PackUK and the UK Packaging PRO have set out a revised approach to updating the Recyclability Assessment Methodology (RAM), giving the industry a more active role in shaping future changes.

The UK Packaging PRO will work with stakeholders throughout the packaging value chain to identify areas for improvement and prioritise proposed amendments, drawing on evidence and industry feedback.

PackUK will continue to oversee and publish the methodology, although further responsibilities are expected to pass to the PRO following RAM 2028.

The revised approach responds to feedback from producers and other stakeholders seeking a clearer timetable for changes, alongside more opportunity to assess their implications and prepare for implementation.

Jeremy Blake, Chief Executive Officer at PackUK, said: “This is a valuable opportunity for PackUK and the UK Packaging PRO to work together, combining our expertise and shared purpose to make meaningful improvements shaped by stakeholder feedback from across the packaging value chain.

“By introducing this dedicated route for producers to engage with and contribute to the RAM, we are giving industry a stronger voice in guiding future developments and ensuring a broad range of insight is reflected in how the methodology evolves.”

The UK Packaging PRO will be responsible for collecting, reviewing and ranking proposals from stakeholders under the revised process. Producers will have access to a formal route for submitting change requests, helping ensure practical industry experience and technical knowledge inform the methodology’s development.

For the 2028 update, PackUK and the PRO intend to concentrate on a more limited set of priority issues. These will include areas previously raised by producers, such as guidance relating to take-back schemes.

The aim is to make future revisions more focused and predictable, while retaining the flexibility to respond to new evidence and feedback from stakeholders as they emerge.

Karen Graley, Chief Operating Officer at UK Packaging PRO, added: “We know how important the RAM is to producers, and this process provides a real opportunity to bring industry expertise and practical experience into its future development.

“I’d encourage producers of all sizes to get involved. We want to hear what is working well, where improvements are needed and what the evidence tells us.”

Stakeholders wishing to put forward proposals for RAM 2028 must submit their supporting evidence to the UK Packaging PRO by 31 December 2026.

The PRO will review each submission to establish whether it provides sufficient grounds for a potential change. It may also approach submitters to request further evidence, clarify details or discuss proposals in greater depth.

Submissions that present a strong case for additional investigation will undergo further assessment, with the PRO using the findings to help formulate recommendations for PackUK.

The Environment Agency has extended its Regulatory Position Statement (RPS) 330, delaying certain packaging Extended Producer Responsibility (EPR) data collection and reporting requirements until 2028 and 2029.

The updated RPS 330, published on 25 August, extends the regulatory position to cover data for 2026 and 2027.

Under the position, the Environment Agency will not normally take enforcement action where producers fail to collect and report certain data relating to packaging EPR.

This applies to data covering the period from 2024 to 2027.

The Environment Agency said the delay would reduce the regulatory burden associated with data collection and reporting requirements, which do not affect producer disposal fees or recycling obligations for producers, compliance schemes and holding companies.

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RPS 330

The updated RPS delays the introduction of several data collection and reporting requirements.

Self-managed organisational waste data collection is delayed until 1 January 2028, with reporting required on or before 1 October 2028.

Nation of Sale data collection is also delayed until 1 January 2028, with reporting required on or before 1 April 2029.

Meanwhile, data collection for plastic and paper bags is delayed until 1 January 2028, with reporting required on or before 1 April 2029.

The Environment Agency said the reporting requirements remain part of the Packaging Regulations. However, where the conditions are met, producers will not normally face enforcement action for failing to collect or report the specified data.

The RPS does not affect any other legal requirements under the Packaging Regulations.

The Environment Agency will review RPS 330 by 31 December 2028.

Local authorities across the UK can now access a new online platform to manage pEPR grant information.

The Local Authority Payments (LAPs) service, developed by PackUK for the four UK nations, gives councils a single platform to view documentation and information relating to their EPR for packaging grant payments.

Users will be able to view and download notices of assessment, grant determination letters and remittance documents through the platform.

The service also allows authorities to check and confirm payment information, submit queries and request support.

Local authorities can use LAPs to manage authorised users within their organisation, with chief executive officers (CEOs) being invited to register initially.

A head of finance must also be registered to confirm the details used for the distribution of EPR for packaging payments.

PackUK explained that LAPs is an information and administration platform rather than a payment system. It does not calculate, process or transfer grant payments, and the launch does not alter how councils receive their EPR funding.

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The Local Authority Payments Service

The platform was developed following engagement with local authorities, with councils from across the UK taking part in testing during June and July.

Feedback from the testing highlighted the ease of navigating the service and the benefit of having grant documentation available through a single platform, PackUK said.

