RAM 2027: the assessment you already did doesn't count

Somewhere there's a packaging technologist with a spreadsheet of recyclability ratings, finished in a fortnight of teeth-grinding last year, filed with a quiet sense of a job done. That spreadsheet has a shorter shelf life than they think.

PackUK published RAM 2027 on 1 July 2026. It's the methodology you must use to rate household packaging placed on the market during 2027. And assessments done under RAM v1.1 don't carry forward. You re-run them.

Which version applies to what

This is the bit that trips people, because three years are live at once.

RAM v1.1. The version for packaging supplied during 2026. Those ratings feed your 2027–28 fees.

RAM 2027. For packaging supplied between 1 January and 31 December 2027. Those ratings feed your 2028–29 fees.

So right now you're operating under v1.1 for this year's data while preparing to reassess everything under RAM 2027 for next year's. The methodology and the reporting year are always a year apart from the fee year, and mixing them up is how you end up rating the wrong stock against the wrong rules.

The change that will catch people: chemistry, not recyclability

RAM 2027 tightens the "automatic red" criteria: the conditions that dump a pack straight into the worst rating regardless of how recyclable it otherwise is.

The one that matters most: any substance of concern exceeding limits under UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), the list of Substances of Very High Concern (SVHCs), the Persistent Organic Pollutants (POPs) Regulation, biocides law, or CLP (Classification, Labelling and Packaging).

The other automatic red triggers are worth reading properly if you handle flexibles or food-contact packaging:

• PFAS (per- and polyfluoroalkyl substances) above 1 ppm total, individual or summed, for general packaging
• PFAS above 25 ppb for food-contact packaging, individual or total
• Non-compliance with UK food contact materials legislation, including restrictions on substances that may migrate into food
• Packaging formats already restricted or being phased out under UK law, including certain single-use plastic formats, even where technically recyclable
• Inks that don't comply with the raw material exclusion charter of EuPIA, the European Printing Ink Association
• Integrated electrical components that would be classed as electrical and electronic equipment, or batteries and accumulators, such as a box with an LED light in it

Read that again, because it's a category shift. Until now recyclability assessment was a question about format: is this material collected, sorted, reprocessed at scale. Now a pack that is perfectly recyclable in every physical sense can be automatically red because of what's in an ink, a coating, an adhesive or a barrier layer.

That has three consequences on a food site:

Your assessment now depends on supplier chemistry data you may not hold. Recyclability you could largely reason about from the spec sheet. PFAS at 25 parts per billion in a food-contact laminate, or whether an ink complies with the EuPIA exclusion charter, you cannot. That comes from your packaging supplier, and the request needs making now rather than in November.

Nothing about the pack has to change for the rating to change. Same artwork, same laminate, same everything, different answer. There's no physical trigger to prompt you to look. The PFAS Plan makes this concrete: further substances are expected to join the UK REACH candidate list, and a listing can move a pack to red without anyone touching the pack.

It cuts across a boundary most sites keep tidy. Food contact and chemical safety sit with one person; packaging extended producer responsibility (EPR) reporting sits with another, often in a different function. Automatic red on substances of concern requires those two to be talking.

The reds that need no data at all

There's a second list, and it's the one most likely to catch a food site, because it turns on format rather than chemistry. No supplier declaration needed, no testing, just look at the pack.

These are red:

• Paper or board with glitter adhered to it
• Padded polyethylene-lined envelopes
• Greaseproof, siliconised or waxed paper or board. This covers packaging using fibre densification, such as greaseproof paper, or a continuous surface treatment such as a wax or silicone coating layer applied to the paper or board. Wax dispersion coatings and silicone in linerless labels are exempt.

That third one deserves a minute of your time. Greaseproof and siliconised paper is ordinary on a food site: bakery liners, chilled interleaving, takeaway wraps, anything that needs to resist grease without a plastic film. If you use it and it's household packaging, it's red, and the only remedies are a format change or accepting the multiplier.

Note the exemptions carefully, because they're the difference between a red rating and a normal assessment. A wax dispersion coating is not the same thing as a wax coating layer, and the guidance treats them differently.

What red actually costs

Fee modulation started with the 2026–27 financial year, using data on packaging supplied in 2025, and the sums involved are not trivial.

Amber is the baseline: from 2026 the base fee for each material is calculated to be reflective of an Amber rating. Red pays more, green pays less, and the extra collected from red-rated material funds the green discount, so modulation reallocates the cost between formats rather than growing the pot.

The red multiplier escalates across the first three assessment years: 1.2 for 2026–27, 1.6 for 2027–28 and 2.0 for 2028–29. The green discount isn't fixed in advance, because it depends on the proportion of red, amber and green reported across the whole system.

Two things worth being precise about, since plenty of coverage isn't. Modulation applies to the household packaging waste disposal element of your fee, not to the whole pEPR bill. A 2.0 multiplier does not double what you pay. And a decision on modulation factors beyond that first period is due at the first review of the policy, no later than 2028.

So a pack that flips to automatic red on a substance issue doesn't just get a worse letter. It gets a worse letter with a multiplier attached to its disposal fee, on every tonne, for as long as it stays red.

What to actually do: the Monday morning list

1. Find out who holds the 2026 assessments and on what. If the answer is "a spreadsheet on someone's drive" you have a continuity problem before you have a compliance one.
2. Walk the site looking for greaseproof and siliconised paper. This is the cheapest hour you'll spend on RAM, because it needs no data from anyone. If it's there and it's household packaging, it's red.
3. Write to your packaging suppliers now. You need substance-level declarations covering inks, coatings, adhesives and barrier layers, not just the substrate. Lead times on this will be dreadful once everyone asks at once.
4. Sort your stock keeping units (SKUs) by tonnage, not by alphabet. Your top few packs by weight decide most of your fee. Assess those against RAM 2027 first and you'll know your exposure before you've finished the long tail.
5. Get packaging technical and food safety in the same room. One of them knows the pack, the other knows the chemistry. Automatic red needs both.
6. Check what your assessment is actually based on. If a rating rests on a supplier statement rather than data, write down which. That's the list you'll be glad of when someone asks.
7. Assume there will be a next version. RAM has been reissued twice already and the "doesn't carry forward" rule came with it both times. Plan for reassessment as a recurring job rather than a one-off.

The bit nobody says out loud

This is a design incentive dressed as a reporting exercise. The point of modulation is that badly recyclable packaging becomes expensive enough that you change it, and the multiplier schedule is the government saying so in numbers.

Which means the useful conversation isn't with your compliance function. It's with whoever signs off new packaging specs, because a decision made in a development kitchen in 2026 sets a fee you'll be paying in 2029.

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I work in quality in UK food manufacturing. This site exists because keeping up with this stuff is a second job nobody gives you hours for. If that's your life too, the newsletter is free: one plain-English update when something actually changes, nothing when it doesn't.