Recyclability Assessment Methodology: RPS released

A Regulatory Position Statement (RPS) was released on 27 June by the Environment Agency concerning the first submission of data relating to the Recyclability Assessment Methodology (RAM).

Producers were due to assess their packaging against the Recyclability Assessment Methodology (RAM) and submit this as part of their current H1 2025 EPR data submission.

The RPS outlines that large producers are still legally liable to submit H1 2025 data with the corresponding RAM ratings as planned. However, the EA have stated that they “will not normally take enforcement action” against businesses that do not submit H1 RAM outputs, provided they comply with the rest of the conditions set out in the statement.

What does this mean for producers?

Producers now have three options for submitting RAM data and can choose to do one of the following:

Assess their H1 2025 packaging against the RAM as planned and include RAM data as part of their forthcoming EPR submission.
Assess their H1 2025 packaging against the RAM but submit their H1 RAM data with H2 2025 data in early 2026.
Choose not to assess their packaging against the RAM for H1 2025. Producers can make their first mandatory RAM data submission in 2026 for H2 2025 data. If no RAM data for H1 2025 is submitted, PackUK will use the H2 data to extrapolate for the full year and charge waste management fees against this extrapolated data.

Ecosurety strongly recommend that producers choose option one.

What are the benefits of submitting RAM data now?

Including RAM data as part of the upcoming EPR submission as planned means producers can:

Avoid unnecessary waste management fees. Applying the RAM to their packaging now means that producers can identify packaging components with an unknown recyclability status sooner. This means they can engage with their suppliers earlier to get the information they need to apply a RAM output to their packaging. This will accelerate how quickly they can reduce their waste management fees by applying fewer red statuses by default, due to lack of data.