RAM 2027: What the New PackUK Guidelines Actually Changed

Most producers read the RAM 2027 announcement, noted that nothing was due yet, and filed it. That is a reasonable reaction to a methodology that does not touch the 2026 reporting year at all. It is also how a packaging portfolio arrives at January with red ratings that were fixable in September.

What PackUK published, and when it bites

On 1 July 2026, PackUK published RAM 2027 after industry consultation. It is statutory guidance, in two parts: an overview covering scope and principles, updated 20 August 2026, and the materials assessment guidance carrying the red, amber and green criteria for each material.

The dates are the first thing to get straight, because two methodologies are live at once.

Scope is unchanged in shape: large producers must assess household packaging, including household glass drinks containers, plus packaging that commonly ends up in public bins. Reusable and refillable household packaging only needs assessing the first time it is supplied. PackUK has also confirmed the RAM will be updated and republished every year before the reporting year starts, advised by an independent Technical Advisory Committee. Treat the methodology as a moving target, not a one-time project.

Five stages became four, and classification moved

Previous versions described five stages. RAM 2027 describes four, and pulls classification out to the front as its own step. That is not cosmetic. Classification is where you decide whether you are rating a whole item or a set of components, and that decision changes the outcome more often than any material criterion does.

The scoring rule across those four stages is unforgiving and easy to remember.

That last clause is the one to underline. Missing evidence is not a neutral state. It is a red rating, and the guidance tells you to go back to your supplier for the technical detail rather than guess.

Automatic reds: the new first question

Before any stage assessment, RAM 2027 asks you to screen for automatic reds. If one applies, you stop. The packaging cannot be treated as recyclable under EPR regardless of technical recyclability, because doing so would create legal, chemical or system level barriers.

• Integrated electrical components or batteries, for example a box with LED lights in it.
• Substances of concern above limits under UK REACH, SVHCs, POPs, biocides regulations, or CLP.
• Inks not manufactured in line with the European Printing Ink Association exclusion charter.
• More than 1 ppm of total PFAS in an item or component, individual or sum, or PFAS above 25 ppb in food packaging.
• Food contact packaging that fails applicable UK food contact legislation.
• Formats subject to UK restrictions or phase-outs, including certain single-use plastic formats, even where technically recyclable.

Two of these are chemistry questions your packaging team probably cannot answer from a spec sheet. Ink compliance and PFAS content live with converters and ink suppliers, and PackUK has flagged it may add more automatic red criteria in future iterations, including packaging with no verified recycled content and packaging with excessive empty space.

The 40mm rule and why it decides your rating

Classification splits every pack into separate components or a single item of packaging formed of integrated components. An item of packaging is rated on its predominant material by weight, and the guidance is candid that this means materials usually rated red or amber can come out green.

The guidance gives the cleanest illustration itself: a plastic label that would be rated red as a separate component, because flexibles cannot go green, is rated green when it is glued to a glass jar and assessed as part of that item. Same label, same adhesive, different classification, different fee.

What each material can actually score

RAM 2027 runs eight material categories. Four of them have a hard ceiling before you assess a single design detail. This table is the fastest way to see where your portfolio's exposure is structural rather than fixable.

Flexibles, wood and other materials share one sentence in the guidance: not collected at kerbside, not sorted or reprocessed at scale in household infrastructure, therefore red unless take back evidence is held. Glass adds a trap of its own. Soda-lime silica is green at collection, but borosilicate, lead crystal, ceramic glass and any other non-soda-lime-silica glass is red at collection, which matters for premium beauty and fragrance packaging in particular.

Rigid plastics: where the reds are made

This is the category with real criteria attached, and it is where most of the new tightening landed. A sample of what turns a rigid plastic red at reprocessing or application:

PET bottles

• Any color other than clear or translucent light blue is red. This applies to the plastic itself, not to printed inks.
• Direct printing is red, unless it is a batch code or expiry date.
• Any use of EVOH is red.
• Caps, seals, valves, labels or sleeves made of any polymer other than PET with a density above 1g per cm3 are red. Silicone is red.
• External coatings, PA-3 layers, UV stabilizers and acetaldehyde blockers are amber, not fatal.

PET thermoforms, HDPE and PP

• PET thermoforms are red on EVOH, non-PET multilayers such as PE seal layers, and any non NIR detectable color.
• HDPE and PP go red on EVOH above 5% by weight, PVDC barriers or coatings, additives pushing density to 1g per cm3 or above, and caps made of steel, aluminium, polystyrene, PVC or thermoset plastics.
• Labels or sleeves of PVC, aluminium, metallized PET or metallized PS are red on HDPE and PP, as are inserts and liners in PS, PVC, PU, nylon, polycarbonate, acrylic or silicone.