Once an organisation has been given access, its authorised users will be able to view grant information and manage access to the service.

Guidance and support on EPR for packaging grants will also be available through LAPs.

The new service is part of PackUK's wider development of digital infrastructure for the packaging EPR scheme.

More than £1.4 billion was distributed to local authorities across the UK during the scheme's first operational year.

The funding is intended to support improvements to local recycling and waste management services.

UK Packaging PRO has appointed Kerry Easter as its new Chief Executive Officer, with Karen Graley taking on the role of Chief Operating Officer as the producer responsibility organisation prepares to move beyond its initial set-up phase.

The appointments mark the next stage in the development of the UK's packaging extended producer responsibility (pEPR) scheme operator, which represents more than 100 major producers, retailers and trade associations.

UK Packaging PRO has been established with support from a number of industry organisations, including the Food and Drink Federation (FDF) and the Industry Council for Packaging and the Environment (INCPEN).

Announcing the appointments, Chair Sebastian Munden said: "Kerry brings exceptional international experience of leading complex supply chains, transforming organisations and embedding sustainability across major consumer businesses.

"Karen brings deep expertise in packaging policy and producer responsibility, alongside the operational knowledge and relationships developed through UK Packaging PRO's establishment and mobilisation.

"Their complementary experience will give the organisation the strategic leadership, continuity and operational focus it needs for its next stage of development."

Jeremy Blake, Chief Executive of PackUK, also welcomed the appointments.

He said: "These appointments are an important step for UK Packaging PRO as it moves from mobilisation into delivery.

"Together, they give UK Packaging PRO the leadership, operational discipline and stakeholder focus needed to help build an effective, efficient and evidence-led packaging EPR system across the UK."

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Kerry Easter Appointed as PRO CEO

Easter joins the organisation after a career spanning supply chains, manufacturing, quality, innovation and business transformation across the food, drinks, beauty, personal care and retail sectors.

Before joining UK Packaging PRO, she was Global Head of Category Supply Chain for Gin, Rum and Vodka at Diageo.

Her previous roles also include senior positions at Unilever and The Estée Lauder Companies, while she was also a co-founder of Rituals.

Easter commented: "I'm delighted to be joining Sebastian, Karen and the team in this exciting growth phase of UK Packaging PRO and wider packaging circularity across the UK.

"My immediate priority will be to engage with the organisation's partners and stakeholders, taking input to build on the foundations already established.

"We will ensure that UK Packaging PRO develops the appropriate strategies, capability and discipline required for a successful next phase."

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Karen Graley to Oversee PRO Operations

As Chief Operating Officer, Graley will be responsible for developing UK Packaging PRO's operational capability, governance and delivery arrangements.

She has been closely involved in the organisation's establishment and mobilisation and brings experience across retail, FMCG, packaging, environmental compliance and producer responsibility. Graley added:

"I am looking forward to building UK Packaging PRO into an organisation that is trusted by producers, respected by its partners and recognised for delivering practical results."

"I look forward to working alongside Kerry, our Board, our growing team, PackUK and partners across the value chain to build the capability, relationships and momentum needed to make packaging EPR work effectively and deliver meaningful, measurable improvements."

PackUK has released an updated version of its Recyclability Assessment Methodology, known as RAM 2027, following extensive consultation with industry stakeholders.

The revised framework builds on RAM version 1.1, which was published in April 2025, and reflects input from producers, trade bodies, technical experts, and recycling operators.

The methodology is a key part of the UK’s packaging Extended Producer Responsibility (pEPR) system, where packaging is scored as green, amber, or red depending on how easily it can be recycled.

These ratings directly affect the level of fees producers must pay, with less recyclability leading to higher costs.

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Scope and rollout of RAM 2027

PackUK has confirmed that RAM 2027 applies to the 2027 Data Year and 2028 Compliance Year. Therefore, if you expect to report Household, Public Binned or Glass Household Drinks Containers in the 2027 Data Year, it is recommended that you review the updated RAM at your earliest convenience to get ahead of any potential Red/Amber/Green ‘RAG’ classification changes.

The first reporting deadline under the new version is scheduled for 1 October 2027.

The updated framework is intended to make assessments more consistent and easier to apply, while better reflecting how packaging actually performs within UK collection, sorting, and reprocessing systems.

RAM 2027 introduces a series of refinements to definitions, material rules, and guidance notes, developed with support from the RAM Technical Advisory Committee and recycling data collected from real-world facilities.

According to PackUK, these updates are designed to reduce uncertainty in assessments and ensure producers apply the rules more consistently across different packaging types.
The organisation also said RAM 2027 is more closely aligned with actual recycling performance in the UK, improving the connection between design choices and what can realistically be collected and reprocessed at scale.

