Why recyclability is becoming a commercial imperative for plastic packaging: RAM 2027
24 Jul
2026
2026
Paul Rawlings
Launch Manager, kp Food Packaging
Launch Manager, kp Food Packaging
As the UK packaging industry prepares for the introduction of Recyclability Assessment Methodology (RAM) 2027, packaging design is increasingly becoming a commercial issue as much as a sustainability one. The latest updates to the Recyclability Assessment Methodology (RAM), combined with the potential for increased fee modulation under Packaging Extended Producer Responsibility (pEPR), could significantly alter the cost profile of packaging formats currently used across the food industry.
For brand owners, the challenge is no longer simply understanding the regulation – it is understanding what actions need to be taken now to avoid future risk and maintain flexibility.
Share this story
How the latest changes to the UK's RAM will reshape packaging design, material selection and pEPR costs for brand owners.
The direction of travel: real-world recyclability matters
The publication of RAM 2027 marks another significant step in the evolution of the UK's Packaging pEPR framework. While many of the updates appear technical, their implications are fundamentally strategic.
RAM 2027 strengthens the connection between packaging design and financial consequences, placing greater emphasis on real-world recyclability and increasing the incentives to move away from packaging formats that do not perform effectively within the UK's recycling infrastructure.
It is important to distinguish between the RAM methodology and future fee modulation. RAM 2027 has now been published by PackUK and will apply to household packaging placed on the UK market from 1 January 2027. While industry roadmaps indicate an intention to increase the Red fee multiplier* from 1.2x to 1.6x, this remains subject to regulatory confirmation.
It is important to distinguish between the RAM methodology and future fee modulation. RAM 2027 has now been published by PackUK and will apply to household packaging placed on the UK market from 1 January 2027. While industry roadmaps indicate an intention to increase the Red fee multiplier* from 1.2x to 1.6x, this remains subject to regulatory confirmation.
RAM 2027 strengthens the connection between packaging design and financial consequences, placing greater emphasis on real-world recyclability and increasing the incentives to move away from packaging formats that do not perform effectively within the UK's recycling infrastructure.
It is important to distinguish between the RAM methodology and future fee modulation. RAM 2027 has now been published by PackUK and will apply to household packaging placed on the UK market from 1 January 2027. While industry roadmaps indicate an intention to increase the Red fee multiplier* from 1.2x to 1.6x, this remains subject to regulatory confirmation.
The message, however, is increasingly clear: recyclability is no longer simply a sustainability discussion. It is becoming a business performance issue.
For brand owners, this means:
- Packaging design must reflect actual UK recycling capability, not theoretical recyclability
- Packaging components can no longer be considered in isolation
- Design-for-recycling principles become increasingly important
- Packaging choices made today may have significant future cost implications
Beyond design for recycling: designing for disposal
One of the unintended consequences of recyclability frameworks is that they encourage us to assess packaging on a component by component basis.
Consumers do not see trays, films, labels and adhesives. They see a pack.
The question is no longer simply: Can this pack be recycled?
The question is: How will consumers actually dispose of it?
Many fresh food applications are designed with the expectation that consumers will remove lidding films, separate materials and follow different recycling routes. Packaging professionals may view this as straightforward; consumers may not.
Consumers do not see trays, films, labels and adhesives. They see a pack.
The question is no longer simply: Can this pack be recycled?
The question is: How will consumers actually dispose of it?
Many fresh food applications are designed with the expectation that consumers will remove lidding films, separate materials and follow different recycling routes. Packaging professionals may view this as straightforward; consumers may not.
That distinction matters, because RAM 2027 increasingly focuses on real-world recycling outcomes rather than theoretical recyclability. If packaging enters the recycling stream as a complete unit, recycling performance becomes dependent on how consumers present the pack, not how designers intended it to be recycled.
This may require a shift in thinking. The industry may need to move beyond design for recycling towards design for disposal – designing packaging around what consumers actually do, rather than what recyclers hope they will do.
If the most likely outcome is that the pack remains intact, packaging systems should be designed increasingly to deliver successful recycling outcomes, even when components remain attached.
This may require a shift in thinking. The industry may need to move beyond design for recycling towards design for disposal – designing packaging around what consumers actually do, rather than what recyclers hope they will do.
If the most likely outcome is that the pack remains intact, packaging systems should be designed increasingly to deliver successful recycling outcomes, even when components remain attached.
This is one reason mono-material packaging systems are becoming ever more attractive. By reducing material complexity across the complete pack, they reduce reliance on consumer behaviour and simplify the challenges for downstream recycling infrastructure.
As RAM continues to evolve, the packaging formats most likely to succeed may not be those that are theoretically recyclable when fully disassembled, but those that remain recyclable when disposed of exactly as consumers are most likely to present them.
