OPINION: Does RAM 2027 work for plastics?

OPINION: When the Recycling Assessment Methodology (RAM) 2027 was released on the 1 July it certainly raised a few eyebrows. The RAM, published by PackUK, is used to eco-modulate fees for the Extended Producer Responsibility for packaging (pEPR) scheme which provides for companies placing products on the market to pay Local Authorities to collect, sort and dispose of the packaging. This latest version replaces RAM 1.1, which is in force until the end of the year, and contains significant changes that have come as a big surprise to many in the industry.

pEPR and eco-modulation of the fees are laudable policies, aimed at reducing the amount of packaging we are using, preventing litter and promoting recyclability. Most in the industry see this as a positive step towards making packaging more sustainable and reducing resource usage. However, the contents of RAM 2027, the way it has been developed, and the change in approach to the previous version has caused a great deal of concern with the whole value chain.

For plastics packaging there are three major changes that are very troubling, along with many smaller, but significant updates. The moving of PFAS from “intentionally added” in RAM 1.1 to all PFAS, in all packaging, at extremely low levels was unforeseen as most were happy with the older regulation. This tightening is far stricter than the EUs Packaging and Packaging Waste Regulation (PPWR), which was already causing many issues within the industry. There has been so much push back that PackUK have formed an industry task force to review this which should report back by November.

For flexible plastic packaging, RAM 2027 removes all details of what is and is not recyclable. Our belief is that this was done to align with the delay to Simpler Recycling where kerbside collection of flexibles is delayed from April 2027 until 2030. All flexible plastic packing will now be classified as unrecyclable (even though the vast majority of it is) and will pay higher pEPR fees.

There is now no way to avoid this, apart from operating a take back scheme which is impractical for most companies. Without even guidelines to good design, it leaves the flexible packaging industry little hope of improving its lot. Defra have said they will set up a task force to ensure the collection starts in 2030.

The biggest mystery is why Polypropylene (PP) direct printed tubs have been moved from a Green (recyclable) rating into Red (unrecyclable). One of our BPF members told me that he has been recycling PP printed tubs for over 20 years and has never had any issues. Again, the pushback has been so intense that PackUK have set up another working group to review this.

All this raises questions about the whole ethos of the RAM, the transparency behind the decision making, and the political interference behind some of the decisions being made. PackUK will be the first to admit that the RAM is not a Design for Recyclability guideline, but a tool for eco-modulating the fees. However, by default the RAM drives packaging decisions, many of which, for plastics, are plain wrong.

One stated aim of PackUK is to make the RAM as simple as possible to reduce the reporting burden on obligated producers. For some materials (glass, aluminium, steel) recycling is simpler so this approach has benefits. Plastics are far more complex and small design features can have a marked effect on the recyclability of a piece of packaging and seriously effect the reusability of that material. There are many good sets of Design for Recyclability (DfR) guidelines available from RecyClass, RECOUP, and OPRL, which cover plastic packaging but unfortunately these have been ignored.

As the RAM has so many issues, PackUK have a programme of reviewing the contents annually. Having worked in the industry over 40 years, I know it usually takes between 2 and 3 years to design, develop, tool, manufacture and feed stock through the logistics chain so an annual review is impossible for companies to deal with as design features may become outdated before they get to market. The problem with setting a longer timescale is that the inbuilt inaccuracies will persist in the system and have longer term consequences. We need to get the major things sorted before lengthening the timelines.

With the drive for simplicity, political interference in the decision making, and lack of transparency of the process, we have to question the validity of the RAM and ask if it is fit for purpose. We also have to look at what is happening with the PPWR in Europe, where we believe DfR criteria will be far stricter (publication of the Enabling Act is due by the end of this year). Many companies will be forced to follow these regulations if they export to the EU or sell products in Northern Ireland anyway.