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Impact on pEPR fees

Under the UK pEPR system, producers must evaluate household packaging using the RAM framework. Packaging rated green is considered widely recyclable and benefits from lower fees. Amber indicates partial recyclability or system limitations, while red signifies the poorest recyclability and attracts the highest charges.

The modulated fee system is a central feature of pEPR reforms, which aim to transfer the full net cost of managing household packaging waste from local authorities to producers.

PackUK has also indicated that the methodology will continue to be reviewed annually, ensuring it keeps pace with changes in recycling infrastructure, regulation, and material innovation.

Defra has launched a new consultation on reforms to the Packaging Recovery Note (PRN) system, outlining proposed measures to strengthen oversight and address potential misuse.

Open until 5 May 2026, the consultation introduces a range of options intended to improve fairness between UK reprocessors and exporters.

This consultation builds on changes introduced in January 2026.

Defra has indicated that, although those earlier reforms marked progress, additional steps are necessary to further develop the system.

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Measures Relating to System Integrity

A central aspect of the consultation is the introduction of safeguards to address the risk of improperly issued PRNs and PERNs.

According to Defra, such issues can affect market balance by increasing the volume of evidence available and influencing pricing.

Proposals under consideration include:

• Granting regulators the authority to cancel PRNs or PERNs where there is evidence they were issued incorrectly
• Strengthening due diligence requirements for compliance schemes and producers when acquiring evidence
• Increasing transparency through the publication of accreditation suspensions and cancellations
• Introducing mandatory registration and reporting obligations for brokers and trading platforms

Additional measures focus on refining how the “recyclable proportion” of waste is calculated, with the aim of ensuring that evidence is issued only once material has completed the recycling process.

The consultation also suggests that national protocols used to estimate recycling rates could be subject to periodic review, potentially every three years, to reflect changes in waste composition.

Commenting on the proposals, Circular Economy Minister Mary Creagh said: “Through our proposed reforms, we will support our recycling sector by stamping out fraudulent activity and boosting recycling rates.

“I encourage all packaging producers, reprocessors, and exporters to engage with our consultation, aimed at ensuring a level playing field for all businesses.”

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Compliance Mechanisms Under Review

Defra is also seeking feedback on potential mechanisms to support compliance in situations where PRNs or PERNs are in limited supply.

Two approaches are outlined:

• A fee-based option that would allow producers to meet their obligations without PRNs in exceptional circumstances
• A provision enabling limited use of evidence from the following compliance year

Both options are described as contingency measures, intended for use only when standard compliance routes are not available.

UK Packaging PRO has officially been appointed by PackUK as the Producer Responsibility Organisation (PRO) for the UK’s packaging Extended Producer Responsibility (pEPR) programme.

The organisation, which is led by producers, has been established to support a number of responsibilities currently handled by PackUK.

Bringing together over 100 major UK brands, retailers and trade associations, UK Packaging PRO has gained support from key industry bodies such as the Food and Drink Federation and the Industry Council for Packaging and the Environment.

According to PackUK, the appointment followed a thorough and competitive selection process designed to ensure the chosen organisation could effectively represent the full scope of the UK packaging sector.

Jeremy Blake, Chief Executive of PackUK, commented: “I’m delighted to welcome UK Packaging PRO as the new Producer Responsibility Organisation.

“This announcement follows a rigorous selection process, as PackUK was committed to choosing the best candidate possible to represent the diverse interests of the packaging industry.”

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Rollout Begins in April 2026

UK Packaging PRO will formally take on its role from 1 April 2026, with responsibilities being phased in over time.

Its duties are expected to include developing fee modulation and recyclability methodologies, overseeing communications and public engagement, and supporting operational delivery.

While UK Packaging PRO will take on delegated responsibilities, PackUK will continue to oversee its activities and ensure accountability to governments across the UK.

Key administrative decisions, including those relating to local authority payments and producer fees, will remain under PackUK’s control.

Compliance schemes will remain essential partners to producers, continuing to support data, reporting, obligation management and day‑to‑day compliance under the pEPR framework.

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Strengthening Industry Involvement in pEPR

The introduction of a PRO builds on the strong representation and practical insight that compliance schemes have long provided to Defra and the regulators, further strengthening relationships between policymakers and industry across the pEPR system.

Circular Economy Minister Mary Creagh added: “This government will accelerate the circular economy transition.

“Our packaging Extended Producer Responsibility (pEPR) scheme will incentivise businesses towards more sustainable packaging choices and improve recycling services in every region.

