PPWR vs UK EPR: recyclability compared

Anyone supplying packaging to both the European Union and the United Kingdom has to assess the recyclability of the same pack twice — using two methods with two different legal consequences. In the EU, the performance grade under the Packaging and Packaging Waste Regulation (PPWR) decides market access from 2030. In the UK, the traffic-light rating under the Recyclability Assessment Methodology (RAM) decides the level of the waste disposal fee. As Packaging Insights reported on 21 September 2026, the gap between the two systems risks widening with the new RAM 2027: a pack may count as recyclable under one regime and attract higher costs under the other.

EU

Regulation (EU) 2025/40, Article 6 and Annex II

UK

SI 2024/1332 and RAM 2027 (PackUK)

EU consequence

market access from 1 January 2030

UK consequence

fee uplift for “red” up to factor 2.0

Two systems, two legal consequences

The PPWR (Regulation (EU) 2025/40) has applied since 12 August 2026. Under Article 6(1), all packaging placed on the market must be recyclable. The yardstick is a set of design-for-recycling criteria that assign each pack to performance grade A, B or C. Packaging that misses grade C may no longer be placed on the market from 1 January 2030. In the EU, recyclability is therefore a condition of market access.

The UK has taken a different route. The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332) have applied in all four nations since 1 January 2025 and require producers to bear the cost of disposing of household packaging. The RAM determines how high these costs are in each case. A “red” pack may still be sold — it simply costs more. The RAM is thus a fee-modulation tool, not a market ban.

The UK traffic light in detail

The RAM is published by PackUK, the scheme administrator of the UK EPR system, supported by an independent technical advisory committee. For the 2026 reporting year, RAM version 1.1 applies; RAM 2027, published on 1 July 2026, applies to packaging placed on the market from 1 January to 31 December 2027. The methodology is to be updated annually before each reporting year. Large producers are legally required to assess their household packaging using the RAM.

• Green: the pack is widely recyclable in the current UK infrastructure. It must achieve “green” at every stage — collection, sortation, reprocessing and application.
• Amber: there are collection or sortation difficulties, or reprocessing requires specialist infrastructure, with some loss of secondary material.
• Red: the pack is difficult to recycle at scale and cannot reliably move through the existing system. A single “red” at any stage is enough.

Two rules deserve particular attention. First, a pack is rated “red” if the producer cannot provide evidence for “amber” or “green”. The burden of proof lies with the producer. Second, flexible plastic packaging and wood are to be rated “red” unless the producer meets the requirements for a take-back scheme. In addition, certain criteria automatically lead to “red” regardless of technical recyclability:

• integrated electrical or electronic components or batteries, such as LEDs
• exceeding limits under UK REACH, for substances of very high concern, persistent organic pollutants, biocides or under the CLP Regulation
• printing inks not manufactured in line with the EuPIA exclusion list
• PFAS above the RAM 2027 thresholds
• food-contact packaging that breaches UK food-contact law
• formats subject to UK restrictions or phase-outs, such as certain single-use plastics

Red-rated packaging cannot be considered recyclable within pEPR, regardless of its technical recyclability, because to do so would create legal, chemical, or system-level barriers.

What the traffic light costs

Fee modulation starts in the second year of the scheme. According to PackUK’s modulation statement, the first modulated fees apply to the 2026/27 financial year and are calculated on the basis of packaging data for 2025. “Amber” pays the base fee, “red” pays an uplift that rises step by step. The additional revenue from “red” is redistributed to “green” as a reduction. Medical packaging that is red solely by virtue of a regulatory requirement is treated like “amber”.

The illustrative fees for 2026/27 published by the UK government in December 2025 show what this means in money: for plastic they were £415/t (green), £455/t (amber) and £545/t (red); for paper and board £190, £210 and £250/t; for aluminium £245, £270 and £325/t. These are indicative figures, not the final fees. As the factor rises to 2.0, the gap between “red” and “green” widens considerably by 2028/29.

The EU grades for comparison

The PPWR does not assess the current infrastructure of a Member State but the design of the pack against design-for-recycling criteria that are uniform across the EU. The Commission must set these criteria by delegated acts by 1 January 2028. This results in a staggered timetable:

• From 1 January 2030 (or 24 months after the delegated acts enter into force, if later): only packaging of grades A, B or C.
• From 1 January 2035: the pack must additionally be “recycled at scale”.
• From 1 January 2038: only grades A or B.
• Under Article 6(8) PPWR, EPR fees are to be modulated according to the performance grades. The EU does not set fee levels; they remain a matter for Member States and their schemes.

Where the systems diverge

The different yardsticks produce situations in which the same pack is rated differently. Alex Hilton, Director of Policy and Public Affairs at Beyondly, told Packaging Insights that a pack could theoretically be considered recyclable under one regime but attract higher costs under another because collection systems, infrastructure assumptions or assessment criteria differ.

