Recyclability Assessment Methodology: Regulatory Position Statement 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.
- Improve waste management fees cost forecasting. Submitting H1 2025 RAM data now means that producers can more accurately forecast their waste management fees for future years using analytics tools. Ecosurety members can explore the range of tools available to them on the Ecosurety Hub.
- Ensure waste management fees are accurate. Waste management fees will be applied to packaging from 2026, based on 2025 data. These fees will be less accurate if producers don’t submit RAM data now as the fees for H1 2025 will be based on extrapolated data rather than real RAM data submitted by the producer.
Our systems are ready
Robbie Staniforth, Chief Policy and Impact Officer, commented:
“For some, there simply hasn't been enough time to assess their packaging data against this recycling methodology, given the delays over the last several years. However, our systems are ready and we aim to help all members make a first attempt at their assessments during the fast-approaching submission window. It may not be perfect, but it is a great opportunity to get prepared for modulated fees, which are only a year away.”
Robbie Staniforth
Chief Policy & Impact Officer
If you have any questions about your RAM data submission, please contact your account manager or help desk for assistance.
by Louisa Goodfellow
Policy Manager
2 July, 2025
As Policy Manager Louisa provides key support to our team, including preparing reports on environmental policy issues and maintaining awareness of new developments.
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