Under RAM 2027, packaging can default to Red, the costliest rating, simply for lack of evidence to prove otherwise. We look at how some of those Reds can be turned Amber or Green, and the key role that component-level packaging data plays.
PackUK’s Recyclability Assessment Methodology (RAM) rates household packaging Red, Amber or Green. Large producers must report these ratings, which affect the disposal fees they pay under pEPR (packaging Extended Producer Responsibility). RAM 2027 applies to packaging supplied in the UK during 2027, while RAM version 1.1 still governs 2026.
But here’s the problem: Red doesn’t only mean hard to recycle. Where a producer can’t provide enough evidence for Amber or Green, the packaging must be reported Red. So a recyclable component can incur the same Red fee as one that isn’t recyclable if the data behind it is missing.
The good news is that some of those Reds can be removed with better data. In this guide we’ll look at what Red costs, how packaging ends up Red, and where to act first to improve the ratings you can.
In this article
How much could a Red rating cost?
Red costs the most, and the premium rises each year. The Red multiplier on the Amber fee is 1.2x in 2026/27, 1.6x in 2027/28 and 2.0x in 2028/29. As an illustration, PackUK cites 2026/27 plastic fees of £455 per tonne at Amber and £545 at Red, so 500 tonnes would cost £45,000 more at Red.
These figures are illustrative and based on 2025 packaging data. PackUK expects to issue its 2026/27 notices of liability by the end of November 2026. RAM 2027 assessments will inform fees for 2028/29, when the Red multiplier reaches 2.0x.
£45,000 more at Red
Based on PackUK’s illustrative 2026/27 plastic fees, 500 tonnes of packaging rated Red rather than Amber would cost an additional £45,000.
How does packaging end up rated Red?
Let’s look at the two major hurdles packaging must clear to avoid a Red. First comes a check against a fixed list of automatic Red triggers. Fail that, and it’s Red.
But packaging that clears the check must clear a second hurdle. Across each of four recycling stages, the assessment asks: is there enough evidence to support anything better than Red?
The first hurdle: the automatic Red check
Before any assessment, packaging is checked against a fixed list. It gets rated Red straight away if it:
- contains an integrated electrical component or battery;
- is a format already restricted or being phased out in the UK, such as certain single-use plastics;
- contains more than 1 ppm (parts per million) of total PFAS or, in food packaging, more than 25 ppb (parts per billion) of any individual PFAS or of total PFAS;
- contains substances of concern above limits under UK REACH, SVHC, POPs, biocides or CLP rules;
- uses inks not made in line with the European Printing Ink Association charter; or
- fails UK food-contact legislation.
Failing any one of these ends the assessment. Passing them isn’t enough, though, because everything that clears the list faces a second hurdle.
One Red result is enough
Green at every stage is required for an overall Green rating. Amber at any stage limits the rating to Amber, while Red at any stage makes the entire assessed item Red.
The second hurdle: evidence across four recycling stages
Packaging that clears the automatic check is now assessed at four stages: collection, sortation, reprocessing and application. Evidence (or lack of it) can be the deciding factor, and it can catch you in any of three key areas: chemicals, materials/components, and formats.
To get a Green rating, you need a Green result at every stage. An Amber result at any stage caps the rating at Amber, and a Red result at any stage makes the item Red.
At each stage, where a producer can’t evidence Amber or Green, the result is Red. Integrated components are assessed as one item using the predominant material by weight. While this can improve the rating of some individual materials, the whole item will be Red if it fails any applicable Red criterion.
1/ Chemical thresholds
Each chemical trigger needs its own evidence: a test result or supplier declaration covering PFAS, substances of concern, inks and food contact. That data usually sits with suppliers, and a declaration is strongest when it names the threshold it meets. Without it, the packaging is unproven on that point and must be reported Red, even if it’s compliant.
The PFAS limits are being challenged by industry bodies and PackUK is reported to be reviewing testing approaches. Until any changes are published, producers should continue to follow the current RAM 2027 criteria.
Chemical data is the first place records run out. The second is the components themselves.
2/ Materials and components
Closures, labels, adhesives, sleeves, liners and coatings get less scrutiny than the main material, yet any one of them can be where the evidence ends. Where evidence is missing, PackUK’s position is simple: ask the manufacturer or supplier.