• Flexible plastic packaging: in the UK “red” by default unless a take-back scheme is evidenced. Under the PPWR it depends on the design-for-recycling criteria, which may allow grade C or better for mono-material films. The relevant delegated acts are still pending.
• Missing evidence: in the UK, missing documentation automatically leads to “red” and thus higher fees. In the EU, without evidence there is no basis for the declaration of conformity — with the harsher consequence that the pack may not be placed on the market from 2030.
• Inks and substance restrictions: the RAM relies on UK REACH and the EuPIA exclusion list, the PPWR on EU substance restrictions under Article 5. Both frameworks are evolving separately.
• Timing: the RAM is updated annually and already affects fees today. The PPWR criteria will only be settled in early 2028 and take effect from 2030. In the meantime, companies have to assess under the RAM without knowing the final EU criteria.

PFAS: different thresholds and consequences

Both systems address PFAS, but differently. Since 12 August 2026, Article 5(5) PPWR limits PFAS only in food-contact packaging: 25 ppb per individual PFAS, 250 ppb for the sum of PFAS and 50 ppm for PFAS including polymeric PFAS. RAM 2027, by contrast, rates any pack with more than 1 ppm PFAS as “red”, and food packaging from 25 ppb — for individual PFAS and for the total alike. For the total of all PFAS in food packaging, the RAM thus sets a threshold at one tenth of the PPWR limit.

The consequences differ here too: in the EU, food-contact packaging above the limits may not be placed on the market. In the UK, exceeding them leads to “red” and thus higher fees. Hilton sees this as moving the assessment beyond pure recyclability into the wider question of material safety and chemical circularity.

The special case of Northern Ireland

In Northern Ireland, both regimes apply side by side. Under Article 13(3) of the Windsor Framework, the PPWR applies there to the extent it falls within the Framework’s scope. According to the UK government’s explanatory memorandum, this covers the product requirements — substance restrictions including PFAS, recyclability, recycled content, labelling and format bans. Among the provisions that do not apply are those on extended producer responsibility (Articles 44 to 47 PPWR), deposit return schemes and recycling targets. Northern Ireland’s environment department DAERA states that packaging first placed on the Northern Ireland or EU markets from 12 August 2026 must meet the PPWR requirements. EPR obligations there continue to follow the UK system, including the RAM.

Other UK obligations alongside the RAM

• Plastic Packaging Tax: since 1 April 2026 the tax is £228.82 per tonne of plastic packaging with less than 30% recycled content; registration is required for anyone manufacturing or importing 10 tonnes or more.
• Deposit return: in England, Northern Ireland and Scotland, a deposit return scheme for PET, steel and aluminium drinks containers from 150 ml to 3 l starts on 1 October 2027 (for England and Northern Ireland: SI 2025/67). Wales starts on the same date and includes glass.
• Labelling: in September 2024 the UK government removed the planned mandatory recyclability labelling (“recycle” / “do not recycle”) from the EPR regulations in order to wait for the EU approach. It does not currently apply.
• Simpler Recycling (England only): consistent collection of recyclables for businesses since 31 March 2025 and for households since 31 March 2026; plastic films follow by 31 March 2027.

Is alignment in sight?

There is no official statement that the RAM traffic light and the PPWR performance grades will be merged. The UK government had said it would consider a consultation on adopting equivalent PPWR measures across the UK. According to DAERA, no decision on alignment has yet been taken and a formal consultation is being planned. PackUK’s press release on RAM 2027 does not mention the PPWR. Beyondly is calling for closer alignment and reliable signals: if recyclers, packaging manufacturers and investors can see a stable direction of travel over several years, they can invest in new infrastructure and packaging formats with greater confidence.

What companies supplying both markets should do

• Capture component data at SKU level. Material, weight, colours, adhesives, labels and barriers per component are the basis of both assessments. According to Packaging Insights, this knowledge is increasingly becoming a competitive advantage in managing EPR costs.
• Run both assessments in parallel. A PPWR grade does not replace a RAM rating, and vice versa. Record both results per pack with date and methodology version.
• Secure evidence for “amber” and “green”. Without evidence, the UK default is “red” — and the factor rises to 2.0 by 2028/29. Evidence must be kept for the RAM version of each reporting year.
• Test PFAS against the stricter yardstick. Anyone supplying both markets should align food-contact packaging with the UK total threshold of 25 ppb and keep the RAM’s 1 ppm threshold in view for all other packaging.
• Align redesigns with the stricter requirement. A change that achieves “green” in the UK and at least grade B in the EU avoids fee uplifts and keeps EU market access after 2038.
• Treat Northern Ireland separately. The PPWR product requirements and UK EPR obligations apply there side by side.

The key dates