UK packaging regulations PFAS limit turns packs red above 1 ppm from 2027, and food packaging above 25 ppb

How PackUK's automatic red works

RAM is the test that sorts UK household packaging into red, amber and green for extended producer responsibility (EPR) fees. Large producers are “legally required to use the RAM to assess the recyclability of the household packaging they supply”, according to PackUK’s RAM 2027 overview, and the result feeds fee modulation, the system that charges more for less recyclable packaging.

The materials guidance runs in three steps. Step 1 is a check for automatic red packaging, Step 2 assesses the material category and Step 3 assesses recyclability. Its Step 1 sentence reads: “You must rate your packaging as red automatically if any of the following apply:”. Six criteria follow, and PFAS is one of them.

That line is the point of the rule for producers. A pack that fails Step 1 does not reach the material and recyclability steps, so good recycling performance elsewhere cannot rescue it. The guidance also says an item assessed as red at any stage is reported as red, and a final green needs a green result at every stage.

The rating matters because of the fee. PackUK’s overview says red-rated materials will cost more than more recyclable ones. The modulation statement of 28 June 2025 sets how much higher, and the next table shows how the automatic red list has moved between versions¹.

SPI analysis: Step 1 works as a gate, not a weighting. A carton that would score green on fibre recovery is red if a component holds 1.1 ppm of total PFAS, so PFAS data now decides the rating for some packs before any recycling evidence is read.

The scope is narrower than all UK packaging. RAM ratings apply to household packaging, and SPI’s UK tracker notes that commercial and industrial packaging that never reaches a household bin carries no disposal fee under regulation 60 of the 2024 regulations. Small producers register and report but pay no disposal fee, so the PFAS rating changes a bill only for large producers of household packaging.

What changed between RAM 1.1 and RAM 2027

RAM 1.1 for 2026 supply. The RAM version 1.1 guidance on GOV.UK, first published on 23 December 2024 and last updated on 4 September 2025, says: “If perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) have been intentionally added to packaging, this is also an automatic red.” It adds: “However, this does not apply if the predominant material is aluminium, steel or glass.” That version still applies to everything supplied in 2026.

RAM 2027 published on 1 July 2026. PackUK’s news story of that day says RAM 2027 is the framework producers use under packaging EPR and that it “responds directly to stakeholder feedback”, with a focus on clarity, consistency and accessibility. The Step 1 PFAS criterion in the new materials guidance reads in full: “an item or component contains more than 1 parts per million (ppm) of total perfluoroalkyl and polyfluoroalkyl substances (PFAS) (individual or sum), or PFAS in food packaging exceeding 25 parts per billion (ppb) for any individual or total PFAS”.

Two clarifying updates in July and August. The collection page lists three change notes: a translation on 1 July, a clarified detergent bottle example on 2 July, and on 20 August an amendment “to clarify examples of evidence of traceability for take-back schemes”. None of the three touches PFAS. The news story page carries an update date of 26 October 2026 in its metadata, but it shows no change note and does not mention PFAS³.

The webinar on 26 August. In joint slides hosted by the Food and Drink Federation, PackUK listed “PFAS above limits” among six automatic reds, with “Non-food packaging >1 ppm” and “food packaging >25 ppb”. Slide 31, headed “Why the changes to automatic reds?”, says the threshold applies to “all material categories, intentionally added or otherwise”.

The EU restriction took effect on 12 August. One day earlier, the European Commission’s environment department announced that the PPWR’s food-contact PFAS limits were entering into application.

Calls for a delay, as reported. Trade press reported on 2 November that the Packaging Federation, with other industry bodies, had asked PackUK to defer the PFAS change by 12 months and keep the RAM 1.1 “intentionally added” wording, and that the Confederation of Paper Industries and the British Plastics Federation had also criticised the change. The same report said PackUK had set up a technical expert group and would give an update as soon as possible. SPI has not yet confirmed any PackUK or Defra statement on GOV.UK about such a group, its members or a timetable¹².

What UK packaging regulations PFAS limits require from 2027

The obligation sits with large producers, those above GBP 2 million turnover and 50 tonnes of packaging a year under the 2024 packaging regulations, as SPI’s UK tracker sets out. They must rate the household packaging they supply in 2027 under RAM 2027 and report it in two halves: data for January to June 2027 by 1 October 2027 and for July to December by 1 April 2028, according to PackUK’s 1 July news story.

The PFAS criterion is one of six automatic reds. The table below sets them out as the materials guidance lists them, with what each means for a pack. Two features stand out for PFAS. The limit applies to “an item or component”, so a liner, label, coating or closure can turn a whole pack red, and the 1 ppm limit covers non-food packaging as well as food packaging.

PackUK’s overview says RAM “will be updated each year and published before the next reporting year starts”, and that PackUK “may consider adding additional criteria for automatic red rating in future iterations of the RAM”. Any change to the PFAS limit for 2027 supply would therefore need a revised RAM 2027 or a statement before 1 January.

SPI analysis: the timing gap between supply and billing is the reason the rule matters now. PackUK’s modulation statement says the first modulated fees, for 2026 to 2027, are calculated on packaging supplied in 2025. On the same two-year cycle, packaging supplied in 2027 and rated under RAM 2027 feeds the 2028 to 2029 fee year, the first at the full 2.0 factor. Producers fix their 2027 pack specifications in the coming weeks, but the cost of a PFAS red arrives on an invoice in the 2028 to 2029 year.

