Key Takeaways

• Understand evolving EPR obligations: Learn how UK Extended Producer Responsibility (EPR) timelines and data requirements are changing and what producers must do to remain compliant.
• Navigate eco-modulation and RAM: Explore how recyclability assessments and modulated fees will reshape producer costs starting in 2026.
• Adopt digital compliance tools: Discover how automated EPR and RAM software solutions simplify complex reporting and ensure accuracy.

Introduction

Extended Producer Responsibility (EPR) continues to evolve across the UK, introducing new reporting and recyclability assessment rules. Eco-modulation links fees to a product’s environmental impact, pushing producers to rethink packaging design and recyclability.

Under this system, producers pay higher fees for hard-to-recycle packaging and benefit from lower costs when using easily recyclable materials. The Recycling Assessment Methodology (RAM) underpins this process, setting measurable standards for recyclability.

EPR in the UK: Key Updates & Deadlines

UK producers are required to collect and report packaging data under the new EPR framework. Reporting frequency depends on company size:

• Large producers: Must report packaging data twice yearly in April and October.
• Small producers: Report once per year, first submission due April 2025.

The UK Government launched early data collection in 2024 to help companies:

• Estimate upcoming modulated fee responsibilities.
• Build consistent data systems for smoother submissions.
• Review recyclability and transition to sustainable materials.

Eco-Modulation & RAM Explained

RAM, developed by PA Consulting and Defra, standardises how recyclability is measured across the UK. From January 2025, large producers must assess and submit recyclability results for household packaging.

RAM uses Red, Amber, and Green ratings to classify packaging recyclability.

• Red: Hard to recycle at scale, higher modulation fees.
• Amber: Moderately recyclable, standard fees. May require specialist infrastructure or minor material loss.
• Green: Easily recyclable with current UK infrastructure, lower fees.

From 2026, fees will directly link recyclability to costs. Unsustainable packaging may see fees rise up to 2× by 2028.

Materials That Are Exempt

Some packaging is exempt from a recyclability assessment:

• Reused packaging, unless imported into the UK
• Packaging exported from the UK
• Drinks containers made of PET, steel, or aluminium
• Drinks containers within Deposit Return Scheme (DRS)
• Non-household packaging

Automatic Reds (‘Problematic Packaging’)

Items automatically classified as red include:

• Integrated electrical components or batteries (EEE packaging)
• Substances of very high concern above UK REACH thresholds
• Non-compliant printing inks (EuPIA Exclusion Policy)
• Household packaging lacking required assessment data

Medical Packaging

Immediate or outer packaging on:

• Medicinal products
• Veterinary medicinal products
• Medical devices

Immediate packaging is in direct contact with the product. Outer packaging contains the immediate packaging.

More info: Human Medicines Regulations 2012

Check MHRA guidance: how to tell if your product is a medicine

• Red - medical
• Amber - medical
• Green - medical

How Our Platform Supports EPR and RAM Compliance

Remedy EPR automates EPR and RAM compliance, managing packaging data, recyclability assessments, and reporting. The integrated RAM ruleset identifies cost drivers and predicts modulated fee impacts.

Core Advantages of Digital Compliance

• Automated data capture and categorisation
• Instant recyclability scoring with RAG classification
• Real-time visibility into modulated fees
• Built-in alerts for reporting and legislation updates
• Ongoing updates aligned with latest EPR/RAM guidance

Adopting digital compliance tools reduces manual effort, prevents costly errors, and prepares your business for 2026 fee modulation.

Stay Ahead of the Curve

Proactive data collection and recyclability analysis will set sustainable brands apart. Early preparation ensures operational efficiency, lower costs, and stronger environmental credibility.