Recyclability Assessment Deadline Delayed – RPS 350

As was probably always quite likely, the Environment Agency have now published a Regulatory Position Statement (RPS) to give large producers under the UK´s Extended Producer Responsibility Regulations for Packaging some breathing space when it comes to submitting their Recyclability Assessments (RA´s), that were originally due by October.

The RPS is quite clear that the legal deadline of October 2025 still stands, however they have stated that they ´will not normally take enforcement action against you if you do not comply´, providing that the RA data is submitted by 1st April 2026. Read the full text of the Extended Producer Responsibility for Packaging (pEPR) recyclability assessment obligations: RPS 350.

What this does mean however is that if, as a large producer, you decide to delay your submission until 1st April 2026, your disposal fees calculated in financial year 2026-2027 will be based on the data submitted in April 2026 and applied to the whole of the data reported in CY 2025. As opposed to your October submission being used for the first half year´s data submission and your April submission being used for the second half year´s data.

This does provide large producers with some much needed breathing space to organise their recyclability assessments. Need help with your Recyclability Assessments?

Visit our Recyclability Assessment Tool page for further information on our Tool or Contact us for a demo of our simple to use Recyclability Assessment Tool and let our simple software solutions take the pain away. Our mission is to simplify the complex.

Surprise Revision to The Recyclability Assessment Methodology (RAM)

The Governments Recyclability Assessment Methodology (RAM) has already been amended. First published in December 2024, the RAM underwent minor amendments to a few typos in February of this year, but has since been amended significantly in April.

Despite it stating that ´Updates from version 1 (December 2024) are noted in the text´ – only whole requirements that have been removed are highlighted. There are other minor changes (word/phrase additions and removals) that have also been made and that are not highlighted.

With the first submission deadline of October fast approaching many organisations will already have started their assessments. These will now need to be revisited. Read the Recyclability Assessment Methodology v1.1.

If your organisation is obligated to undertake these recyclability assessments, let us take the pain out of keeping up-to-date with all these changes. Our bespoke tools keep on top of everything for you.

Visit our Recyclability Assessment Tool page for further information on our Tool or Contact us for a demo of our simple to use Recyclability Assessment Tool.

Recyclability Assessments – Everything You Need to Know

The UK Government´s Extended Producer Responsibility (EPR) regulations for packaging have introduced a requirement that from 1/1/25 Large Producers (those with a turnover of > £2 million and which supply more than 50T of packaging per annum) must conduct Recyclability Assessments for all packaging that becomes Household Packaging and report these assessments by 1/10/25.

The aim of the requirements is to shift the cost of managing packaging waste from the taxpayer to the producer and to make producers responsible for the full lifecycle of their packaging, from design through to end-of-life disposal or recycling.

How to do Recyclability Assessments for the Regulations?

The Recyclability Assessments must follow the specific Gov.uk Recyclability Assessment Methodology (RAM). The methodology requires that each packaging component is assessed through the life cycle stages of classification, collection, sortation, reprocessing and application and will be assigned a Red, Amber or Green rating. These ratings will be applied to the EPR fees to be paid by the producer, therefore encouraging producers to improve the recyclability of their packaging.

  • Red: means the item is challenging to recycle, often due to problematic materials or designs.
  • Amber: means the item is recyclable but may need specialised collection or reprocessing.
  • Green: means the item is widely recyclable within the UK’s current systems.

The RAM is complex and requires in depth knowledge of your packaging components, the materials used within them, their design and detailed specifications from your suppliers.

Need Help with Your Recyclability Assessments?

Watch our brief video on An Introduction to Extended Producer Responsibility and Recyclability Assessments

Watch our brief video on How to Define Household Packaging

Watch our brief video on How to Determine Packaging Components and Material Types

With our bespoke tools we can help you to: brief your teams on what is required; understand the guidance; follow the RAM; complete the Recyclability Assessments for all your components; and report to meet your compliance deadlines with Certitude.

Visit our Recyclability Assessment Tool page for further information on our Tool or Contact us for a demo of our simple to use Recyclability Assessment Tool.