The first packaging EPR invoices to reflect recyclability are now arriving, and for many producers the colour of their packaging has become a cost line. Under the modulation policy, red rated packaging pays 1.2 times the base fee in 2026 to 2027, rising to 1.6 times in 2027 to 2028 and double in 2028 to 2029 (Food Manufacture, Sept 2026).
What Are RAM Colour Ratings?
RAM, the Recyclability Assessment Methodology, is the system used under UK packaging EPR to rate each packaging component red, amber or green according to how recyclable it is in practice. Green means widely recyclable in current UK infrastructure. Amber means recyclable with some challenges. Red means not recyclable at scale.
Ratings are based on how packaging performs in real UK collection, sorting and reprocessing, not on theoretical recyclability. A component is also given the highest rating it reaches at any stage of the assessment, so one red stage makes the whole component red.
The fee itself is calculated per material. The tonnage of each component is multiplied by the base fee for that material and then by the modulation factor for its rating. Amber packaging pays the base fee, while the discount for green packaging is set each year in proportion to how much red packaging is reported across the market.
The stakes are significant. In 2025, 61.8% of flexible plastic packaging assessed under RAM received a red rating (Food Manufacture, Sept 2026). The methodology is also updated each year, so a rating achieved once is not guaranteed for future reporting periods.
Can Labels Affect a RAM Rating?
Yes, labels can affect a RAM rating. The assessment asks for detailed information about inks, adhesives, additives and coverage, and labels contribute to all of these. A label that covers too much of a bottle can interfere with optical sorting. Some adhesives and inks affect the quality of recycled material. Dark pigments, particularly carbon black, can prevent some plastics being detected by sorting equipment.
There is also an information risk. Packaging can be rated red simply because the data needed to complete the assessment is unavailable. If you do not know what adhesive or ink is on your label, you may be paying a red rate for a component that could have been amber or green.
What Should You Review Before Your Next Invoice?
Start with the components carrying the highest tonnage, because the multiplier applies per tonne. Ask your label supplier for technical data on facestock, adhesive and inks, and check whether label size and material are compatible with the pack they sit on. A paper label on a paper based pack, or a polypropylene label on a polypropylene tub, is often easier to justify than a mixed combination.
With the red multiplier set to increase each year, small changes now can deliver savings that grow over time. Producers with complete, accurate component data are also better placed to challenge a rating that does not reflect how their packaging really performs. A label chosen with recyclability in mind is one of the simplest ways to protect your EPR costs.