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Packaging EPR Recyclability Assessment Methodology updated

Defra have today (21st of November 2024) published an updated Recyclability Assessment Methodology (RAM) for further comment from stakeholders, following the publication of the first draft and the first survey in October 2024.

Producers will be required to carry out a recyclability assessment in line with the RAM on their household packaging placed on market and packaging that is commonly placed in public bins throughout 2025, the results of which will determine the level of modulation of disposal fees that will be charged to producers in 2026. Read our previous news story, which explains how the RAM will work in further detail.
The results of the recyclability assessments will be required to be reported in producer’s 2025 placed on market data, that Beyondly report on your behalf to the regulator. Beyondly will be in touch with our members in due course with further information on this element of data reporting.

What has been updated in the second version of the RAM?

PA Consulting, on behalf of Defra, have reviewed stakeholder feedback from the first survey, and incorporated this into a revised, second version of the RAM. There have been significant updates, clarifications and changes to the second version of the RAM including, but not limited to:

  • Confirmation that the RAM is only for household packaging, and packaging that is commonly placed in public bins.
  • Alignment with the SI for definitions, such as ‘component’, ‘drinks container’, and exempt packaging.
  • Update of the packaging that will automatically fall into the ‘Red’ category of the RAM and disposal fees will resultantly be modulated higher. There are now only four categories of packaging that this applies to, they are packaging with:
    • Integrated electrical componentry inc. batteries
    • Substances of very high concern (SVHC)
    • Inks excluded by the EuPIA
    • Per- and Polyfluoroalkyl Substances (PFAS)
  • Confirmation that any packaging currently using OPRL labelling for take back schemes should have sufficient evidence to meet the definition under the RAM.
  • And a wide range of changes and clarifications for the assessment of each individual material based on feedback from stakeholders.

We encourage stakeholders, particularly producers who this will directly impact, to review the draft RAM and feedback your views on how it could be improved via the second survey, before the deadline of 5pm on Wednesday 27th of November 2024. The feedback will be used to produce the final version of the RAM, which will be published by Defra in December 2024.

Key takeaways
  • Following stakeholder feedback via a survey on the first draft of the RAM, the second draft of the RAM has been published for further stakeholder feedback, to finalise the methodology and guidance. There are several updates, clarifications, and changes to the methodology and guidance in this second version.
  • In line with the RAM, producers will be required to assess the recyclability of household packaging and packaging commonly placed in public bins. The outputs will be reported in the bi-annual placed on marketing data, and is used to inform the level of modulation of 2026 disposal fees from 2026 onwards.
  • There is opportunity for further stakeholder feedback via a second survey, which will be used to produce the final version of the RAM. The survey is open until 5pm on 27th of November 2024.
  • Defra will publish the final version of the RAM in December 2024 on gov.uk.

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 contact your account manager or drop a line to our team on packaging@beyond.ly. We’ll be happy to discuss any issues you may have and how we can help.