Printing “recyclable” on a label has always been a marketing decision. From April 2026, it is also a financial one. The UK’s Extended Producer Responsibility scheme entered eco-modulation in the 2026/27 scheme year, meaning packaging is now rated under the Recyclability Assessment Methodology and assigned a red, amber, or green rating. Red-rated packaging, assessed as harder to recycle, pays a fee premium of 1.2 times the base rate this year, rising to 2.0 times by 2028. Green-rated packaging pays a discounted rate. The recyclability claim on the label and the RAM outcome for the packaging should reflect the same technical reality. Where they do not, the business faces both a financial penalty and a green claims enforcement risk.
What the RAM Means for the Recyclability Claim
The Recyclability Assessment Methodology assesses each component of a packaging unit separately. For a labelled bottle, that includes the bottle itself, the closure, and the label. A label that interferes with sortation equipment in material recovery facilities, or that reduces the quality of the recyclate recovered from the primary container, can pull the overall RAM rating down from amber to red. Common label factors that affect the RAM outcome include full-wrap coverage that obscures the primary material to near-infrared sortation systems, adhesives that prevent label removal during recycling, and ink or coating systems that contaminate recyclate streams.
A business that carries a “Recycle” claim on its label, based on the OPRL scheme, and then receives a red RAM rating during modulated fee assessment, is in a position where its on-pack claim and its regulatory compliance status are in direct conflict. The CMA’s January 2026 supply chain guidance makes clear that a recyclability claim on a label must be substantiated with evidence held before the claim is printed, and that a claim made without adequate verification is potentially a misleading green claim actionable under the DMCC Act.
The Interaction Between EPR Fees and Green Claims Risk
The EPR and green claims regimes are legally separate but practically linked. A business that has not completed a RAM assessment for its packaging, and carries a recyclability claim on the label without that evidentiary basis, is simultaneously at risk of a red RAM default rating, paying the maximum fee premium, and of CMA enforcement for a potentially misleading environmental claim. The two risks compound each other.
Packaging that defaults to a red RAM rating because no assessment was completed automatically incurs the maximum fee premium. That default outcome, combined with a “Recycle” claim on the label that the RAM outcome contradicts, is exactly the scenario the CMA’s January 2026 guidance is designed to address. Acting early on RAM assessments, aligning label recyclability claims with verified outcomes, and engaging with OPRL scheme labelling as the most credible form of consumer-facing substantiation is the practical route to managing both risks simultaneously.