UK and EU recyclability rules risk widening packaging compliance gap

The EU’s Packaging and Packaging Waste Regulation (PPWR) mandates that all packaging on the EU market is recyclable in an “economically viable way” by 2030. Meanwhile, the UK’s packaging EPR (pEPR) requires packagers to use the Recyclability Assessment Methodology (RAM) 2027 to assess the recyclability of household packaging placed on the UK market in 2027. 

A notable difference is that the UK’s RAM is a fee-modulation tool that applies a traffic light rating system to packaging based on the UK’s current recycling infrastructure, whereas the EU’s PPWR legal compliance standard regulates market access. 

The RAM 2027 framework was published in July and the PPWR became applicable across the EU in August. 

Packaging Insights speaks with Alex Hilton, director of Policy and Public Affairs at UK-based regulatory compliance provider Beyondly, about how UK and EU approaches to packaging recyclability align and where they differ.

Hilton argues that “there are some broader issues that deserve more attention than they are currently receiving” when it comes to recyclability definitions across the two regions.

“The risk is that the UK and EU develop subtly different definitions of recyclability,” he explains, highlighting the interconnectedness of packaging markets with many UK-based packaging businesses supplying the EU and vice versa.

“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,” Hilton continues.

“For global brands, the real challenge may not be designing recyclable packaging, but designing packaging that satisfies multiple recyclability frameworks simultaneously. This is costly and places a barrier on trade rather than enabling it.”

Recyclability expectations

PackUK, the official scheme administrator for the pEPR published guidance for the 2027 reporting year (January 1 to December 31, 2027), stating that obligated large producers must use RAM 2027 to assess recyclability during this period.

For global brands, designing packaging that satisfies multiple recyclability frameworks simultaneously is an emerging challenge, according to Hilton.The official RAM 2027 recyclability ratings published by PackUK and the UK’s Department for Environment, Food and Rural Affairs (Defra) dictate that all packaging will be given one of three ratings. 

One of the ratings is red, which is applied to packaging that “has specifications that make it difficult to recycle at scale, it cannot reliably move through the existing recycling system due to challenges in collection, sortation, reprocessing, or because no end‑use exists within current operational infrastructure.” 

“Packaging that’s considered automatic red cannot be considered recyclable within pEPR, regardless of its technical recyclability, because to do so would create legal, chemical, or system‑level barriers to safe and effective recycling,” PackUK elaborates.

Amber is the rating given to packaging that “may experience challenges during collection and difficulties in sortation, requires specialist infrastructure for reprocessing, the efficiency and output quality of reprocessing is affected, or there is some secondary material loss.”

Lastly, a green rating is granted to packaging that is widely recyclable in the current UK infrastructure.

Hilton says the latest RAM changes increasingly tie the UK’s definition of recyclability to real-world recycling outcomes rather than theoretical recyclability. He adds that administration or reporting does not stand out as equally significant.

“PackUK has explicitly positioned RAM 2027 as a methodology that better reflects how packaging is actually collected, sorted, and reprocessed within UK infrastructure.”

Meanwhile, the European Commission (EC) highlights that Article 6(1) of the PPWR requires that all packaging placed on the market is recyclable without providing a specific deadline for the application of this provision, which means that it applies from August 12, 2026.

“Article 6(2)(a) ‘shall apply from January 1, 2030, or 24 months from the date of entry into force of the delegated acts adopted pursuant to the first subparagraph of paragraph 4, whichever is the latest’,” the EC elaborates.

“According to Article 6(4), this delegated act, which will fully harmonize design for recycling requirements and the related assessment methodology, should be adopted by the Commission by January 1, 2028.”

Ensuring predictability for investors

Hilton argues that much of the discussion surrounding the UK’s RAM 2027, and recyclability more broadly, has focused on producer costs. “The more interesting question is whether RAM creates sufficiently clear market signals to drive investment,” he adds.

“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.

“That is where alignment with PPWR and annual updates to RAM becomes particularly important. Consistency and predictability may ultimately be just as valuable as the technical details of any individual red, amber, or green classification. At present, the signals in the RAM and from PackUK and Defra are not strong enough, driving uncertainty and a lack of investment in the UK packaging industry.”

Hilton calls on the UK Government to be “bold and ambitious” while looking to enable alignment with the “nearest trading partners.”He further notes that many organizations still view RAM as a reporting exercise. “In reality, the businesses that succeed under EPR are likely to be those with the strongest packaging data.”

“Understanding components, coatings, labels, adhesives, and material composition at the SKU level will become increasingly valuable for managing future costs. The winners may not necessarily be the companies with the most sustainable packaging today, but those with the best visibility of their packaging portfolios.”

PFAS considerations

PFAS restrictions are now firmly entering the recyclability conversation, continues Hilton.

In the EU, the PPWR requires the packaging industry to demonstrate that the materials it uses do not exceed PFAS‑related limits.

In the UK, packaging containing PFAS above defined thresholds will receive a red rating, says Hilton. “This is significant because it moves RAM beyond pure recyclability and into the wider question of material safety and chemical circularity.”

“Circularity increasingly requires consideration of chemical safety, material quality, and downstream environmental impacts. But some argue that it is an over-reach, while others want it to go further.”

“There are concerns about the divergence between RAM2027 and PPWR,” he notes.

Discussing RAM 2027 and PPWR divergence more broadly, Hilton calls on the UK Government to be “bold and ambitious” while looking to enable alignment with the UK’s “nearest trading partners.” He states that this can be achieved by giving industry a clear and robust roadmap for the future, strengthening existing legislation “to root out fraud,” and driving UK growth.

“Overall, the methodology is moving in the right direction. However, its long-term success will depend on whether it can continue evolving while bringing industry with it, and fundamental concerns remain for me regarding the process of engagement to develop the RAM.”