The UK Recyclability Assessment Methodology (RAM): Turning Recyclability Into a Financial Metric

Table of Contents

1. 1.What RAM Is and How It Works
2. 2.Why RAM Is Critical For Beauty Brands
3. 3.Building RAM Into Design and Governance
4. 4.How Packgine Helps
5. 5.Understanding RAM Classifications in Detail
6. 6.Conducting a Portfolio RAM Assessment
7. 7.Redesign Strategies for Improved RAM Ratings
8. 8.The Commercial Case for RAM Optimisation

The Recyclability Assessment Methodology (RAM) is the mechanism that converts "design for recycling" from a qualitative aspiration into a quantified rating that directly influences UK EPR fees. From January 2025, all liable producers that supply household packaging must assess and report the recyclability of that packaging using RAM.

What RAM Is and How It Works

RAM is a government-specified framework, developed with PA Consulting and Defra, that evaluates each packaging component against actual UK recycling infrastructure. It looks at how easily a given item can be:

• Collected in household systems
• Sorted by UK MRFs and sorting technologies
• Reprocessed by recyclers into secondary raw material
• Applied in new products at meaningful scale

Each packaging component is given a Red, Amber or Green (RAG) rating under RAM. These ratings are then used to modulate household packaging disposal fees under EPR, with "green" formats incurring lower fees and "red" formats attracting higher charges. Version 1.1 of RAM was published in April 2025, and a technical advisory committee will review and update it annually to reflect changes in UK infrastructure and policy.

For beauty and personal care, RAM applies to household packaging components such as bottles, jars, caps, pumps, labels and outer cartons; non-household packaging is outside RAM's scope for now. Producers must complete RAM assessments for each relevant component from the 2025 packaging year and report the data according to regulatory timelines.

Why RAM Is Critical For Beauty Brands

Beauty packaging often uses multiple materials, complex formats and high-impact aesthetics, all of which can complicate recyclability. RAM turns these technical nuances into a clear financial signal:

• A "green" PET bottle with compatible closures and labels will attract lower modulated fees than a similar bottle with incompatible materials or formats that diminish recyclability.
• An "amber" or "red" rating for components like pumps, sleeves or multi-material cartons will raise fees and may push brands to redesign to avoid ongoing cost penalties.
• As RAM is updated over time, formats that are marginal today may become more or less favourable depending on how UK infrastructure evolves.

For beauty and personal care brands, this means recyclability can no longer be treated as a secondary consideration behind aesthetics and cost. RAM effectively embeds recycling performance into the core economics of packaging.

Building RAM Into Design and Governance

To stay ahead, brands should integrate RAM thinking across the packaging lifecycle:

• **Design and innovation:** Specify materials, formats and components known to achieve green RAM ratings, based on current versions of the methodology.
• **Supplier selection and qualification:** Ask converters and component suppliers for RAM-aligned specifications and evidence of recyclability in UK systems.
• **Portfolio reviews:** Prioritise redesign of high-volume SKUs where RAM indicates red or amber components, focusing on simplification and mono-material solutions.
• **Scenario modelling:** Quantify the cost difference between red, amber and green outcomes to build strong internal business cases for change.

In effect, RAM turns recyclability into a design constraint and an optimisation opportunity. Beauty and personal care brands that engineer for green ratings will be better positioned to control EPR costs, support credible sustainability claims and align with retailer expectations in the UK market.

How Packgine Helps

RAM Rating Engine: Packgine automatically assesses every packaging component against current RAM criteria, giving you instant Red, Amber or Green ratings across your entire portfolio.

Fee Impact Modelling: See the direct financial impact of RAM ratings on your EPR fees. Packgine quantifies the cost difference between red, amber and green outcomes so you can prioritise redesign efforts.

Design-for-Recycling Guidance: Our platform recommends specific material and format changes to move components from red or amber to green, with projected cost savings for each change.

Portfolio Optimisation: Packgine identifies high-volume SKUs with poor RAM ratings and suggests simplification and mono-material solutions that reduce both fees and environmental impact.

