EPR, RAM and DRS – Why packaging data accuracy has never mattered more

Many businesses will be feeling the pressure of multiple emerging Extended Producer Responsibility (EPR) obligations this year, as requirements under the now fully enacted Producer Responsibility Obligations Regulations become a reality. In 2025, many organisations will have several regulatory obligations that need to be fulfilled for the first time.

The reality of EPR’s impact on businesses is becoming realised financially too, as EPR fee estimations loom large ahead of invoicing in October. The consequence of these competing pressures has led to a more urgent need for early preparation this year, especially given the technical understanding of the regulations needed to do so is – in some areas – still being agreed and communicated to industry.

Prepare for the Recyclability Assessment Methodology

Those classed as ‘large producers’ under EPR should be aware that the first submission of packaging data that must be analysed against the Recyclability Assessment Methodology (RAM) is due in October to the regulator (and earlier to compliance schemes such as Ecosurety), for packaging supplied in the first half of this year (2025).

The RAM sets out the features of packaging that impact its recyclability at each stage of the recycling process – including collection, sortation, reprocessing and application. It is broken down by material type, and indicates features which may hinder the packaging component’s ability to be recycled. A ‘red’, ‘amber’ or ‘green’ (RAG) result is then associated to the component accordingly.

The RAM must be used for all household, commonly street binned and shipment packaging that larger producers place on the market.

The RAG result will then be used by government to eco-modulate Waste Management Fees (WMF). From 2026, easily recyclable packaging will attract a proportionally lower WMF per tonne compared to materials that are classed as difficult to recycle.

Recyclability data: the cost of getting it wrong

The RAM constitutes a significant additional data burden for producers, but the value in ensuring its accuracy was highlighted recently as Defra shared an example of how EPR fee modulation, starting in 2026, may look for the first three years.

The illustrative modulation rates suggested packaging that is assigned as ‘red’ via the RAM could be charged 1.2 times the material base fee in 2026, 1.6 times in 2027, and double by 2028. As an example, the indicative base fee rate for plastic this year is £485, meaning plastic allocated a ‘red’ RAM rating may cost organisations nearly £1000 per tonne in a few years. For producers with high exposure to plastic, fibre-composite and paper materials (the materials which have the most wide-ranging factors to consider for recyclability, and therefore have the biggest challenges to achieve green statuses), this will be a real focus, as the risk of being in the red category and seeing fees double is much higher.

A further consequence of not having the required level of RAM data is a ‘red’ classification by default of the relevant packaging, meaning a higher fee next year for formats that don’t necessarily warrant it.

DRS on the horizon

As we see EPR fees being implemented this year, and modulation from 2026, drinks producers will also have to start contending with Deposit Return Scheme (DRS) implementation plans. The DRS legislation for England and Northern Ireland has now passed – Scotland will amend their existing regulations in order to align – and a Deposit Management Organisation (DMO) for all nations other than Wales has been appointed by Defra. If a DRS is to be operational by 2027, as is stipulated in the regulations, then impacted businesses should expect more data collection and submission, and cost, obligations in the next few years.

Although drinks containers in-scope of the future scheme are exempt from EPR local authority disposal fees, this is only because the producers of them are expected to invest in the DRS setup costs ahead of implementation. These costs could be made more significant depending on whether the Welsh scheme will follow suit with the rest of the UK in terms of implementation timelines, and the exclusion of glass bottles.

Data accuracy is critical

The above is in addition to other requirements under the legislation, which are perhaps less burdensome, but increase the need for granular packaging data coverage nonetheless.

For instance, in 2025, businesses will need to collect data on the amount of plastic and paper bags they have supplied in England, and report this in 2026. Furthermore, despite a welcome Regulatory Position Statement confirming that this year’s submission won’t be enforced, organisations small and large alike must not forget the additional nation of sale data reporting requirement.

Essential EPR data deadlines

The technical nature of the various data requirements, in addition to the inevitable information sharing along supply chains that will be necessary, means there is a lot for businesses to understand and start acting upon. Essentially, inaccurate packaging data and poor coverage will mean inaccurate EPR costs and, potentially, enforcement consequences.

The increased scale of EPR and additional compliance costs means the accuracy of data is now vital.

If you're an Ecosurety member visit the Ecosurety Hub to find out more about your EPR data requirements, the RAM and DRS.