By assessing the recyclability of their packaging, producers will assign each component a RAG output, to be reported in their bi-annual EPR submissions, which will determine the modulation of disposal fees:
Red (not collected from kerbside, or difficult to recycle at scale) = Higher Fees
Amber (faces challenges during recycling or affects the quality of recyclate) = No Modulation
Green (widely recyclable with current UK infrastructure) = Lower Fees
You will have to complete recyclability assessments if you are a large producer that supplies household, or public bin, packaging to the UK market. (Excluding drinks containers in scope of DRS)
Obligated producers will have to assess their packaging, or packaging components, and report the output alongside their packaging data bi-annually as part of their pEPR submissions.
Small producers aren’t obligated to complete recyclability assessments, but may be affected due to their suppliers having to complete assessments in their stead and being charged resultant costs.
Starting from 1 January 2025, producers will need to begin assessing their relevant packaging against the RAM.
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January – June packaging data to be submitted to the regulator by 1 October (delayed)
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July – December packaging data to be submitted to the regulator by 1 April of the following year.
Disposal fee invoices will then be raised to producers in July (October 2025 for the first year of fees) with the option to pay in quarterly instalments.
In June 2025 it was confirmed through an Environment Agency Regulatory Position Statement, that there will be a six-month respite for producers for reporting the output of their recyclability assessments.