Rules that catch almost everyone

• A label adhesive that does not release the label in a standard 70 to 90 degree Celsius hot wash is red.
• A label or sleeve of a different material or polymer covering more than 60% of the surface area drops sortation to amber. Enrobed paper or board sleeves that carry clear removal instructions for the consumer are exempt from that amber.
• Anything under 40mm in two dimensions fails sortation as a standalone component, so small parts need to reattach.
• PVC, polystyrene, expanded PE, oxo-degradable, biodegradable and compostable plastics are red at reprocessing across rigid plastics.
• Trigger sprays containing glass, metal or non-polyolefin plastics are red. Foil that is not designed to be permanently removed before disposal is red, though tear-off seals on a milk bottle or yogurt tub are fine.

Take back schemes: the only amber route for flexibles

If a format is not collected at kerbside, a take back scheme is the one path from red to amber. It is not a checkbox. Producers must hold evidence that the scheme meets every one of these tests.

• Collection points reachable by at least 75% of the UK population or households within a 5-mile radius, or a postal service covering at least 75% of UK addresses.
• It does not compete with kerbside, so the material is not listed as commonly collected or limited collection.
• It accepts packaging from all brands.
• It requires no purchase before deposit.
• It can show traceability of the specific material through all four stages of recycling.

PackUK expects to be notified when packaging is reported as amber on this basis, with guidance on how to notify still to come. Evidence can include mapped collection points over population density, written declarations from the scheme operator, and PRN or PERN references from accredited sorters and reprocessors. For the 2027 reporting year only, flexibles that are collected at kerbside in some areas can still use take back schemes alongside that collection.

Five worked examples from the guidance

PackUK published five worked examples showing how classification, ratings and reporting interact. They are the closest thing to case law you get here, so they are worth reading as design briefs rather than admin. Ratings shown are illustrative in the guidance itself.

Read the five together and one pattern repeats. Tonnage is always reported by material, even when the rating is inherited from a different material. Your data model has to carry both facts per component: the material it is reported under, and the rating it was assigned. Systems that store one rating per SKU cannot express the jam jar, and moving to dated, component level records is the work that makes RAM survivable at portfolio scale.

What a red actually costs

RAM ratings modulate household packaging waste disposal fees. Under PackUK's disposal fees modulation statement, red rated household packaging pays 1.2 times the amber base fee in assessment year 2026 to 2027, 1.6 times in 2027 to 2028, and 2.0 times in 2028 to 2029. The penalty for a red roughly doubles over three years while your packaging stays the same.

Green ratings are treated as the base against which discounts are considered, so the practical planning question is not whether you can get everything to green. It is which reds you are still carrying in 2028, when the multiplier is at its highest, and which of those are structural, like a flexible pouch, versus fixable, like a metallized label on an HDPE bottle.

Evidence, deadlines and re-submission

Assessments are reported through the report packaging data service alongside other EPR data. Two deadlines each year: 1 October for January to June data of the same year, and 1 April for July to December data of the previous year.

You do not submit the evidence behind an assessment, but you must keep it for 7 years and hand it to regulators on request. That covers proof you applied the correct rating, and proof of any red by virtue of a regulatory requirement claim on medical packaging, which needs the specific regulation named, paragraph included, per component and per product.

Re-assessment is required when the design, manufacture or composition changes, when the RAM itself changes in a way that would affect the outcome for 2027, or when anything else is likely to change the result. In practice that means a change control process with dated records, because an annual methodology plus a live portfolio means ratings move even when nobody touches the pack.

What to do this quarter

1. Run the automatic red screen across your portfolio first. Ink charter compliance and PFAS thresholds need supplier confirmation, and those requests take weeks.
2. Classify before you assess. For every pack, write down which parts are separate components and which are integrated, and record the 40mm test result for each small part.
3. Pull every PET bottle that is not clear or translucent light blue, every metallized or PVC label on HDPE and PP, and every EVOH barrier, into one redesign list.
4. For flexibles, decide now whether you are securing take back evidence for 2027 or accepting red, because the evidence pack takes longer to assemble than the assessment does.
5. Check your data model stores material and rating per component, not one rating per SKU.

None of this is difficult in isolation. It becomes difficult at 4,000 SKUs, with an annual methodology update and a fee multiplier climbing toward 2.0. Packgine keeps component level packaging records with supplier evidence attached to the component it belongs to, so a RAM re-assessment is a re-run rather than a rebuild. If you want to see how your current portfolio maps against RAM 2027 criteria, our EPR risk checker is the fastest starting point, or talk to our team.

Sources

PackUK and Defra, RAM 2027: overview, statutory guidance, updated 20 August 2026. PackUK and Defra, RAM 2027 materials assessment guidance, statutory guidance for the 2027 reporting year. PackUK, PackUK publishes Recyclability Assessment Methodology (RAM) 2027, 1 July 2026. PackUK, EPR for packaging producer disposal fees modulation statement. Educational only, not legal advice. Confirm your obligations against the published guidance and your compliance scheme.