage if the plastic itself is clear or translucent light blue. Under RAM v1.1, bottles in dark blue, dark green and brown were rated amber rather than red. That amber allowance has been removed; any colour other than clear or translucent light blue is now red. Direct printing on PET bottles is also red unless limited to batch codes or expiry dates. PET thermoforms face equivalent restrictions, with non-NIR-detectable colours now rated red and direct printing similarly restricted.

For HDPE and PP packaging, RAM 2027 introduces a red rating for direct printing on clear or white items, again exempting batch codes and expiry dates. In-mould labels made from the same polymer type as the main item are permitted.

On barrier materials, the treatment of ethylene vinyl alcohol (EVOH) has hardened considerably. Any use of EVOH in PET bottles and thermoforms is now rated red at the reprocessing stage - version 1.1 allowed up to 10 per cent by weight. HDPE and PP packaging faces a new 5 per cent EVOH threshold. Expanded polyethylene has been added to the list of materials rated red at reprocessing, alongside existing restrictions on polystyrene and PVC.

Label adhesives that do not release during a standard 70 to 90 degree Celsius hot wash are now rated red. Version 1.1 had removed the previous 80 degree requirement; RAM 2027 reintroduces it with a temperature range. Attached labels or sleeves of a different material covering more than 60 per cent of surface area are now rated amber at sortation - a clarification after version 1.1 removed the previous red rating for this criterion.

Paper, board and fibre-based composites

Paper and board changes are less dramatic. The collection stage now uses the 75 per cent local authority threshold for "commonly collected" status, with a separate list of commonly collected packaging published by PackUK for producers to check against. Parchment and baking paper no longer appear on the explicit red list at collection, though greaseproof, siliconised and waxed paper remain red.

At the reprocessing stage, packaging designed for food to be heated within it is now automatically red - a recognition that such packaging is likely to be contaminated when disposed of. Silicone in linerless labels, previously a blanket red under the siliconising agents criterion, now has a specific amber threshold of greater than 0.3 per cent by weight.

PVDC and PVC polymer dispersion coatings on paper and board have moved from amber at the application stage to red. Direct and transfer metallisation, previously amber, no longer appear as separate criteria in RAM 2027.

Fibre-based composite non-liquid cartons now explicitly list single-use beverage containers, including coffee cups, as red at the collection stage. This codifies what was already practical reality but removes any remaining ambiguity.

Simplified treatment of flexibles, wood and other materials

Flexible plastic packaging, wood and "other materials" have been substantially simplified. All three categories remain red unless a valid take-back scheme is in place, in which case amber is the ceiling. RAM 2027 removes the detailed sorting, reprocessing and application criteria that appeared in version 1.1 for flexible plastics - producers simply assess whether they have a qualifying take-back scheme and, if not, rate the packaging red with no further assessment required.

RAM 2027 does note that flexible plastic packaging "may be collected at kerbside" in future, signalling that the current blanket restriction could change as collection infrastructure develops.

Steel, aluminium and glass

Metals see a modest improvement at the sorting stage. Oversized steel and aluminium packaging - items exceeding 300mm in any dimension - is now rated amber rather than requiring take-back or consumer folding to avoid red. Items that can be folded by consumers to meet the size threshold remain green.

Glass has been simplified so that ordinary soda-lime-silica packaging, once collected, runs green through every stage. The version 1.1 penalties for unusual colours, ceramic swing stoppers and fixed non-glass attachments have gone, with red now reserved for named exclusions including lead crystal, borosilicate, aluminosilicate and pyro-ceramic glass.

Medical packaging and reporting

RAM 2027 introduces an entirely new section on medical packaging. Items rated red can be reported as amber where a producer can demonstrate that another regulation prevents the use of a more recyclable material - a provision catchily termed Red by Virtue of a Regulatory Requirement (RBVORR). Evidence requirements are specific, requiring producers to identify the regulation by name and paragraph reference and show how it prevents more recyclable alternatives.

The updated guidance also includes detailed worked examples showing how to report multi-material packaging items, covering jam jars, battery packs, detergent bottles, liquid cartons and aerosol cans.

Winners and losers

Producers of steel and aluminium packaging gain from the change in sorting levels, with oversized items moving from a potential red to amber. Glass producers benefit from simplified criteria and the removal of several amber triggers. Carbon black plastic, previously red whenever the pigment was present, is now red only where the pigment prevents detection by near-infrared sorting equipment. Medical packaging producers gain a formal route to amber where regulatory constraints apply.

The changes are less favourable for producers relying on coloured PET, EVOH barriers, direct printing or PFAS-containing coatings. PET bottle producers face the sharpest tightening, with the colour window narrowing to clear and translucent light blue only, and any EVOH use now red. Coffee cup producers face explicit red classification as single-use beverage containers under fibre-based composites.

RAM 2027 rewards packaging that is genuinely collected, sorted and reprocessed through existing UK infrastructure at scale, and penalises packaging that is technically recyclable but not practically recycled. The PFAS thresholds and food contact legislation triggers suggest PackUK is also using the methodology as a lever for chemical safety objectives beyond recyclability alone. With the red-rating multiplier set to double by 2028-29, these reclassifications will have cost implications for affected producers well ahead of any change in collection or reprocessing infrastructure.

Robbie Staniforth, Chief Policy and Impact Officer at Ecosurety, commented: "We welcome the approach PackUK has taken to updating recyclability definitions. Releasing the revised methodology now gives time for us to recodify our members' packaging, and to explain what these changes might mean for their costs, well ahead of reporting deadlines in October 2027. This advanced warning acts as a signal that will be used to further improve packaging and reduce the amount of unrecyclable waste being created."

Staniforth added that most of the changes amount to clarifications and simplifications, "such as, explaining the evidence base for deciding whether an item of packaging is 'commonly collected' or not. However, there are some tweaks that we are pleased to see, particularly around ensuring that technical recyclability factors align more closely with real-world practices."

"The new EPR system is designed to build an efficient and effective system that promotes recyclable packaging," Staniforth said. "While these annual technical changes make it difficult for producers to keep pace, we believe they are urgently needed to ensure that definitions are in lock-step with the evolving recycling landscape."