As RAM continues to evolve, the packaging formats most likely to succeed may not be those that are theoretically recyclable when fully disassembled, but those that remain recyclable when disposed of exactly as consumers are most likely to present them.
For PET thermoforms, this means understanding how trays, lidding films, barrier layers, labels and adhesives collectively influence recycling outcomes.
Whole-pack design is becoming increasingly important
A broader theme running throughout RAM 2027 is the recognition that recyclability is determined by the complete packaging system rather than simply the primary material.
For PET thermoforms, this means understanding how trays, lidding films, barrier layers, labels and adhesives collectively influence recycling outcomes.
Businesses using thermoformed packaging should increasingly examine:
For PET thermoforms, this means understanding how trays, lidding films, barrier layers, labels and adhesives collectively influence recycling outcomes.
Historically, packaging specifications prioritised functionality, appearance and cost. RAM 2027 reinforces the need to add recyclability performance to that list.
Businesses using thermoformed packaging should increasingly examine:
- Material combinations
- Barrier technologies
- Lidding film compatibility
- Labels and adhesives
- Features that may interfere with sorting or reprocessing
The focus shifts from whether a tray is made from polyethylene terephlthalate (PET) to whether the complete packaging system performs successfully within the UK recycling system.
The end of the road for PET/PE structures?
Perhaps the most commercially significant change within RAM 2027 is the treatment of multi-material PET structures incorporating other polymers.
The direction of travel is clear. Packaging structures that rely on combinations of PET and PE may face more challenging recyclability assessments than under RAM Version 1.1, potentially exposing brand owners to Red classifications and higher modulated fees.
Historically, PET/PE structures have offered an excellent balance of sealing performance, product protection, shelf life and operational efficiency. RAM 2027 reinforces a preference for mono-material structures that can be more readily collected, sorted and recycled within established infrastructure.
For brand owners, the implications could be substantial. Packaging changes rarely happen quickly, and many organisations may already be running short on time. Shelf-life testing, retailer approvals, factory validation and consumer testing programmes often take months to complete.
The direction of travel is clear. Packaging structures that rely on combinations of PET and PE may face more challenging recyclability assessments than under RAM Version 1.1, potentially exposing brand owners to Red classifications and higher modulated fees.
Historically, PET/PE structures have offered an excellent balance of sealing performance, product protection, shelf life and operational efficiency. RAM 2027 reinforces a preference for mono-material structures that can be more readily collected, sorted and recycled within established infrastructure.
For brand owners, the implications could be substantial. Packaging changes rarely happen quickly, and many organisations may already be running short on time. Shelf-life testing, retailer approvals, factory validation and consumer testing programmes often take months to complete.
Flexible packaging remains under pressure
For many organisations, flexible packaging may become the most difficult packaging format to defend under RAM 2027.
Whilst significant progress has been made in film design and recyclability, the methodology increasingly demands evidence of successful collection, sortation, reprocessing and application within existing UK infrastructure. The challenge is no longer simply designing a recyclable flexible film - it is proving that it is genuinely recycled at scale.
Whilst significant progress has been made in film design and recyclability, the methodology increasingly demands evidence of successful collection, sortation, reprocessing and application within existing UK infrastructure. The challenge is no longer simply designing a recyclable flexible film - it is proving that it is genuinely recycled at scale.
The business case for moving away from complex laminate structures and towards recyclable mono-material alternatives continues to strengthen.
The take-back scheme challenge
RAM 2027 continues to recognise take-back schemes as a potential route for packaging that is not commonly collected through conventional kerbside systems. However, collection alone is not sufficient.
Producers may need to demonstrate successful progression through all four stages of recycling:
Producers may need to demonstrate successful progression through all four stages of recycling:
- Collection
- Sortation
- Reprocessing
- Application
Building this evidence base is likely to require collaboration across retailers, recyclers, scheme operators and brand owners. For many flexible packaging formats, proving recyclability may become as important as designing for it.
Automatic Red criteria increase compliance risk
RAM 2027 introduces a new Automatic Red screening stage before packaging progresses through the standard assessment process.
Packaging may automatically receive a Red classification if it contains excessive PFAS** levels, certain restricted substances, non-compliant food-contact materials, or packaging formats already subject to regulatory restrictions.
For brand owners, this reinforces the importance of material traceability, supplier certification and robust compliance documentation. Demonstrating compliance is becoming almost as important as compliance itself.
Packaging may automatically receive a Red classification if it contains excessive PFAS** levels, certain restricted substances, non-compliant food-contact materials, or packaging formats already subject to regulatory restrictions.
For brand owners, this reinforces the importance of material traceability, supplier certification and robust compliance documentation. Demonstrating compliance is becoming almost as important as compliance itself.
Labels still matter
Labels, sleeves and adhesives remain important elements within recyclability assessments.
Packaging featuring labels that cannot be effectively removed during recycling may attract less favourable outcomes because of their impact on recyclate quality. For organisations that have already invested in recyclable trays and films, label design may represent one of the final opportunities to further improve recyclability performance and reduce future EPR exposure.