SPI calculation: 1 ppm equals 1,000 ppb, so the UK limit for non-food packaging is 40 times the 25 ppb limit for food packaging. A food wrap and a non-food mailer made from the same grade can therefore get different ratings at the same PFAS level.

Who pays most if packaging turns red

Paper and board food packaging. The Commission’s August news names takeaway containers and fast-food wrappers among the food packaging where PFAS have been used, and these are the formats where the 25 ppb food limit bites. At PackUK’s illustrative year 2 fees, paper and board is GBP 210 a tonne amber and GBP 250 red. By SPI’s calculation, holding that amber fee constant, a red tonne would cost GBP 420 at the 2.0 factor.

Recycled-content grades. PackUK’s slides say the limit covers PFAS “intentionally added or otherwise”. A grade that carries low PFAS levels from recycled input can therefore be caught even though nobody added PFAS, which is the concern the trade bodies raised, as reported on 2 November.

Fibre-based composites. Cups and cartons sit in the fibre-based composite category, the highest illustrative amber fee at GBP 525 a tonne. At the 2.0 factor, by SPI’s calculation on the same constant-fee basis, a red tonne would cost GBP 1,050, the largest per-tonne exposure in the table.

Metal and glass packaging. RAM version 1.1 exempted packaging made mainly of aluminium, steel or glass. RAM 2027, on PackUK’s slides, covers all material categories, so coatings, liners and closures on cans, jars and bottles come into scope for the first time.

Plastic packaging. Plastic pays GBP 455 amber and GBP 545 red in the illustrative year 2 table. At 2.0 it would be GBP 910 a tonne by SPI’s calculation, before Plastic Packaging Tax, a separate HMRC charge.

SPI calculation: a producer supplying 1,000 tonnes of paper and board food packaging in 2027 would pay GBP 210,000 at the year 2 amber fee, and GBP 420,000 if the whole tonnage were rated red at the 2.0 factor, holding fees constant. The PFAS rating alone would add GBP 210,000 a year to that line.

SPI analysis: the table compares per-tonne fees within one currency and one scheme. It is not a forecast. PackUK sets each year’s base fees from council costs and reported tonnage, and the green discount moves with how much red tonnage producers report.

The data gap behind the PFAS threshold

Neither the RAM 2027 materials guidance nor the RAM 2027 overview names a test method for PFAS. The guidance does not say whether “total” PFAS means a sum of targeted analyses or a broader measure that includes polymeric PFAS, and the PackUK and FDF slides give no PFAS-specific evidence rule. The only evidence line in the slides is a general one under Step 3: “MISSING EVIDENCE? Contact your supplier.”

This matters because the EU uses three distinct measures. Commission Notice C/2026/3084 quotes Article 5(5) of the PPWR as setting “25 ppb for any PFAS as measured with targeted PFAS analysis”, “250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis” and “50 ppm for PFASs (including polymeric PFAS)”. The UK text uses one word, “total”, for limits of 1 ppm and 25 ppb⁹.

The general evidence section of the materials guidance requires producers to keep records of the RAM rating they applied, but it does not mention PFAS. SPI has not yet confirmed what evidence PackUK or the environment agencies will accept for a PFAS result, or how they will treat packaging rated without one.

SPI analysis: until PackUK defines the basis, a producer cannot know in advance whether a supplier’s targeted-analysis result answers the UK total limit. That uncertainty, more than the limit itself, is what the reported request for more time turns on.

The 1 ppm and 25 ppb figures sit in PackUK’s RAM guidance, which large producers must use under the 2024 EPR regulations, not in a separate PFAS law. That makes the RAM text the place where the limits are defined, and where any change would appear, so producers should watch the RAM 2027 collection page and its change notes rather than legislation.gov.uk for the next move.

How UK PFAS rules compare with PPWR PFAS limits

PFAS in food packaging regulations now differ on each side of the Channel in kind as well as in number. The EU restriction in Article 5(5) of Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), applies from 12 August 2026 and bars food-contact packaging at or above its limits from the EU market. The UK rule, in RAM 2027, does not ban sale: it rates packaging red and prices it through the EPR fee.

The individual limit matches. Both set 25 ppb for any single PFAS in food packaging. This is the alignment PackUK’s slide refers to.

The total limit is lower in the UK on the face of the wording. The UK caps “total” PFAS in food packaging at 25 ppb. The EU caps the sum of targeted PFAS at 250 ppb and total PFAS including polymers at 50 ppm. By SPI’s calculation, the UK figure is one tenth of the EU sum limit and one two-thousandth of the EU total limit, but this holds only if the measures are comparable, which GOV.UK does not define.

The UK adds a non-food limit. The EU’s Article 5(5) covers food-contact packaging only, while Article 5 asks for substances of concern to be minimised generally. The UK’s 1 ppm limit applies to all household packaging in RAM’s scope.

The review clocks differ. The Commission reviews the EU restriction by 12 February 2030, SPI’s EU tracker shows, while PackUK updates RAM each year.

SPI analysis: a brand selling into both markets may find the UK test stricter in two ways and looser in one. The UK reaches non-food packs and may set a lower total, but a red rating costs money rather than market access, so the EU rule still sets the floor for whether a food pack can be sold in the EU at all.

SPI analysis: for a UK and EU supply chain, the simplest reading is to hold one set of PFAS results per grade that answers all three EU measures and the UK total limit together. A supplier that reports only a total fluorine screen below 50 mg/kg meets the EU’s evidence trigger but says nothing direct about a 25 ppb UK total. Ask what each result measures, not only whether it passes.