GovWire

Guidance: Recyclability assessment methodology: how to assess your packaging waste

Natural Resources Wales

December 23
00:00 2024

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From 1 January 2025, liable producers who supply household packaging must assess the recyclability of that packaging and report the results of the assessment to the environmental regulator.

Find out about EPR for packaging. This collection of guidance includes information on who is affected (liable), what data to collect and how to report

To do this, you will need to assess packaging you supply using the recyclability assessment methodology (RAM).

The RAM is also available in Welsh (Cymraeg).

Different kinds of packaging receive different ratings - red, amber or green. This rating affects the disposal fee that will be charged for that packaging. This is sometimes called fee modulation.

You must assess all household packaging you supply.

This is an overview of the RAM. There is separate technical guidance that explains:

Who has to do this

Only large producers (also known as large organisations) must report their recyclability assessment data. Find out about small and large producers.

Find out about small and large producers.

What packaging you must assess

You only need to collect and report recyclability assessment data if you are responsible for household packaging.

Categories of material

There are 8 categories for materials. These are often called specified materials.

Each item of packaging or component should be assessed under one of these categories.

If your unit or component is made up of more than one of these materials, assess it under the category that makes up most of its weight.

Separate guidance explains how to apply the RAM to each category of material. Use that guidance to assess whether your packaging unit or component isred,amberorgreen.

Drinks containers

For glass containers, other parts that come away easily should be assessed separately from the glass body.

This includes things like metal lids and screw tops. It does not usually include labels that cannot be removed without effort or tools. These should be assessed as part of the container.

For steel, aluminium and PET containers, include all the other parts in the total weight. Report the drinks container as whatever material makes up most of the weight.

Outputs: the red, amber, green scale

Packaging will fall into one of 3 categories:

In addition to the material category, packaging will fall into one of 3 sub-categories:

  • redpackaging has specifications that make it difficult to recycle at scale
  • amber packaging may experience challenges during collection and sortation, requires specialist infrastructure for reprocessing, the efficiency and output quality of reprocessing is affected, or there is some secondary material loss
  • greenpackaging is widely recyclable in the current UK infrastructure

Materials that are exempt

Some packaging is exempt:

  • reused packaging, unless it has been imported into the United Kingdom
  • any packaging exported from the United Kingdom by the producer

Automatic reds (problematic packaging)

Some packaging and components of packaging always count as red on the scale.

Items of packaging or components must be classified as red if they contain any of the following above the limit of detection:

  • integrated electrical components or batteries that would be classed as Electrical and Electronic Equipment (EEE) - for example, boxes that include LED lights
  • any of the substances of very high concern (SVHC) under UK REACH
  • inks that are manufactured in compliance with the EuPIA Exclusion Policy for Printing Inks and Related products
  • perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) that have been intentionally added

How this will affect what you pay (modulation)

Full details of how fees will be modulated will be published in 2025.

What you must report in 2025

You need to submit recyclability assessment data about all household packaging placed on the market.

You must enter the results of your assessment on the packaging data file that you submit to the regulator through the report packaging data service. There are initial details on how to do this in the guidance that explainshow to create your file for EPR. More details will be published closer to the date you must report.

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