Packaging featuring labels that cannot be effectively removed during recycling may attract less favourable outcomes because of their impact on recyclate quality. For organisations that have already invested in recyclable trays and films, label design may represent one of the final opportunities to further improve recyclability performance and reduce future EPR exposure.
The bigger story: fee modulation changes everything
The technical changes within RAM 2027 are important. The financial implications could be even more significant.
This would represent a 33% increase in the Red penalty alone. Combined with stricter recyclability criteria, packaging decisions are increasingly becoming strategic business decisions.
If the proposed increase in the Red fee multiplier from 1.2x to 1.6x is implemented, the economics of packaging design would change considerably. A packaging portfolio carrying £100,000 of base fees would incur £120,000 under today's multiplier and £160,000 under the proposed structure.
This would represent a 33% increase in the Red penalty alone. Combined with stricter recyclability criteria, packaging decisions are increasingly becoming strategic business decisions.
The real risk: doing nothing
When discussing RAM 2027, much of the focus naturally centres on classifications, compliance and fee modulation. The greatest risk may be delaying action.
The implementation date of 1 January 2027 may appear distant, but packaging development programmes often operate on significantly longer timelines. Design development, shelf-life validation, food safety assessments, manufacturing trials, retailer approvals and supply-chain qualification all take time. Organisations evaluating alternatives today retain flexibility and choice. Those waiting for complete regulatory certainty may find themselves operating against increasingly compressed timelines.
The implementation date of 1 January 2027 may appear distant, but packaging development programmes often operate on significantly longer timelines. Design development, shelf-life validation, food safety assessments, manufacturing trials, retailer approvals and supply-chain qualification all take time. Organisations evaluating alternatives today retain flexibility and choice. Those waiting for complete regulatory certainty may find themselves operating against increasingly compressed timelines.
RAM 2027 does not start on 1 January 2027. For organisations preparing for it, it has already started.
Why brand owners need partners who understand RAM 2027
While the challenges presented by RAM 2027 are significant, many of the solutions already exist.
The question is no longer whether alternative packaging technologies are available. It is whether they can be implemented, validated and commercialised quickly enough to mitigate future risk.
At kp Food Packaging, our strategy is closely aligned with the direction of travel established by RAM 2027.
The question is no longer whether alternative packaging technologies are available. It is whether they can be implemented, validated and commercialised quickly enough to mitigate future risk.
At kp Food Packaging, our strategy is closely aligned with the direction of travel established by RAM 2027.
- kp Elite® is a mono-PET MAP tray designed for fresh protein applications, incorporating post-consumer recycled content and endorsed by TCEP.
- kp MonoSeal® also endorsed by TCEP, provides a mono-PET alternative to traditional PET/PE constructions while maintaining sealing performance.
- kp FlexiLid® EH 145 R has been developed in line with CEFLEX design guidelines and independently certified for recycling within PE streams.
Together, these technologies help brand owners reduce packaging complexity, improve recyclability alignment and prepare for evolving pEPR requirements.
Key takeaways
- RAM 2027 becomes applicable on 1 January 2027
- Real-world recyclability is becoming increasingly important
- Many traditional PET/PE structures may receive less favourable recyclability outcomes than under RAM 1.1
- Flexible packaging will increasingly require evidence of successful progression through all four stages of recycling
- The proposed increase in Red fee modulation from 1.2x to 1.6x remains subject to regulatory confirmation
- Packaging validation programmes can take many months to complete
- Organisations that begin evaluating alternatives now will retain greater flexibility and choice
Conclusion: The cost of non-recyclability is rising
Paul Rawlings, Launch Manager, kp Food Packaging
The future winners will not simply be those using recyclable materials.
They will be those designing packaging systems that reflect how materials are actually collected, sorted, reprocessed and recycled within the UK's infrastructure – and how consumers are most likely to dispose of them.
The biggest risk is waiting for RAM 2027 to arrive before taking action.
Organisations that begin evaluating alternatives, validating new packaging formats and understanding future recyclability exposure today will retain flexibility and choice. Those that delay may find their options narrowing, as classifications, fees and compliance expectations become embedded within the market.
*The Red fee multiplier in the RAM is a financial penalty applied to packaging that is not easily recyclable. This multiplier is part of the EPR scheme in the UK.
**Per- and polyfluoroalkyl substances (PFAS) are a large group of fluorinated substances that may be used in materials for specific performance properties including resistance to heat, grease and moisture.
More like this
Follow us
Contact us
Klöckner Pentaplast GroupCapital House, 4th Floor,
25 Chapel Street
London NW1 5DH
United Kingdom
Legal
Copyright® Klöckner Pentaplast 2026 | kp and other kp marks are registered or proprietary marks of Klöckner Pentaplast