UK packaging producers are being urged to examine complete packaging structures rather than relying on broad recyclability claims as the country’s extended producer responsibility system moves toward recyclability-based fee modulation.

PackUK published its Recyclability Assessment Methodology (RAM) 2027 guidelines in July, setting out how packaging recyclability will influence producer fees next year.

Waste and recycling company Bins.co.uk has highlighted four packaging design and data issues that could affect assessments: complex material combinations, limited real-world recyclability, incompatible components and insufficient technical evidence.

The changes reinforce an important shift in packaging regulation: being technically capable of recycling is not necessarily enough if the package cannot be collected, sorted and reprocessed effectively at scale.

Complex Material Combinations Can Affect Recyclability

Combining multiple materials can provide packaging with useful properties, from barriers and mechanical strength to appearance and functionality.

The problem occurs when those materials cannot be separated or processed effectively within existing recycling systems.

Multilayer structures and incompatible material combinations can interfere with sorting and reprocessing, potentially affecting the packaging’s RAM classification.

For producers, this creates another reason to examine whether packaging structures can be simplified without compromising essential product protection or performance.

Material reduction alone is not necessarily the objective.

A simpler structure still needs to provide the required shelf life, protection and functionality. The design challenge is to achieve those requirements while minimizing components that interfere with recycling.

Technical Recyclability May Not Be Enough

One of the most significant aspects of RAM is its focus on what happens to packaging under real operating conditions.

A material might theoretically be recyclable under laboratory or specialized processing conditions but have limited recycling potential if the necessary infrastructure is unavailable at sufficient scale in the UK.

RAM therefore considers more than the intrinsic properties of the packaging material.

The assessment follows the recycling chain through collection, sorting and reprocessing, as well as whether the recovered material has a viable subsequent use.

This distinction could become increasingly important for packaging claims.

Producers may need to demonstrate not simply that a package can be recycled, but that an established recycling pathway exists for it within the relevant market.

Labels and Adhesives Can Change the Result

Another potential mistake is assessing only the primary packaging material.

A bottle, tray, carton or flexible package rarely consists solely of its main substrate.

Labels, sleeves, adhesives, closures and inserts can affect how the complete package behaves during sorting and recycling.

A component representing only a small proportion of the package by weight may still create problems if it interferes with material identification, separation or reprocessing.

This means packaging developers need to assess the complete construction rather than treating secondary components as insignificant.

It also increases the importance of coordination between packaging manufacturers, label suppliers, adhesive producers, converters and brands during product development.

Producers Need Evidence to Support Recyclability

Packaging data will become another critical consideration.

Producers need accurate information about the materials, components and structures used in their packaging to determine how they perform against RAM criteria.

This may require more detailed technical information from suppliers.

Waiting until a package has already entered the market can make changes more difficult and expensive.

Obtaining material and recyclability information during development gives producers an opportunity to identify components that could negatively affect their assessment before designs are finalized.

It can also provide evidence needed to substantiate recyclability claims and classifications.

pEPR Links Packaging Design With Producer Costs

The UK’s packaging extended producer responsibility system changes the economic significance of recyclability.

Historically, improving recyclability could primarily be treated as a sustainability or corporate packaging objective.

Under fee modulation, packaging design can also have a more direct financial consequence.

If a packaging format performs poorly against recyclability criteria, producers may face higher costs. Designs with stronger recycling outcomes can therefore become relevant to both environmental performance and packaging economics.

This creates an incentive to consider end-of-life performance earlier in product development.

For packaging buyers, procurement decisions may increasingly need to account for the potential EPR implications of a material or component alongside its conventional purchase price.

RAM Moves Focus From Claims to Recycling Systems

Mark Hall, a dry mixed recycling specialist at Bins.co.uk, said RAM creates a clearer distinction between aiming for recyclability and demonstrating that recycling can occur at scale.

He noted that the methodology considers the entire recycling chain rather than only the principal packaging material.

As a result, producers may need to reassess existing packaging, obtain additional supplier information and build stronger evidence around recycling performance.

The broader implication extends beyond RAM itself.

Packaging regulations are increasingly evaluating system performance rather than material labels alone.

A package can be made predominantly from a commonly recycled material and still perform poorly if its coatings, labels, adhesives or other components disrupt processing.

Likewise, a theoretically recyclable material provides limited circularity benefits when collection or reprocessing infrastructure does not exist at meaningful scale.

For UK producers preparing for RAM 2027, recyclability is therefore becoming a question that needs to be answered across the complete packaging and recycling system — from initial design and material selection through collection, sorting, reprocessing and the eventual use of recovered material.

Source: PackUK and Bins.co.uk.

Last Updated on 31/08/2026 by Jota Machinery