RAM v1.1: What Changed and What You Need to Know

On 20 January 2026, OPRL and WRAP jointly published version 1.1 of the Recyclability Assessment Methodology – the framework that determines whether a packaging component is rated Green, Amber, or Red under the UK's Extended Producer Responsibility (EPR) scheme. For obligated producers who spent the back half of 2025 painstakingly assessing their portfolios against RAM v1.0, the natural reaction is a mixture of concern and frustration: what changed, and do I need to redo my assessments?

The short answer is that v1.1 is an incremental update, not a wholesale overhaul. The five-stage assessment structure remains intact. The core logic has not changed. But several of the underlying data inputs, classification boundaries, and assessment criteria have been revised in ways that materially affect the ratings of specific packaging formats. If you have PP trays, flexible plastics, fibre composites, or multi-component packaging in your portfolio, you need to pay close attention.

This article walks through every significant change in RAM v1.1, identifies which materials have had their ratings shift, explains the new "M" modifier system, and sets out what producers need to do now to ensure their RPD submissions remain accurate ahead of fee modulation taking effect later this year.

A Brief Recap: What Is the RAM?

The Recyclability Assessment Methodology is the standardised framework that all UK obligated producers must use to classify the recyclability of their packaging. Developed by OPRL in collaboration with WRAP, and endorsed by DEFRA for use within the EPR reporting system, the RAM evaluates each packaging component across five sequential stages:

1. Classification – Identifying the primary material and packaging format
2. Collection – Whether UK local authority kerbside or bring-site infrastructure exists to collect the material
3. Sortation – Whether materials recovery facilities (MRFs) can mechanically identify and separate the material, primarily via near-infrared (NIR) detection
4. Reprocessing – Whether sufficient UK-based or accessible reprocessing capacity exists to convert the sorted material into secondary raw material
5. End Markets – Whether viable commercial demand exists for the recycled output

A component must clear all five stages to achieve a Green rating. Failure at any stage results in a downgrade to Amber or Red, depending on the severity of the barrier. The resulting rating feeds directly into your RPD submission and, from the 2026-2027 compliance year onwards, will determine your fee modulation multiplier.

Why Did OPRL and WRAP Update the RAM?

RAM v1.0 was always understood to be a living document. When it launched in mid-2025 to support the first year of EPR reporting, OPRL and WRAP were explicit that the methodology would be updated periodically as new data became available. Several factors drove the v1.1 revision:

• Updated local authority collection data. Between the v1.0 data freeze (early 2025) and the v1.1 revision, a number of local authorities changed their kerbside collection policies, particularly around flexible plastics and certain composite materials. The collection coverage thresholds needed to reflect the 2025-2026 reality on the ground.
• MRF sortation technology advances. NIR detection capabilities have continued to improve, and several large MRF operators upgraded their sorting lines during 2025. The sortation stage criteria needed updating to reflect current, not historical, detection rates.
• Industry feedback on multi-component assessment. During the first cycle of RPD submissions, producers raised numerous questions about how to assess packaging with multiple attached components (e.g., a card sleeve permanently bonded to a plastic tray). The v1.0 guidance was ambiguous, and v1.1 provides clearer rules.
• Reprocessing capacity changes. New reprocessing facilities came online during 2025, while some existing facilities adjusted their intake specifications. The capacity thresholds at Stage 4 needed recalibration.
• Alignment with the "designed for recycling" vs "recycled in practice" policy position. DEFRA and the Scottish Government provided further guidance in late 2025 on how the RAM should distinguish between packaging that is theoretically recyclable and packaging that is actually recycled at scale within the UK system. This distinction has been made more explicit in v1.1.

Key Changes in RAM v1.1 vs v1.0

Below is a detailed breakdown of every area where v1.1 diverges from v1.0. We have grouped these by the RAM stage they primarily affect.

1. Updated Material Classification Categories (Stage 1)

RAM v1.0 used a set of material classification categories broadly aligned with the PRN material categories. Version 1.1 introduces three new sub-categories within the plastics classification to provide more granular assessment:

• Flexible mono-material PE is now separated from the general "flexible plastics" category, reflecting the fact that mono-material PE films have a distinct and increasingly viable recycling pathway (particularly through front-of-store collection schemes and dedicated PE recycling streams).
• Flexible mono-material PP has been similarly separated, acknowledging that PP-only flexibles behave differently at sortation and reprocessing compared to multi-polymer laminates.
• Rigid PP (non-bottle) has been given its own assessment pathway, distinct from rigid PP bottles. This is significant because PP trays, pots, and tubs face different sortation and reprocessing dynamics than PP bottles, and the v1.0 approach of assessing them under the same criteria was producing misleading results.

For fibre-based packaging, v1.1 also introduces a clearer distinction between fibre composites with separable layers (e.g., a card box with a removable plastic window) and fibre composites with non-separable layers (e.g., liquid cartons with laminated PE/aluminium barriers). These two categories now follow different assessment pathways from Stage 3 onwards.