How a component is assessed also affects the result. RAM assesses separable components individually and integrated components as part of the item, using the predominant material by weight. A flexible plastic label assessed alone is Red, for example, but the same label on a glass jar can be rated Green with the jar.
Integration doesn’t always help. On rigid plastics, a label adhesive that fails to release in a 70 to 90°C hot wash makes the pack Red. So do carbon black pigment that blocks near-infrared sorting and PVC, including a PVC component. A pack that fails these criteria stays Red whatever its records say.
3/ Formats
Components can be checked one at a time. But formats depend on how the UK collects packaging, which no single producer controls.
At the collection stage, a format collected at kerbside by at least 75% of UK local authorities counts as commonly collected, and 50 to 75% counts as limited collection. Anything else is Red unless take-back scheme evidence supports Amber.
Not every Red has the same solution
Missing evidence may be resolved by obtaining the right supplier information. But where packaging fails a recyclability criterion, better records alone won’t change the rating. That calls for a decision about design, collection schemes or accepting the higher fee.
To qualify, a scheme must reach at least 75% of the UK population within 5 miles (or cover 75% of addresses by post), accept all brands, require no purchase and be traceable through all four recycling stages. Producers must also notify PackUK, which says it will publish guidance on how to do this.
Plastic flexibles can’t be Green in 2027. They’re Red unless take-back evidence is in place, which can lift them to Amber. For some formats no qualifying scheme exists, and better records won’t change the rating. The same applies to new formats the UK system doesn’t yet recognise at scale, so innovation carries risk.
What to do now
With the sources of Red ratings mapped, the next question is which of them can be fixed with data and which need a decision.
- Screen every component against the automatic Red list first.
- Audit each component, including closures, labels, adhesives and inks, for its material, weight, how it’s attached and what supplier declarations exist.
- Sort the Reds by cause. A missing record is a data problem. A design feature such as PVC or carbon black, or a format with no qualifying scheme, calls for a design or commercial decision.
- Prioritise by tonnage multiplied by fee uplift, starting with the fixes that save the most for the least effort. As the worked example below shows, the largest exposure isn’t always the best place to start.
Prioritisation: a worked example
Take two plastic components at the £90 per tonne uplift between Amber and Red (using PackUK’s illustrative 2026/27 fees). A 200-tonne bottle missing an ink declaration has £18,000 at stake but needs just one supplier request to fix. A 500-tonne flexible pouch with no scheme has £45,000 at stake, but requires much more effort to remedy: build or join a scheme, redesign or accept Red.
Recommended action: Send the bottle request now and take the pouch to a decision in parallel.
Keeping RAM evidence up to date
Producers must keep the evidence behind each rating for 7 years and update assessments when the packaging changes or a RAM change affects the outcome.
A change of supplier, specification or format should prompt a re-check. Records also have to keep pace with the rules, and the rules are tightening.
How could RAM requirements change after 2027?
RAM is revised each year. PackUK has signalled that future versions (after 2027) may add automatic Red criteria for packaging with no verified recycled content and for excessive packaging, such as unnecessary empty space or fillers.
RAM is UK-specific, but overseas suppliers whose products enter the UK market may need to supply the data their UK customers require.
The EU’s Packaging and Packaging Waste Regulation (PPWR), applicable since August 2026, is a different regime and shouldn’t be compared directly with RAM. However, it also places significant demands on packaging data and supporting evidence, with further requirements being phased in over time. Manufacturers must undertake conformity assessments and issue EU Declarations of Conformity for packaging against applicable requirements. This depends on having complete, accurate technical information, with added complexity for businesses operating across different countries and regulatory systems.
Whichever rules apply, the starting point is the same.
The first step is data
Some Reds depend on evidence and can move once the records show the packaging is compliant. Others can’t, and need a decision about design, schemes or fees.
Knowing which situation you’re in takes complete, component-level data: what each component is made of, how it’s attached and what evidence supports it, held somewhere it can be found, queried and updated. But that information also needs to be accessible, kept up to date and linked to the relevant packaging specifications. Without that foundation, producers risk repeating assessments, chasing missing information and paying higher fees than necessary.
Can you find the packaging data you need?
Accurate RAM assessments rely on detailed packaging specifications, supplier information and supporting evidence. 4Pack helps bring this information together, making it easier to access, manage and keep up to date.