“The launch of UK Packaging PRO, led by businesses and working closely with PackUK, is a major step forward”

Compliance schemes will continue to play a vital role in supporting producers. At Wastepack, we remain fully committed to championing our members’ needs. We continue to listen closely, engage proactively with industry, and advocate on behalf of producers to help deliver a system that is efficient, fair and effective for every stakeholder. We look forward to working alongside the producer‑led UK Packaging PRO to ensure our members’ insights and practical experience continue to inform the successful delivery of pEPR.

If you have any questions about pEPR or the introduction of a PRO, our team is here to help, so please don’t hesitate to get in touch here.

PackUK has confirmed that packaging producers are expected to contribute around £1.56 billion in the second year of the UK’s Extended Producer Responsibility (pEPR) scheme.

The figure was published in the organisation’s 2026/27 operational plan, which also states that final per-tonne fees for year two will not be determined until regulators have received and verified all producer data for 2025. Those final calculations are anticipated in summer 2026.

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Year 1 of pEPR

During the scheme’s first operational year, approximately £1.44 billion was projected to be paid to local authorities.

Producers were invoiced £1.46 billion, slightly below the £1.523 billion required, as the system accounted for businesses expected to register later in the compliance period.

PackUK reported that revised producer submissions and major changes in reported obligated tonnages created financial uncertainty and highlighted weaknesses in existing data controls. The organisation said this demonstrated the need for more robust validation processes and clearer mechanisms for recalculating obligations.

So far, two payments have been issued to local authorities, covering roughly three quarters of the financial year. Going forward, the scheme expects quarterly payments to become the standard approach.

Provided sufficient funds are collected from producers, PackUK plans to release a fourth and final payment by 31 March 2026.

The UK government has already confirmed it will cover the £63 million shortfall identified in the scheme’s first year.

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Deadline Introduced for Local Authority Data

Under the new operational plan, PackUK intends to introduce a firm data submission cut-off for local authorities.

For the 2026/27 assessment year, information submitted after 1 May 2026 will generally not be included and will instead be considered during the 2027/28 cycle.

Authorities will still be able to raise concerns if they believe calculations do not comply with legislative requirements. However, PackUK said recalculations cannot remain open indefinitely and that clearer limits are necessary to ensure the system remains stable.

Over time, the organisation expects this cut-off date to move earlier in the year as the scheme becomes more established.

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Defined Recalculation Timetable for Producers

After large numbers of producers amended their submissions in year one, PackUK has introduced a structured timetable for recalculating liabilities in 2026/27.

The proposed schedule from PackUK for the 2026 Compliance Year includes:

• First liability notices issued: July 2026
• Formal recalculation: November 2026
• Additional contingency recalculation: February 2027
• Final year-end recalculation: Late March or early April 2027

PackUK also confirmed in the plan that after 1 October in the relevant compliance year, they will no longer generally recalculate a notice of liability for producers who have resubmitted packaging data to a lower obligation. This is to facilitate greater stability in producer obligations.

Wastepack are continuously working with PackUK, the regulators, and the wider industry to review reported household data and resubmission timelines, ensuring a robust operational system is in place for all stakeholders under pEPR.

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Producer Responsibility Organisation Expected Soon

The administrator also confirmed that it plans to appoint a Producer Responsibility Organisation (PRO) in March 2026.

Applications for the role were open between November and December 2025. Once selected, the PRO will operate as an independent body led by producers, working alongside PackUK to support delivery of the scheme.

Its responsibilities are expected to include developing modulation and Recycling Assessment Methodology (RAM) frameworks, managing communications and public engagement, and providing operational assistance.

PackUK will retain oversight of key statutory functions, including data governance, fee setting and payment management.

The UK Government will cover a funding shortfall in the first year of packaging for Extended Producer Responsibility (pEPR). This ensures Local Authorities receive the required funding, and liable producers will not face increased Local Authority (LA) Disposal Fees for the 2025 Compliance Year.

This follows recent uncertainty after PackUK identified a reduction in the overall reported tonnage had lowered the expected fee income originally forecasted.

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How the Shortfall Arose

As obligated producers became more confident in the new reporting requirements and calculated more accurate data, many resubmitted their data in line with guidance which resulted in a reduction in household packaging tonnage.

As the resubmissions lowered total liable tonnage, this directly reduced the funding collected for LA Disposal Fees at the initial base rate, therefore reducing the overall forecasted funds.

Under normal circumstances, this would have triggered a recalculation of the base fee rates and the reissue of Notices of Liability (NoLs) to liable producers, potentially raising costs at a very late stage in the compliance period.