2. Revised Sortation Criteria (Stage 3)

The sortation stage has seen some of the most consequential updates. RAM v1.0 used NIR detection rates based on 2023-2024 MRF performance data. Version 1.1 updates these to reflect 2025 data, which shows measurable improvements in detection capability for several material types:

• PP detection rates have improved from a v1.0 baseline of approximately 72% to a v1.1 baseline of 81%, driven by MRF equipment upgrades and improved polymer library databases in NIR systems. This is the single change most responsible for shifting PP tray ratings.
• Carbon black alternatives are now explicitly recognised. The v1.0 sortation criteria treated all dark-coloured plastics as a single category with uniformly poor NIR detectability. Version 1.1 introduces a distinction between carbon black pigmented packaging (which remains NIR-invisible and fails Stage 3) and packaging using NIR-detectable dark pigments (which can now pass Stage 3 provided the specific pigment system is on the OPRL-approved list).
• Flexible film sortation thresholds have been tightened. While rigid plastics saw improved detection rates, the v1.1 data shows that MRFs continue to struggle with flexible film sortation. The minimum detection rate threshold for flexible films has been revised upward from 50% to 60%, meaning some flexible formats that marginally passed under v1.0 now fail under v1.1.

3. Changes to Reprocessing Capacity Thresholds (Stage 4)

RAM v1.0 set reprocessing capacity thresholds based on the principle that at least 30% of the collected and sorted material must have access to UK-based reprocessing capacity. Version 1.1 raises this threshold to 40%, reflecting DEFRA's stated policy direction of reducing reliance on export markets for recycling.

This change has a targeted impact. Materials with abundant UK reprocessing (clear PET, HDPE, aluminium, glass, corrugated card) comfortably clear the new threshold. But materials where UK reprocessing is more limited – particularly certain flexible plastics and fibre composites – are affected. Two new reprocessing facilities that came online in late 2025 (one specialising in PP, one in PE film) have been factored into the v1.1 capacity calculations, partially offsetting the higher threshold for those specific materials.

4. New Guidance on Multi-Component Packaging Assessment

This was one of the most requested clarifications from the first reporting cycle. RAM v1.1 introduces a formal decision tree for multi-component packaging:

• Separable components (components that a consumer can reasonably separate by hand without tools) are assessed individually. Each component receives its own RAM rating and is reported separately in the RPD.
• Non-separable components (permanently attached, bonded, or integrated) are assessed as a single unit. The material classification is determined by the primary material by weight, but the assessment must account for the impact of the secondary material on sortation and reprocessing. For example, a predominantly card tray with a non-separable plastic film liner is classified as fibre composite and assessed under the composite pathway.
• The "contamination threshold" rule is new. If a non-separable secondary component constitutes more than 5% by weight and is known to be a contaminant in the primary material's recycling stream, the overall component is automatically downgraded by one rating level (e.g., from Green to Amber, or from Amber to Red).

5. Updated Collection Infrastructure Data (Stage 2)

The collection coverage figures in v1.1 reflect local authority collection policies as of October 2025, replacing the January 2025 data used in v1.0. Notable changes include:

• Flexible plastic collection coverage rose from 54% to 67% of UK local authorities, driven by the continued rollout of flexible plastic kerbside collection under Simpler Recycling mandates. However, the 67% figure still falls below the 75% threshold required for a "pass" at Stage 2 for household packaging, meaning flexible plastics continue to face collection barriers in the RAM – though the gap is narrowing.
• Rigid PP collection coverage crossed the 75% threshold for the first time, moving from 73% in v1.0 to 78% in v1.1. This is the other key factor behind the PP tray rating shift.
• Fibre composite (beverage carton) collection remained essentially static at 68%, still below the pass threshold.

6. "Designed for Recycling" vs "Recycled in Practice"

RAM v1.0 assessed recyclability based on technical capability: can this material be recycled given existing infrastructure? Version 1.1 sharpens this to include a throughput test: is this material being recycled at meaningful scale? Specifically, Stage 4 now includes a secondary criterion requiring evidence that at least 20% of the material placed on market is actually reaching reprocessors, not just that reprocessing capacity nominally exists.

This change primarily affects materials where infrastructure exists in theory but utilisation rates are low. Certain fibre composites and niche plastic formats are most exposed to this additional test.

Materials Whose Ratings Changed Between v1.0 and v1.1

The following table summarises the packaging formats where the RAM rating outcome has changed as a result of the v1.1 updates. Not every component in these categories will be affected – specific product characteristics matter – but these are the formats where producers should re-examine their assessments.

The "M" Modifier: R-M, A-M, and G-M Ratings Explained

One of the more subtle additions in RAM v1.1 is the introduction of the "M" modifier suffix. This applies to packaging components whose rating is expected to change within the next 12 to 18 months based on confirmed infrastructure investments or policy changes. The modifier does not change the current rating – it signals that the rating is under active review and is likely to shift in the next RAM version.

