Key Takeaways

  • Understand evolving EPR obligations: Learn how UK Extended Producer Responsibility (EPR) timelines and data requirements are changing and what producers must do to remain compliant.
  • Navigate eco-modulation and RAM: Explore how recyclability assessments and modulated fees will reshape producer costs starting in 2026.
  • Adopt digital compliance tools: Discover how automated EPR and RAM software solutions simplify complex reporting and ensure accuracy.

Introduction

Extended Producer Responsibility (EPR) continues to evolve across the UK, introducing new reporting and recyclability assessment rules. Eco-modulation links fees to a product’s environmental impact, pushing producers to rethink packaging design and recyclability.

Under this system, producers pay higher fees for hard-to-recycle packaging and benefit from lower costs when using easily recyclable materials. The Recycling Assessment Methodology (RAM) underpins this process, setting measurable standards for recyclability.

EPR in the UK: Key Updates & Deadlines

UK producers are required to collect and report packaging data under the new EPR framework. Reporting frequency depends on company size:

  • Large producers: Must report packaging data twice yearly in April and October.
  • Small producers: Report once per year, with the first submission due April 2025.

The UK Government launched early data collection in 2024 to help companies:

  • Estimate upcoming modulated fee responsibilities.
  • Build consistent data systems for smoother submissions.
  • Review recyclability and transition to sustainable materials.

Eco-Modulation & RAM Explained

RAM, developed by PA Consulting and Defra, standardises how recyclability is measured across the UK. From January 2025, large producers must assess and submit recyclability results for household packaging.

RAM uses Red, Amber, and Green ratings to classify packaging recyclability.

  • Red: Hard to recycle at scale, higher modulation fees.
  • Amber: Moderately recyclable, standard fees. It 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.
  • Green: Easily recyclable with current UK infrastructure, leading to lower fees.

From 2026, fees will directly link recyclability to costs. Unsustainable packaging may see fees rise up to 2× by 2028.

Note: There are separate codes for medical packaging. Read the guidance below for more details.

Materials that are exempt

Some packaging is exempt from a recyclability assessment:

  • Reused packaging, unless it has been imported into the United Kingdom
  • Any packaging exported from the United Kingdom by the producer
  • Drinks containers made of polyethylene terephthalate (PET) plastic, steel or aluminium
  • Drinks containers for which a deposit is payable and is within scope of a DRS which is in operation
  • Non-household packaging

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 and they have been intentionally added:

  • Integrated electrical components or batteries that would be classed as Electrical and Electronic Equipment (EEE) - e.g., boxes that include LED lights
  • Any of the substances of very high concern (SVHC) above the specified thresholds set out under UK REACH
  • Inks not manufactured in compliance with the EuPIA Exclusion Policy for Printing Inks and Related products
  • Any household packaging within scope of RAM which has not been assessed or where the detail required to undertake an assessment isn’t available

If perfluoroalkyl and polyfluoroalkyl substances (PFAS) have been intentionally added to packaging, this is also an automatic red. However, this does not apply if the predominant material is aluminium, steel or glass.

Medical packaging

Medical packaging is immediate or outer packaging on:

  • Medicinal products
  • Veterinary medicinal products
  • Medical devices

Immediate packaging that is in immediate contact with the product.

Outer packaging is any packaging into which the immediate packaging is placed.

Find out more about medicinal products in the Human Medicines Regulations 2012.

If uncertain whether a product counts as medical, check with the Medicines and Healthcare products Regulatory Agency (MHRA). They provide guidance on how to tell if your product is a medicine.

Medical packaging must be reported under different codes:

  • Red - medical
  • Amber - medical
  • Green - medical

If you assess your medical packaging as Red - medical just due to a regulatory requirement, it can be reported as Amber - medical with supporting evidence. Otherwise, it is subject to modulation like other red-rated materials.

RAM TreeFigure 1: RAM Decision Tree Example

How Our Platform Supports EPR and RAM Compliance

Remedy EPR automates EPR and RAM compliance, managing packaging data, recyclability assessments, and reporting. The integrated RAM ruleset identifies cost drivers and predicts modulated fee impacts.

Core Advantages of Digital Compliance

  • Automated data capture and categorisation
  • Instant recyclability scoring with RAG classification
  • Real-time visibility into modulated fees
  • Built-in alerts for reporting and legislation updates
  • Ongoing updates aligned with the latest EPR/RAM guidance

Adopting digital compliance tools reduces manual effort, prevents costly errors, and prepares your business for 2026 fee modulation.

Stay Ahead of the Curve

As the UK transitions into a modulated EPR model, proactive data collection and recyclability analysis will set sustainable brands apart. Early preparation ensures operational efficiency, lower costs, and stronger environmental credibility.