PackUK opens RAM 2028 to producer change requests, with evidence due by 31 December as red multipliers climb

How RAM ratings set the fee

Under the 2024 packaging regulations, tracked as PR-GB-002, a large producer pays PackUK a disposal fee for each tonne of household packaging it supplies. From year 2, that fee is modulated by recyclability, tracked as PR-GB-003. PackUK’s RAM 2027 announcement of 1 July 2026 puts it plainly: RAM assessment outcomes decide whether packaging is red, amber or green, and that rating feeds fee modulation.

The mechanics sit in PackUK’s modulation statement, dated 28 June 2025. Amber is the base fee. Red pays the base fee times 1.2 in 2026 to 2027, 1.6 in 2027 to 2028 and 2.0 in 2028 to 2029, and the extra red revenue funds an equal percentage discount on every green tonne. Total fees do not rise because of modulation; costs shift between packs. A decision on factors after 2028 to 2029 is due no later than 2028.

The rating rules matter as much as the multiplier. GOV.UK’s RAM guidance, last updated on 4 September 2025, says household packaging in scope that has not been assessed, or lacks the detail for an assessment, must be classed as red. Only large producers must collect and report RAM data. The statement adds that the most recent RAM version is used when each year’s invoices are generated.

Until now, PackUK alone drove the annual rewrite. The RAM 2027 overview says PackUK is responsible for designing, maintaining and publishing the RAM, advised by an independent Technical Advisory Committee, and that each annual update will be evidence led.

What changed this week

22 October: a joint announcement. PackUK published A new approach to RAM updates on GOV.UK, setting out a process introduced by PackUK and UK Packaging PRO. It says the new process gives producers clearer routes to engage and more visibility of how evidence is assessed and how future updates are set and prioritised. It was built, the release says, after producers and stakeholders across the value chain asked for greater predictability and more time to prepare for changes.

The deadline: 31 December 2026. The release says change requests for RAM 2028, with supporting evidence, go to UK Packaging PRO by 31 December 2026. That gives 70 days from the announcement, or 68 days from 24 October, by SPI’s calculation. The release does not name a submission form; it links to the PRO’s page for detail. The window overlaps year 2 billing: PackUK intends to issue the year 2 notice of liability by the end of November 2026, so teams will read their first modulated bill while the window is open.

The PRO’s page: the how. The UK Packaging PRO’s RAM evidence page, which carries no publication date, asks producers to complete an evidence submission form, published as an Excel file named RAM 2028 Technical Discussion Template, and to email it with supporting evidence to a dedicated RAM evidence address listed on the page. The PRO says that address is only for completed forms and evidence. SPI has not yet confirmed the fields the template asks for.

The scope: a transition year. The PRO’s page says RAM 2028 will be a transition year while PackUK and the PRO develop and refine the new process. Changes will focus on fewer priority areas, including take-back scheme guidance that producers have already raised. Future updates are meant to be targeted rather than full annual redesigns, the page says.

PFAS and direct printing under review. The same page says PackUK and the PRO are already reviewing existing guidance on PFAS and on direct printing on polypropylene (PP), in response to producer feedback. Neither the GOV.UK release nor the RAM 2027 overview mentions those two topics, so the PRO’s page is where the two topics are named for 2028.

23 October: an early read from foodservice. The Foodservice Packaging Association’s digest of 23 October told members that proposals should show where the method could improve, backed by practical experience, technical evidence or the effects of current requirements. The same digest set out the FPA’s own PFAS position on RAM 2027.

What producers can submit, and how

The two official texts set out a short process. A producer, or another stakeholder in the packaging chain, identifies a RAM rule it thinks should change, fills in the PRO’s template and sends it with its evidence by 31 December 2026. The PRO’s page says UK Packaging PRO will then review submissions to judge whether there is a case for change, and may come back with follow-up questions, requests for more information or a call.

Strong cases go further. The PRO says it will bring together experts from across the packaging and recycling sectors to examine them, and will help develop recommendations for PackUK. Not every suggestion will lead to a change, the page warns. Where several proposals arrive, a transparent process will rank them, putting effort into changes backed by strong evidence and offering the widest benefit across the packaging system.

The final say stays with PackUK. PackUK’s operational plan for 2026 to 2027, updated on 10 August 2026, lists functions that cannot be delegated to the PRO, including fee setting, sign-off and ownership of data and the administration of payments⁹. The RAM itself is published by PackUK, both the overview and the PRO’s page say.

Timing for the result is open. RAM 2027 was published on 1 July 2026 for packaging supplied from 1 January 2027, under PackUK’s July announcement, and producers use RAM version 1.1 for 2026 data. Neither text gives a publication date for RAM 2028, and SPI has not yet confirmed which reporting year it will apply to.

The rules already in play for 2028

Three of the topics named for 2028 are among the most contested in RAM 2027. The RAM 2027 materials assessment guidance, updated on 20 August 2026, sets the current position for each.

PFAS. Under RAM version 1.1, used for 2025 and 2026 data, intentionally added PFAS make packaging an automatic red, unless the main material is aluminium, steel or glass, according to GOV.UK’s RAM guidance. RAM 2027 switches to a threshold: an automatic red where an item or component contains more than 1 part per million of PFAS, and more than 25 parts per billion for food packaging.

