For producers EPR cost impact is big, the complexity is high, the resource to deliver this inhouse isn’t available – so we’ve developed a solution to help you through RAM v1.1.
If you place consumer packaged goods on the UK market, the next EPR packaging compliance deadline is uncomfortably close. The biannual EPR reporting point in February 2026 includes a requirement that is proving hard for many small and mid-size producers to manage. Every item of household packaging must be assessed using the Recyclability Assessment Methodology, the RAM, and the results included in your packaging EPR submission. For many businesses that is only ten weeks away. This is not a simple data exercise. RAM affects the modulated fees you will pay from 2026 onward. The cost difference between a red rating and a green is expected to be greater than 20%.
Why RAM feels complicated
UK Extended Producer Responsibility legislation is technical by design. It asks producers to look beyond packaging formats and consider what happens in real waste systems. If householders dispose of your packaging, you need to understand how well it is collected, sorted and reprocessed in the UK. RAM breaks this down into clear stages but applying them to real portfolios is a challenge. PackUK have published guidance on how to apply the RAM, but the fragmentation and multiple criteria mean application to product or component data feels disjointed. This doesn’t gel readily with the overall data methodologies that I’ve seen from producers calculating total packaging volumes per product.
Each packaging component needs its own red, amber or green rating. You assess whether the material is widely collected, whether UK facilities can sort it, whether it can be reprocessed at scale, and whether it has viable end applications. Items like flexible films, various grades of rigid plastics, composite structures, closures and labels often create the most uncertainty. A single SKU can involve multiple components that require separate classification.
For a small or mid-size producer this becomes a serious workload. You need material level detail, component weights, and clarity on whether you act as the brandholder, importer or manufacturer when reporting. Unlike the former PRN regime, estimates are no longer acceptable. RAM demands evidence and consistent application of the published criteria.
Why internal teams are struggling
Many businesses planned to manage RAM internally. Once they started to interpret the guidance, the volume of decisions became clear. Without tools that follow the structure of RAM v1.1, teams find themselves comparing spreadsheets, searching advisory updates, and second-guessing definitions.
The cost of errors is not trivial. If your data is wrong, you might underpay and face enforcement or overpay without realising. If you skip assessment, items default to red and attract a 20% uplift on your 2026 pEPR fees. For many of the clients I’ve been working with these pEPR fees run into six figures. The penalty for inaction is significant and real.
Why we developed a RAM Classification system
Mark Sayers has advised producers under international EPR systems for two decades. He also sits on the PackUK RAM advisory team, which means he is involved in the technical work that shapes how the methodology is interpreted and applied. Over the past year he has been called upon by smaller brands that face repeated challenges with pEPR compliance and RAM, especially where portfolios include mixed materials, complex packaging and a distant customer base.
It became clear that businesses needed something more practical than static guidance. They needed a structured and reliable way to translate their packaging data into RAM recyclability assessments that stand up to scrutiny. That insight led to the development of a user friendly RAM assessment and reporting system designed specifically for SMEs selling consumer packaged goods into the UK.
How the system works
The classification system helps you carry out packaging recyclability assessments in line with RAM v1.1. It has been refined down to a simple tabulated form, designed to feed into your overall packaging data calculations. It is not generic software so can be easily picked up by any team. The bespoke elements are configured to match the materials, formats and business activities relevant to your product and packaging portfolio.
Key functions include:
- Structured component mapping
- Built in RAM logic based on latest v1.1 guidance
- Clear red, amber or green outcomes
- Scalability for different portfolio sizes.
Why this matters in the long term
RAM is not a one off task. You will submit recyclability reporting every six months. As packaging formats change, materials evolve, and the methodology is updated, you will need a repeatable and evidence based process.
By putting structure around your EPR packaging reporting requirements now, you protect your business from rising costs in 2026 and give yourself time to redesign packaging where it delivers meaningful savings. You can see cost hot spots, understand where flexibility exists in your supply chain and avoid the cycle of last minute rush for compliance.
The risk of doing nothing
If you do not complete RAM assessments, you default to red. That adds at least a 20% uplift from the baseline to your fees in 2026. Over a full reporting year this can be substantial for even modest portfolios when measured against the latest pEPR invoice (aka Notice of Liability). You also signal to regulators that your packaging data lacks the detail of the latest Regulations, so may not meet compliance requirements. In a competitive market this puts the cost of your products at a disadvantage while others optimise their packaging for lower EPR costs.
Discuss your solution
With the next deadline approaching, now is the time to assess whether your internal process is enough. If you are a UK importer, brandholder or manufacturer of consumer packaged goods that end up in household waste streams, the Circumetrics classification system gives you clarity, structure and confidence.
Mark Sayers can walk you through how our RAM system adapts to your portfolio and help you establish a reliable path to EPR compliance for SMEs.
Get in touch to discuss how Circumetrics RAM classification system can support your business and ensure you meet the next reporting deadline with confidence.