Defra’s Recyclability Assessment Methodology published
Defra have today (17th October 2024) published the Recyclability Assessment Methodology (RAM) publicly for comment from stakeholders, via their Resource & Waste Newsletter.
What is the RAM?
The RAM is a methodology of how primary and shipment packaging placed on market by producers will be assessed for recyclability and the resultant modulation of disposal fees from year 2 of operation (2026 disposal fees, based on 2025 placed on market data). We are unsure if this must be carried out on non-household packaging, which is not subject to a disposal fee, at this time.
You can access the RAM via this public link.
Survey and timeline
The RAM has been produced by PA Consulting on behalf of Defra and has been developed collaboratively with representatives from industry across the packaging value chain. PA Consulting is seeking views and feedback on the RAM methodology and guidance in its current form.
You can access the survey here.
The survey is open for two weeks, closing on the 31st of October 2024. Following this, there will be a second draft shared for testing and further feedback in November.
Once the surveys are complete, PA Consulting will amend and refine the RAM guidance into its final form, and hand this over to Defra by the end of November 2024. Defra will need to approve the RAM and the guidance during December 2024, to publish the final version for producers to use from January 2025.
Producers will be able to access and use the final approved RAM guidance and some form of document to input their packaging into from January 2025.
How will the RAM work?
Packaging will be inputted into the RAM, and a Red, Amber, or Green output will reflect the recyclability of that packaging. This output will inform the level of disposal fee modulation for that packaging for 2026 disposal fees onwards. Modulation means the increase or decrease of the base disposal fee, to incentivise producers to use more recyclable packaging.
As a reminder, the first year of disposal fees (2025 fees, based on 2024 placed on market data) will not be modulated, a flat base fee will be charged per material. Whereas, for the second year of fees, these will be modulated (2026 fees, based on 2025 placed on market data).
To assess recyclability, the RAM evaluates 4 elements of the recycling process:
- Collection: if the packaging is collected by local authorities or by other dedicated collection services;
- Sortation: if the packaging is designed to be sorted at scale;
- Reprocessing: if the packaging can be reprocessed without harm, challenges or compromised quality;
- Application: if the reprocessed packaging waste has a suitable application that could replace virgin material use.
The output from this assessment will classify the recyclability of the packaging as either:
- Red: a challenge to recycle this packaging at scale that are problematic for waste management systems to handle;
- Amber: are recyclable, but may have limited or inconsistent infrastructure support or contain items that are detrimental to the recycling process, but do not prevent it entirely;
- Green: widely recycle within the UK’s existing waste management systems.
Disposal fees which apply only to household packaging, will be modulated based on the red, amber or green rating of this assessment. Disposal fees will be modulated in this way and charged to producers to influence packaging design towards increased recycling performance across the UK. To meet the core aims of packaging EPR, which to incentivise recyclability and reuse of packaging, and to encourage more domestic reprocessing and overall system improvements and savings.
Final list of problematic packaging items
The RAM guidance contains a list of problematic packaging items which will automatically fall into the ‘Red’ category and be modulated higher. This means disposal fees will be automatically higher for producers placing these packaging items on the UK market, to try and disincentivise their use.
- The packaging has integrated electrical componentry and/or batteries that would be classed as Electrical and Electronic Equipment (EEE) for example, boxes that include LED lights
- Component is made of plastic containing Carbon Black pigment
- Component is made of PVC (including non-PVC with PVC components)
- Component is made of Polystyrene HIPS, expanded & extruded
- Component is made of Compostable and degradable, including bio- or oxo-degradable
- Component is made of Non-polyolefin foamed plastics e.g. non-PP and non-PE
- Component is made of paper or board and has double sided lamination
There were previously 13 packaging items shortlisted for automatically higher modulation, but this has been reduced down to 7.
Why is it important for stakeholders to respond to the survey?
The methodology will determine how disposal fees invoiced in 2026 will be modulated. 2026 fees will be determined by packaging placed on the market during 2025, and so on in subsequent years. So, the RAM will have financial implications for producers placing household packaging on the UK market from 2025 onwards.
We would therefore encourage producers and members of Beyondly to review the RAM guidance and share your feedback via the survey, so your views are considered and the RAM can be further refined.
Beyondly took part in a feedback session with PA Consulting before this draft was shared publicly, which was very constructive with feedback shared to improve the guidance and the methodology before it is handed over to Defra.
Key takeaways
- A draft of the RAM has been published for stakeholder feedback, to finalise the methodology and guidance. There will be a second opportunity to feedback in another survey in November, before it is handed over to Defra in December 2024.
- The RAM will assess recyclability, and the outputs will be used to inform the level of disposal fee modulation on household packaging producers place on the market from 2025.
- As the RAM and guidance will be used by producers and will impact the disposal fees invoiced from 2026 onwards, we encourage producers to review and feedback.
- The survey is open until 31st October 2024.
Support for producers
Beyondly are here to support our members every step of the way during the pEPR reform, so if you have any questions or would like to share your thoughts with us, please drop a line to our team on packaging@beyond.ly
We would recommend signing up to the Resources & Waste newsletter published by the Government, in which they share the latest news and engagement sessions relating to the resources and waste reforms.