Direct printing on polypropylene. RAM 2027 rates clear or white HDPE or PP items red if they carry any direct printing other than a batch code or expiry date. In-mould labels made from the same polymer as the main item are exempt.

Take-back schemes. Packaging recycled through a take-back scheme can only be amber if the producer has evidence of processing at each stage; otherwise it is red. The RAM 2027 overview adds an access test: drop-off points within 5 miles of 75% of UK people or households, or a postal service covering 75% of addresses, with no brand or purchase limits. Producers must tell PackUK when they report amber on this basis.

Flexible plastics. The materials guidance says flexible packaging items cannot currently be rated green. Amber is reachable only through the take-back route, which is why take-back guidance sits at the top of the 2028 list.

Who gains and who pays as red gets dearer

Flexible plastics makers and users. With green unavailable and amber reachable only through take-back, flexible packaging without take-back evidence is rated red. At PackUK’s December 2025 illustrative year 2 rates, red plastic costs £545 a tonne against £455 amber, so 1,000 tonnes moved from red to amber saves £90,000, by SPI’s calculation. The kerbside route has also slipped: the LGA’s briefing of 17 July 2026 says councils in England must collect flexible plastic from all households from 1 April 2030, not 31 March 2027.

Retailers running take-back points. The same LGA briefing says retailer front-of-store collections should continue until local collections are in place, and cites Valpak research that 45 councils in England already collect flexibles. Clearer take-back evidence rules in 2028 would decide whether those points earn producers amber ratings.

Foodservice and fibre packaging. PFAS thresholds bite hardest on food-contact packaging, where RAM 2027 sets a 25 parts per billion limit. Fibre-based composite carries the highest illustrative amber rate, £525 a tonne, and £630 red.

ALDI UK. ALDI UK reports a 2023 plastic packaging footprint of 124,940.15 tonnes, of which own-label primary packaging was 110,305.88 tonnes, which ALDI UK puts at 90% of the footprint (88.3% by SPI’s calculation). As brand owner of its own label, it is the obligated producer for that packaging under PR-GB-002.

Tesco. Tesco’s Sustainability Report 2026 says 99% of its Own Brand packaging is recyclable in the UK and, of this, 87% is recyclable at kerbside. The rest of that recyclable share, packaging recyclable in the UK but not at kerbside, is the group where take-back evidence rules matter most.

SPI calculation (illustration only): if 1% of ALDI UK’s 2023 own-label primary plastic, 1,103 tonnes, moved from red to amber, the year 2 illustrative bill would fall by about £99,300. At a 2.0 multiplier on the same £455 amber base, the same shift would be worth about £501,900. These use 2023 tonnage, assumed ratings and illustrative rates, and are not the company’s liability.

The evidence problem behind the ratings

The new process runs on evidence, and evidence is the scarce input. When PackUK published illustrative year 2 rates in December 2025, RAM data covered only 45% of first-half 2025 tonnage, and of that, 71% was rated green, 8% amber and 21% red. PackUK said the rates were likely to change significantly as more data arrived, and put the green discount at a provisional 9% or so⁸.

Because modulation is budget neutral, one producer’s ratings move every other producer’s bill. More red tonnage means a larger premium pool and a deeper green discount; a rule change that moves a format from red to amber shrinks both.

Evidence also has to be usable by thousands of producers. The FPA’s 23 October digest says PackUK’s PFAS technical subgroup is looking at other testing and screening routes, and that the FPA wants supplier declarations accepted. Take-back has the same issue: the amber route needs evidence of processing at each stage, which a brand owner rarely holds itself.

Timing adds to the strain. RAM 2027 was published on 1 July 2026, six months before it applies, and the RAM 2028 window closes before the first data return under RAM 2027 is due on 1 October 2027. Cases for 2028 must therefore rest on 2025 and 2026 data rated under RAM version 1.1, or on a producer’s own trials, rather than a full year under the rules they seek to change.

How the UK's method compares with France, the Netherlands and the EU

The UK is not the first to hand part of the recyclability rulebook to producers’ own bodies. In France, Citeo’s 2026 tariff guide, updated on 22 June 2026, says technical committees (COTREP for plastics, CEREC for paper and board, COCET for sorting behaviour) assess whether a pack disrupts recycling, and Citeo’s board decides which packs join the malus list. Maluses step up from 10% to 25%, 50% and 100% of the contribution.

In the Netherlands, Verpact’s 2026 policy, version 3.3, runs a plastic tariff differentiation scheme with a maximum discount of EUR 0.60 a kilogram in 2025 and 2026, set against base rates of EUR 1.22 a kilogram for rigid plastic and EUR 1.32 for flexible. The Dutch lever is a discount for better design, where the UK pairs a red premium with a green discount.

At EU level, the recitals of Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, say recyclability criteria apply from 1 January 2030 and that packaging should be at least grade B from 1 January 2038. They also say EPR fee modulation criteria will be harmonised by recyclability grade, without setting the amounts of fees.