UK Packaging PRO Puts RAM Modelling at the Top of Its Agenda — and Your EPR Bills Depend on It
By Priory Direct | 6 July 2026 | Sources: Packaging News / PackUK / Gov.uk
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The organisation now responsible for co-ordinating packaging EPR compliance across the UK has confirmed its early priorities — and RAM modelling is at the top of the list. UK Packaging PRO, formally appointed in April 2026 and operating under PackUK's oversight, announced this month that it will focus on industry engagement around the Recyclability Assessment Methodology as fee modulation becomes an increasingly significant financial variable for every business that places packaging on the UK market.
At the same time, PackUK is expected to publish confirmed Year 2 EPR fees imminently — the first to include modulated Green, Amber, and Red rates rather than flat base fees. For businesses buying corrugated boxes, paper mailers, cardboard envelopes, and other fibre-based packaging, understanding where your formats sit in the RAM framework is now a direct cost management question. If you need a grounding in how EPR works before diving into modulation detail, our complete guide to UK EPR for packaging covers the full scheme from registration through to fee reporting.
What is UK Packaging PRO and what does it do?
UK Packaging PRO is the Producer Responsibility Organisation appointed by PackUK in April 2026, backed by over 100 major brands and trade bodies including INCPEN and the Food and Drink Federation. It acts as the operational interface between producers and the packaging EPR system — handling functions that PackUK is gradually delegating, including supporting producers with compliance submissions, developing modulation and recyclability assessment methodologies, and engaging industry on how packaging design decisions feed through to recycling outcomes.
Its appointment marks the shift from a purely government-administered EPR scheme to a more industry-co-ordinated model. UK Packaging PRO doesn't set fees — that remains PackUK's function — but it shapes the technical frameworks that determine how fees are calculated, including RAM.
"As modulation fees begin to play a greater role within the pEPR system, it is essential that producers have confidence in how packaging is assessed, how fees are determined, and how the system will develop over time."Foodservice Packaging Association, responding to UK Packaging PRO's early priorities statement, June 2026
UK Packaging PRO has also highlighted engagement with local authorities — bringing producers and councils together to understand how packaging design decisions influence kerbside collection and recycling outcomes. This is significant: it establishes a direct feedback loop between what producers put on the market and what local authorities can practically collect and process.
Why RAM modelling is the priority
The Recyclability Assessment Methodology is the technical engine behind EPR fee modulation. It assigns every type of household packaging a Green, Amber, or Red rating based on five criteria: whether the material is collected kerbside by at least 75% of UK local authorities; whether sorting infrastructure can identify and separate it; whether it can be reprocessed into quality recyclate; whether there is an end market for that recyclate; and the material's overall classification.
The RAM ratings determine which fee band a producer pays. From the 2026-27 scheme year, those bands carry real financial weight — and the gap widens significantly over the next two years. UK Packaging PRO's decision to prioritise RAM modelling engagement reflects industry pressure for greater transparency and predictability in how ratings are assigned, particularly for complex or composite materials where the methodology is less straightforward.
For businesses buying standard corrugated cardboard, kraft paper, or uncoated paperboard — the core formats that Priory Direct supplies — RAM ratings are relatively clear. These materials consistently achieve Green ratings. The complexity tends to arise with coated, laminated, or composite formats, which is precisely where UK Packaging PRO's engagement work focuses.
Further reading
New to UK packaging EPR?
Our complete EPR guide covers who is obligated, how fees are calculated, reporting deadlines, and what PackUK registration involves — from first principles through to compliance.
1.2×
base fee multiplier for Red-rated packaging in 2026–27
1.6×
Red-rated multiplier rising to this in 2027–28
2.0×
Red-rated multiplier by 2028–29 — double the base fee
£1.2bn
annual cost shift from taxpayers to packaging producers under EPR
How RAM-modulated fees actually work
Under the flat fee system of Year 1 (2025–26), every producer paid the same rate per tonne of a given material regardless of how recyclable their specific packaging format was. A well-designed corrugated box and a difficult-to-recycle plastic laminate both attracted the same fee for their respective material categories.
From Year 2 (2026–27) onwards, that changes. The Amber rate becomes the new baseline — equivalent to what the base fee was in Year 1. Green-rated packaging pays less than Amber. Red-rated packaging pays more, with the multiplier applied to the household waste disposal component of the fee only:
| Year | Green | Amber | Red |
|---|---|---|---|
| 2026–27 | Discount applied | 1.0× (baseline) | 1.2× |
| 2027–28 | Larger discount | 1.0× (baseline) | 1.6× |
| 2028–29 | Maximum discount | 1.0× (baseline) | 2.0× |
The premium on Red-rated packaging funds a pot that is redistributed as a discount to Green-rated packaging producers. Amber-rated packaging sees no change from the baseline. This design means the total pot collected by PackUK stays constant — the modulation is a redistribution mechanism, not an additional levy.
