How to assess packaging recyclability for EPR
An obligated large importer should use the RAM for the reporting year, establish which components need separate assessment, obtain their technical evidence and record the resulting ratings. Keep assessment records for 7 years. Cambridge China Bridge can help collect factory specifications and sample evidence.
Fix the reporting year before assessing
This guide covers the assessment work after you have established your obligations. Use our UK packaging EPR guide for that starting point. PackUK says to use RAM version 1.1 for the 2026 reporting year. RAM 2027 applies to the 2027 reporting year, so do not choose a methodology simply because it is the newest publication.
Put the reporting year, methodology version and guidance copies in your assessment folder. Give each packaging specification a revision identifier so the assessment can be matched to the packaging actually supplied.
Decide what to assess together
Under the supplementary RAM guidance, assess components separately only where they are easily separable by hand. Assess them together where separation needs tools or mechanical sortation, or where a component is undersized. Labels that consumers cannot easily remove should be assessed with the component they are attached to, using the predominant material by weight.
Photograph the complete pack and its separated parts. Record how each part comes away, including sleeves, closures, liners and labels. Ask the factory to demonstrate the actual construction rather than relying on a drawing. Our packaging sourcing guide covers the wider buying specification.
Collect evidence for the actual component
If material composition is uncertain, PackUK says it is your responsibility to obtain it from suppliers. Its supplementary guidance says a household packaging unit or component without supporting evidence is an automatic red. A factory's statement that the pack is recyclable does not establish the technical facts needed for your assessment.
Request a component schedule showing material composition, weight, dimensions, colour, coatings, laminates, adhesives, inks and additives where relevant. Tie declarations and any test reports to the exact specification and sample. Where test results are used, PackUK requires them for each component being assessed. Keep unresolved questions visible for your assessor.
Record the route to the rating
Use the applicable material guidance to assess the unit or component and determine its red, amber or green rating. The materials-and-outputs guidance covers collection, sortation, reprocessing and application, and says the output should be recorded and submitted with packaging data.
Create an assessment sheet with the component identifier, material category, applicable criteria, supporting document references, outcome, assessor and date. Explain the decision at each relevant stage. Keep the component weights and supply records linked to the reporting totals, so someone reviewing the return can follow the calculation back to the assessed specification.
Retain results and control changes
PackUK requires recyclability assessment records to be kept for 7 years. Keep assessments under review and update or reassess them when packaging design, manufacture or composition changes, when a RAM change is likely to affect the outcome, or when another reason is likely to change the result.
As a practical filing approach, retain the result alongside the methodology used, supplier documents, sample photographs, test reports, review notes and submitted data. Preserve earlier revisions when replacing a specification. Require the factory to flag substitutions before production, and compare the run with the approved sample using our printed retail packaging guide.
Frequently asked questions
Which RAM version do I use for 2026 packaging?
Use RAM version 1.1 for the 2026 reporting year. PackUK's RAM 2027 guidance applies to the 2027 reporting year.
Do I assess the label separately from the bottle?
A label that the consumer cannot easily remove is assessed with the component it is attached to, using the predominant material by weight.
What if my factory cannot provide packaging evidence?
Ask for the missing composition and technical details. PackUK says a household packaging unit or component without supporting evidence is an automatic red.
How long must I keep RAM assessment results?
Keep recyclability assessment records for 7 years. Retain supporting documents with the result so its basis can be checked later.