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Government Intervention

To ensure the stability of EPR and avoid additional burden on producers, the Government has stepped in to close the funding gap as a one-time measure, ensuring the initial LA Disposal Fee rates remain unchanged. PackUK has confirmed that the tonnage-based base fees producers received in October 2025 will remain as is, protecting businesses from unexpected cost increases.

This intervention also secures the full funding committed to Local Authorities for 2025/26 waste collection and recycling services. This enables councils to proceed with planned service improvements to infrastructure.

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Updated Notices for Resubmitted Data

Updated NoLs will be issued by the end of March 2026 to producers who resubmitted and had their 2024 packaging data approved by the regulator. These updated notices will reflect the initial base fee rates, thanks to the Government’s decision to cover the shortfall.

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Impact on Producers

For most producers, the implications are straightforward:

• LA Disposal Base Fee rates for the 2025 Compliance Year remain unchanged.
• No action is required if the October 2025 NoL has already been paid or is under a payment plan.
• Producers who resubmitted their household data will receive updated NoLs by the end of March.
• Producers who submitted household data for the first time after the October NoLs were issued will also receive a NoL by the end of March.

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Looking Ahead: What to Expect in Future Years

While the Government has stepped in for Year 1, Defra has been clear that this is very unlikely to occur again. From Year 2 onwards, similar funding gaps will likely result in recalculated invoices and higher fees for producers.

To reduce the risk of late-stage recalculations in future years, PackUK is taking measure to mitigate the risk by looking to tighten household data resubmission deadlines and improving guidance to support more accurate first-time reporting. These measures are expected to stabilise data inputs and reduce the need for such recalculations later in the compliance period.

As one of the UK’s largest compliance schemes, representing more than 1500 producers, we will continue to monitor the situation and work with PackUK, Defra and the regulators to ensure operational efficiency for all stakeholders.

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Previous pEPR Stories:

'PackUK Publishes RAM-integrated pEPR Indicative Fees for 2026 [20.12.25]'

'pEPR Amendments Move Forward After Commons Approval [18.12.25]'

PackUK has confirmed the appointment of members to its newly established Scheme Administrator Steering Group (SASG).

Alongside the announcement, the scheme administrator also revealed the chairs of its three technical advisory groups, which will support the implementation of the UK’s packaging Extended Producer Responsibility (pEPR) programme.

Posting on LinkedIn, PackUK said it was "delighted to announce the members of the Scheme Administrator Steering Group", adding that it is “committed to working collaboratively with experts from across the packaging value chain” and looks forward to partnering with members to help advance a more circular UK economy.

Role of the Steering Group

The voluntary SASG brings together representatives from central and devolved governments, local authorities across all four UK nations and key sectors impacted by pEPR.

According to PackUK, the group will serve as a “critical friend” to the Scheme Administrator Executive Committee (SA ExCo), offering advice and recommendations to help deliver the environmental ambitions of pEPR while also supporting economic development.

The steering group will operate alongside three specialist advisory bodies: the Recyclability Assessment Methodology Technical Advisory Committee (RAM TAC), the Efficiency and Effectiveness Technical Advisory Committee (E&E TAC), and the Communications and Behaviour Change Advisory Group (CBCAG).

Collectively, these groups will provide expert guidance to shape pEPR processes, supporting the development of policy, guidance and delivery. Each group is expected to convene on a quarterly basis.

Membership of the SASG

Sebastian Munden has been appointed chair of the steering group, with James Bull taking on the role of deputy chair.

Producer organisations and trade associations on the group are represented by Alison Bramfitt, Cat Hay, Gareth Callan, James Bull, John Ryan, Kevin Laughton, Paul Vanston and Steve Carpenter.

Robbie Staniforth represents compliance schemes, while waste management interests are covered by Emma Beal and Stuart Hayward-Higham. Environmental non-government organisations are represented by Claire Shrewsbury and Paula Chin.

Local authority members have been appointed from each UK nation: Andrew Cassells (Northern Ireland), Craig Mitchell (Wales), Silke Isbrand (Scotland) and Steve Palfrey (England).

Technical Advisory Group Chairs Announced

PackUK also confirmed the appointment of chairs to its three technical advisory groups.

Emma Wilkinson will lead the RAM TAC, providing independent technical expertise on packaging sustainability and supporting the continued development of the RAM.

The E&E TAC will be chaired by Cathy Cook, drawing on waste management experience to advise SA ExCo on supporting local authorities across a range of operational contexts.

Paul Vanston has been appointed chair of the CBCAG, which brings together expertise from across the packaging value chain, behavioural science and four-nation representation to inform communications and behaviour change approaches under pEPR.

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View our previous story like this here: PackUK Appoints Members to Three pEPR Advisory Panels [20.08.25]