The practical implication is that switching from a Red-rated format to an equivalent Green-rated one doesn't just reduce your EPR fee — it does so at a compounding rate over the next three years, while also drawing down funding from businesses that haven't made the switch.
Year 2 confirmed fees: what's changed from Year 1
PackUK is expected to publish confirmed Year 2 EPR fees in June 2026, following the April 2026 reporting deadline. The Year 2 illustrative fees published in December 2025 gave the first view of modulated rates. Key signals from that publication:
- Year 2 Amber fees have increased for most materials compared to Year 1 base fees, ranging from a 1% increase for aluminium to a 60% increase for wood
- For paper and card — the base fee in Year 1 was £196 per tonne; Year 2 Amber fees are higher, with confirmed figures due imminently
- Green-rated paper and card formats will attract a discount below the Amber rate, partially offsetting the Amber increase
- Red-rated paper and card formats (coated, laminated, or composite) pay 1.2× Amber in 2026–27, rising steeply thereafter
"Companies that embrace these data requirements and use the insights to optimise their packaging choices will be the winners in this new landscape."John Redmayne, Managing Director, ERP UK
Where corrugated and paper packaging sits under RAM
For businesses shipping products in corrugated boxes, paper mailers, kraft envelopes, or uncoated paperboard, the RAM picture is straightforward and favourable. Standard corrugated cardboard is kerbside collected by virtually all UK local authorities, readily sorted at MRFs, widely reprocessed, and has strong end markets in the corrugated manufacturing supply chain. It consistently achieves a Green rating.
Paper mailers, kraft postal envelopes, and plain cardboard postal boxes follow the same logic — Green across all five RAM criteria provided they are uncoated and unlaminated. The same applies to paper-based void fill, tissue paper wrap, and paper tape.
Where businesses need to pay close attention is composite or coated formats:
- Foil-laminated paperboard — typically Amber or Red depending on foil content (Red threshold: >15% non-paper content by weight)
- Plastic-windowed envelopes — the plastic window component drags the overall rating toward Amber or Red
- Wax or plastic-coated boxes — coating typically results in Amber or Red, depending on the coating weight and type
- Padded mailers with plastic bubble lining — the composite nature typically results in Amber or Red; all-paper padded alternatives (crinkle kraft lining) rate Green
The practical guidance is simple: if your packaging is pure corrugated board, kraft paper, or plain paperboard with no coating or lamination, you are almost certainly in Green territory. If it contains any plastic, foil, or coating, it warrants a formal RAM assessment before your next reporting deadline.
What to do now
1. Confirm your RAM rating for every packaging format you use
If you haven't formally assessed the RAM rating of each packaging type in your range, do so before the next reporting deadline. Your compliance scheme or PackUK guidance can assist. For standard corrugated and paper formats you are likely already Green — but confirm it in writing so you can evidence it if queried.
2. Identify any Amber or Red formats and model the cost impact to 2029
For any packaging currently rated Amber or Red, calculate what the fee trajectory looks like at 1.2×, 1.6×, and 2.0× modulation. The cost of switching to a Green alternative is often lower than the accumulated fee premium over three years, particularly for higher-volume formats.
3. Switch plastic-lined or windowed formats to all-fibre alternatives
Plastic-windowed envelopes, bubble-lined mailers, and wax-coated boxes are the most common Amber or Red formats in a typical e-commerce packaging range. Each has a like-for-like fibre-based alternative — plain window-free envelopes, all-paper padded mailers, and uncoated corrugated — that achieves a Green rating and typically costs the same or less per unit.
4. Watch for UK Packaging PRO's RAM engagement outputs in H2 2026
UK Packaging PRO has committed to industry engagement on RAM modelling. That process is likely to produce updated guidance on edge cases, composite materials, and the methodology's evolution. If you have packaging formats where the RAM rating is ambiguous, monitoring these outputs — and engaging through your trade body or compliance scheme — will give you advance notice of any reclassifications before they affect your fees.
Need a broader EPR grounding?
Our complete guide to UK EPR for packaging covers who is obligated, how to register with PackUK, what data you need to report, and how the fee system works — from base fees through to RAM modulation. A useful starting point before your next compliance deadline.
Read the complete EPR guide →Green-rated packaging for your entire dispatch operation
Priory Direct supplies corrugated cardboard boxes, paper mailers, kraft envelopes, paper tape, and paper void fill — all uncoated, unlaminated, and consistently Green-rated under RAM. No composite formats, no hidden linings, no fee surprises.
Browse our range →Sources
- Packaging News — UK Packaging PRO confirms early priorities (12 June 2026)
- Gov.uk / PackUK — Year 2 illustrative waste disposal fees: EPR for packaging
- Gov.uk / PackUK — EPR for packaging: producer disposal fees modulation statement
- Gov.uk / PackUK — PackUK operational plan 2026 to 2027
- House of Commons Library — Packaging extended producer responsibility (updated June 2026)
- ERP UK / Resource Recycling — Producers receive first bills under UK packaging EPR
