How One Producer Saved £340k by Switching from Red to Green Packaging

When FreshPack Foods received their first EPR fee estimate in early 2025, the number stopped the room cold. Their projected annual packaging fees came in at £612,000 -- nearly four times what the finance team had budgeted. Three of their highest-volume product lines had been assessed as Red under the Recyclability Assessment Methodology (RAM), and with fee modulation set to escalate year-on-year, the picture was only going to get worse.

Twelve months later, those same three product lines carry Green RAM ratings. FreshPack's projected annual fees have dropped to £272,000. That is a saving of £340,000 per year -- and the gap will widen further as the modulation factor increases to 2.0x by 2028-29.

This is the story of how they did it.

The Company: FreshPack Foods

FreshPack Foods is a mid-market UK food producer based in the Midlands, turning over approximately £45 million per year. They supply ready meals, chilled snacks, and meal kits to three of the Big Four supermarkets, along with a growing direct-to-consumer channel. As a large obligated producer under the UK's Extended Producer Responsibility (EPR) scheme -- exceeding both the £2 million turnover and 50-tonne packaging thresholds -- they are required to report packaging data twice a year and pay fees based on their RAM ratings.

Their packaging portfolio spans roughly 2,400 SKUs and over 8,000 individual packaging components. Before the audit, nobody at FreshPack had a clear picture of what those components were actually costing them in EPR terms.

The Problem: Three Red-Rated Product Lines

When FreshPack onboarded to Repackd in March 2025, the platform's RAM scoring engine identified that three product lines accounted for a disproportionate share of their total fee liability. All three had been assessed as Red -- meaning they failed key stages of the RAM's five-stage assessment (Classification, Collection, Sortation, Reprocessing, and Application).

The three offending lines were:

Together, these three lines represented approximately 480 tonnes of packaging per year. At the Red fee rate -- which starts at 1.2x the base rate in 2026-27 and rises to 2.0x by 2028-29 -- the financial impact was severe.

The Audit: Understanding What Was Going Wrong

The first step was a granular component-level analysis. Using Repackd's data ingestion tools, FreshPack uploaded their existing packaging specifications, supplier datasheets, and technical drawings. The platform extracted material composition, weight, and structural data for every component across the three product lines.

The analysis revealed several recurring problems that were dragging their RAM scores into Red territory:

1. Carbon Black Pigment in CPET Trays

FreshPack's ready meal trays used carbon black-pigmented CPET (crystallised polyethylene terephthalate). While CPET is technically recyclable, the carbon black pigment absorbs near-infrared light, making the trays invisible to optical sorting equipment at Material Recovery Facilities (MRFs). Under the RAM, this fails at the Sortation stage. The trays are classified as non-recyclable in practice, regardless of the base material's theoretical recyclability.

2. Multi-Layer Lidding Films

The ready meal lidding used a PET/PE/EVOH multi-layer structure. While this provided excellent barrier properties for shelf life, the non-separable layers meant the film could not be recycled through any existing UK reprocessing stream. It failed at both the Reprocessing and Application stages of the RAM.

3. PVC Sleeve Labels

PVC labels contaminate PET recycling streams. Even small amounts of PVC cause significant problems during reprocessing, introducing chlorine and degrading the quality of recycled PET. The RAM specifically penalises PVC labels, and they contributed to the Red rating on both the ready meal and snack pot lines.

4. Non-Separable Mixed Materials

The snack pot design combined a polypropylene (PP) body with a polystyrene (PS) lid that was heat-sealed in a way that made separation by consumers essentially impossible. Since PP and PS have different densities and require different reprocessing streams, a combined item fails at the Sortation stage.

5. PE-Coated Card in Meal Kits

The meal kit boxes used card that was PE-laminated for moisture resistance. This contaminated the paper recycling stream. The PE window inserts further complicated recyclability. Under the RAM, these multi-material constructions fail unless the materials can be easily separated by consumers or mechanically at scale.

The Redesign: Specific Changes Made

FreshPack worked with their packaging suppliers over a four-month period to implement targeted changes. The key principle: make the minimum changes necessary to move each component from Red to Green, whilst maintaining product performance and shelf life. Here is what changed for each line.