The three modulated ratings work as follows:

• R-M (Red-Modulated): Currently Red, but confirmed infrastructure developments (e.g., new reprocessing capacity, expanded collection coverage) mean the material is expected to move to Amber or Green in the next 12-18 months. Producers should monitor but can begin planning material transitions with confidence that the recycling pathway is developing.
• A-M (Amber-Modulated): Currently Amber, but either improving infrastructure (potential upgrade to Green) or deteriorating conditions (potential downgrade to Red) have been identified. The direction of expected change is specified in the assessment notes.
• G-M (Green-Modulated): Currently Green, but risk factors have been identified that could result in a downgrade. This might include a major reprocessor announcing closure, or changes to local authority collection policies that could reduce coverage below the threshold.

For RPD reporting purposes, the base rating (R, A, or G) is what you submit. The "M" modifier is informational only and does not affect fee modulation calculations in the current compliance year. However, it is a valuable forward-planning signal. If a significant portion of your portfolio carries A-M ratings with an expected downgrade direction, you should be treating those components as high-priority for redesign, even if their current fees are at the Amber rate.

Impact on Existing RPD Submissions

If you submitted RPD data for the October 2025 reporting window using RAM v1.0 ratings, the question is whether you need to re-submit. The answer depends on the timing and the specifics of your packaging.

For the April 2025 – September 2025 reporting period: Data already submitted under v1.0 does not need to be re-assessed. DEFRA has confirmed that data submitted in good faith under the methodology version current at the time of submission will be accepted. No retrospective re-rating is required.

For the October 2025 – March 2026 reporting period (due April 2026): DEFRA expects producers to use RAM v1.1 for this submission. If your packaging portfolio includes any of the formats listed in the ratings change table above, you should update your assessments before your April 2026 submission.

For the 2026-2027 compliance year onwards: RAM v1.1 is the mandatory version. All assessments must be conducted against v1.1 criteria. The fee modulation multipliers will be applied based on v1.1 ratings.

What Producers Need to Do Now

With RAM v1.1 now in effect and the April 2026 reporting deadline approaching, producers should take the following steps:

1. Re-Assess Your Full Portfolio Against v1.1

Do not assume your v1.0 assessments carry forward unchanged. Systematically re-evaluate every packaging component using the updated v1.1 criteria, paying particular attention to PP formats, flexible plastics, fibre composites, and multi-component packaging. For large portfolios, prioritise by tonnage – focus on the highest-volume components first, as these have the largest fee modulation impact.

2. Update Your RPD Data

Any components whose ratings have changed under v1.1 must be updated in your packaging data before the April 2026 submission. Ensure your internal systems reflect the new ratings, and update any downstream reporting tools or spreadsheets you use to prepare your RPD file. If you use an automated compliance platform, verify that it has been updated to apply v1.1 rules.

3. Engage Your Packaging Suppliers

Several of the v1.1 changes create opportunities. If you have rigid plastics currently using carbon black pigment, talk to your supplier about switching to an NIR-detectable dark pigment from the OPRL-approved list. If you have fibre composites with separable components, confirm that the design supports easy consumer separation and update your on-pack instructions. If you have PP trays that have moved to Green, communicate this to your sales and marketing teams – it is a genuine sustainability win worth highlighting.

4. Review Multi-Component Packaging Designs

The new multi-component rules may mean that packaging you previously assessed as a single unit now needs to be broken down into separately assessed components, or vice versa. Walk through the v1.1 decision tree for every multi-component format in your portfolio. Pay particular attention to the 5% contamination threshold rule, which can cause unexpected downgrades for packaging with non-separable secondary materials.

5. Monitor "M" Modifier Signals

Check whether any of your packaging formats have been assigned an "M" modifier in the v1.1 assessment guidance. For formats flagged as A-M with expected downgrade, start exploring material alternatives now rather than waiting for the downgrade to take effect. For formats flagged as R-M with expected upgrade, factor the anticipated improvement into your long-term portfolio planning – but do not change your RPD data until the upgrade is formally confirmed in a future RAM version.

Looking Ahead: What to Expect in RAM v1.2

OPRL has indicated that the next RAM revision is expected in Q3 2026, with the working title RAM v1.2. Based on the "M" modifier signals in v1.1 and the current trajectory of UK recycling infrastructure investment, the most likely changes in v1.2 include:

• Flexible mono-material PE upgrading to Green if front-of-store and kerbside flexible collection coverage crosses the 75% threshold (currently 67% and rising)
• Beverage carton fibre composites potentially returning to Amber if the new Valpak-backed fibre composite reprocessing facility in the Midlands begins accepting material at scale
• Further tightening of the "recycled in practice" throughput test, potentially raising the minimum throughput requirement from 20% to 25%

The direction of travel is clear: the RAM will continue to become more granular, more data-driven, and more demanding. Producers who build recyclability into their packaging design process – rather than treating it as a compliance afterthought – will find each successive version easier to navigate. Those who do not will face an increasingly punitive fee environment.

RAM v1.1 is not a disruption. It is a refinement. But refinements matter when they change your fee exposure. Take the time to understand the changes, re-assess your portfolio, and update your data. The April 2026 deadline is closer than it feels.