Understanding RAM Classifications in Detail

RAM assigns Red, Amber, or Green ratings to individual packaging components based on their compatibility with UK household recycling infrastructure. Understanding the criteria behind these ratings is essential for making informed packaging design decisions.

Green Ratings

A component receives a Green rating when it is widely collected through UK kerbside schemes, can be effectively sorted using existing sorting technology, has established reprocessing routes in the UK or through reliable export markets, and produces secondary raw material of sufficient quality for use in new packaging or products.

Common Green-rated formats for beauty packaging include clear PET bottles, natural HDPE bottles and jars, standard PE caps and closures, uncoated folding cartons, and clear glass containers without permanent decoration.

Amber Ratings

Amber indicates that a component has partial recyclability, either because collection or sorting is inconsistent, reprocessing capacity is limited, or the material quality after reprocessing is significantly reduced.

Amber-rated formats commonly found in beauty packaging include coloured PET bottles (particularly dark colours), PP containers of certain sizes, metallised or laminated cartons, and glass containers with moderate decoration.

Red Ratings

Red signals that a component is not currently recyclable through UK household infrastructure, either because it is not collected, cannot be sorted, or has no viable reprocessing route at meaningful scale.

Common Red-rated formats in beauty include multi-material pumps and dispensing systems, flexible sachets and pouches with mixed materials, small format packaging below the size threshold for effective sorting, and heavily decorated glass with ceramic transfers.

Conducting a Portfolio RAM Assessment

A systematic RAM assessment follows a structured process designed to evaluate every packaging component against current criteria.

Step 1: Component Inventory

Break every SKU into its individual packaging components. A typical beauty product might include a primary container (bottle, jar, tube), a closure (cap, pump, dropper), a label or decoration, secondary packaging (carton, sleeve, insert), and transit packaging (corrugated case, void fill). Each component is assessed independently under RAM.

Step 2: Material and Format Classification

For each component, document the exact material composition, weight, colour, and format. RAM assessments are sensitive to details that might seem minor: the difference between a natural HDPE jar and a white HDPE jar, or between a PP cap and a PP cap with a silicone liner, can change the RAM rating.

Step 3: Rating Determination

Apply current RAM criteria to each component. This requires familiarity with the latest version of the RAM methodology, which is updated annually to reflect changes in UK recycling infrastructure. Components that were Amber last year may have moved to Green if new sorting or reprocessing capacity has come online, or to Red if previously available reprocessing routes have closed.

Step 4: Fee Impact Analysis

Calculate the fee differential between your current component ratings and the best achievable ratings. This analysis reveals the financial incentive for redesigning specific components and helps prioritise investment in packaging improvements.

Redesign Strategies for Improved RAM Ratings

Simplify Multi-Component Formats

The most effective strategy for improving RAM ratings in beauty packaging is simplification. Multi-component formats like pumps, airless systems, and complex closures almost always attract Amber or Red ratings. Where functionality permits, replacing pumps with flip-top or disc-top closures, switching from airless systems to standard tubes, and eliminating non-essential components can dramatically improve ratings.

Material Consolidation

Moving from multi-material to mono-material designs improves both recyclability and RAM ratings. For beauty packaging, this often means replacing metal-spring pumps with all-plastic alternatives, switching from metallised to uncoated cartons, and using mono-material labels with compatible adhesives.

Colour Optimisation

Colour choices significantly affect RAM ratings for plastic packaging. Dark and opaque colours, particularly carbon black, interfere with NIR sorting and attract Red ratings. Switching to light colours, transparent, or NIR-detectable dark pigments can move plastic components from Red to Amber or Green.

The Commercial Case for RAM Optimisation

The fee modulation under UK EPR means that RAM ratings have direct financial implications. For a beauty brand placing 500 tonnes of packaging into the UK market annually, the fee differential between a predominantly Red-rated portfolio and a predominantly Green-rated portfolio could be GBP 50,000 to GBP 200,000 per year.

When combined with the consumer perception benefits of genuinely recyclable packaging and the growing retailer pressure for improved packaging sustainability, the business case for RAM optimisation is compelling across both cost and revenue dimensions.

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