Classic Ready Meals

The move from carbon black to a detectable dark-green pigment was the single highest-impact change. The detectable pigment uses organic colourants that reflect near-infrared light, allowing MRF sorting equipment to correctly identify and route the material. Visually, the tray appears similar enough that consumer perception was unaffected -- FreshPack's consumer panel confirmed no negative response to the colour shift.

Switching the lidding film from multi-layer to mono-PET required reformulation of the peelable seal layer, but FreshPack's supplier had already developed a solution for another client. The shelf life impact was a reduction from 14 days to 12 days, which FreshPack mitigated through adjustments to their chilled distribution schedule.

Snack Pots

The most impactful change here was redesigning the lid mechanism. The original heat-sealed PS lid could not realistically be separated by consumers, meaning the entire pot was treated as a mixed-material item in the RAM. The new snap-fit PP lid is the same polymer as the pot body, and even if consumers do not separate it, the item remains mono-PP.

Removing the metalised barrier layer was technically challenging. FreshPack's supplier introduced an in-mould barrier coating that provides equivalent moisture and oxygen protection without adding a separate material layer. This was the most expensive single change across all three product lines, adding approximately £0.008 per unit to the packaging cost.

Meal Kit Boxes

Removing the PE lamination and window from the outer box was straightforward once FreshPack accepted the trade-off: consumers could no longer see the product through the packaging. Consumer testing showed that high-quality printed imagery on the uncoated card was actually preferred by 62% of the test panel over the window design.

The Numbers: Before and After

Here is the full financial picture across the three product lines, based on projected EPR fees at the 2028-29 modulation rate of 2.0x for Red packaging:

The Implementation Cost

Packaging redesign is not free. FreshPack incurred the following costs during the transition:

The net position is clear: a £138,000 investment in Year 1 that pays back within five months. From Year 2 onwards, the net annual benefit is approximately £298,550 (£339,550 fee saving minus £41,000 ongoing material cost increase).

Lessons Learned

FreshPack's journey highlights several principles that apply broadly to any producer looking to optimise their RAM ratings:

1. Start with data, not assumptions. Before the audit, FreshPack's sustainability team assumed their meal kit boxes were the biggest problem. In reality, the ready meal trays -- because of their higher volume and the particularly harsh penalty for carbon black pigment -- accounted for 59% of the total fee liability. Without component-level data, you are guessing.

2. Not all Red ratings require a complete redesign. The ready meal tray change was essentially a pigment swap. The base material, dimensions, weight, and manufacturing process remained identical. Sometimes one targeted change is enough to flip a Red to Green.

3. Suppliers are often ahead of you. FreshPack found that their suppliers had already developed Green-compliant alternatives for other clients. The mono-PET lidding film, the detectable pigment, and the in-mould barrier coating all existed in their suppliers' catalogues. The barrier was not technology -- it was that nobody had asked.

4. The fee multiplier makes small changes worthwhile. At a 2.0x multiplier, even modest tonnage reductions or rating improvements have an outsized financial impact. The difference between Red (2.0x) and Green (0.5x) is a 4x cost differential. That ratio makes packaging changes economically justified that would never have been worth doing under the old flat-fee system.

5. Consumer impact is often smaller than feared. FreshPack ran two consumer panels and found that the visual changes (darker green trays instead of black, no window on meal kits) had neutral-to-positive reception. In some categories, consumers actually preferred the redesigned packaging because it looked more environmentally conscious.

"We expected pushback from our retail customers on the visual changes. Instead, two of our three supermarket partners asked us to accelerate the rollout because it aligned with their own sustainability commitments. The Green RAM rating became a selling point, not a compromise."

-- Head of Packaging, FreshPack Foods

What Comes Next

FreshPack is now using Repackd's fee optimisation engine to assess their remaining 2,400 SKUs. The platform's "What If" simulator allows them to model material changes across their entire portfolio and see the projected fee impact before committing to any physical changes. Early analysis suggests an additional £120,000 in annual savings is achievable by addressing a further twelve Amber-rated product lines.

With fee modulation escalating each year through 2028-29, the financial incentive to move packaging from Red and Amber to Green will only grow. Producers who act now will lock in savings that compound over time. Those who wait will face progressively higher fees -- and progressively more urgent redesign timelines.