Packaging Compliance Glossary

A code used in the DEFRA RPD file to identify the specific way a producer interacts with packaging. Activity codes include brand owner, packer/filler, importer, seller, online marketplace, and distributor. The activity code determines the share of EPR obligation a producer carries for each packaging item they report.

A material category under the DEFRA RPD file covering aluminium cans, trays, foil, and aerosol containers. Aluminium is one of the most widely recycled packaging materials in the UK and typically achieves a Green RAM rating when used without mixed-material components or heavy coatings.

One of three possible outcomes in a RAM assessment. An Amber rating means the packaging is partially recyclable through UK infrastructure but faces barriers at one or more assessment stages. Amber-rated packaging incurs moderate fee modulation, paying between 1.0x and 1.5x the base EPR fee rate depending on the year.

The fifth and final stage of the RAM assessment. The Application stage evaluates whether there is sufficient end-market demand for the recycled material output. Even if packaging can be collected, sorted, and reprocessed, it fails this stage if there is no viable market for the recycled material.

A documented record of all compliance decisions, data submissions, and packaging assessments that demonstrates how an organisation met its EPR obligations. DEFRA and the Environment Agency may request audit trail evidence during compliance checks. Maintaining a clear audit trail is essential for avoiding penalties.

The standard per-tonne rate charged under EPR before any modulation adjustments are applied. The base fee varies by material category and covers the cost of collection, sorting, and recycling packaging waste. Fee modulation multipliers are applied on top of this base fee according to the packaging's RAM rating.

Packaging designed to break down through biological processes. Under UK EPR, biodegradable packaging is still subject to reporting obligations and often receives an Amber or Red RAM rating because UK recycling infrastructure is not designed to process it at scale. Compostable packaging faces similar challenges in the current system.

An organisation that puts its brand or trademark on packaging and places it on the UK market. Brand owners carry the primary EPR obligation for their packaging and must report all primary, secondary, and tertiary packaging associated with their branded products. This is the most common activity code in RPD submissions.

A collection point, typically located at supermarkets or car parks, where consumers can deposit specific types of recyclable packaging such as glass bottles, textiles, or plastics not collected kerbside. Bring banks are considered in the Collection stage of the RAM assessment as an alternative to kerbside collection.

A pigment used in dark-coloured plastic packaging (such as ready-meal trays) that makes the packaging undetectable by NIR sorting equipment at material recovery facilities. Carbon black packaging typically receives a Red RAM rating because it cannot be sorted for recycling. Alternatives include detectable dark pigments.

The first stage of the RAM assessment. Classification identifies the material type and packaging format, mapping each item to a specific material and subtype. Correct classification is essential because it determines which pathway the packaging follows through the remaining four RAM stages.

The network of kerbside collections, bring banks, and other recovery systems used to gather packaging waste from households and businesses across the UK. Under EPR, producers collectively fund the full net cost of collection infrastructure. The Collection stage of RAM assesses whether packaging is accepted by these systems.

The second stage of the RAM assessment. It evaluates whether the packaging material is accepted for collection through kerbside schemes or bring-bank systems. Packaging that is not collected at all, such as certain flexible films, will fail at this stage and receive a Red rating.

An approved organisation that manages EPR obligations on behalf of obligated producers. Compliance schemes handle data submission, fee payments, and evidence purchasing in exchange for membership fees. Under pEPR, the Scheme Administrator (SA) role replaces the previous compliance scheme structure for collecting packaging waste fees.

The 15-column comma-separated values file format required by DEFRA for packaging data submissions. Each row represents one combination of packaging activity, type, class, material, and nation. Columns include organisation ID, subsidiary ID, organisation size, submission period, packaging activity, packaging type, packaging class, material, material subtype, from country, to country, weight in kg, units, transitional units, and RAM RAG rating.

The UK government department responsible for designing and enforcing packaging EPR regulations. DEFRA sets the rules for data reporting, fee structures, and compliance timelines. They work alongside the Environment Agency, Natural Resources Wales, SEPA, and NIEA to enforce compliance across England, Wales, Scotland, and Northern Ireland.

The minimum level of packaging handling below which an organisation is not obligated under EPR. Currently, the de minimis thresholds are: turnover exceeding £1 million (small producers) or £2 million (large producers), AND handling more than 25 tonnes (small) or 50 tonnes (large) of packaging per year.

Any single-use container used for beverages, including plastic bottles, glass bottles, cans, and cartons. Drinks containers have additional reporting requirements under EPR, including a mandatory units count in the RPD file. They may also fall under the Deposit Return Scheme (DRS) where implemented.

A system where consumers pay a small deposit on drinks containers at the point of sale, which is refunded when the container is returned for recycling. Scotland launched its DRS in 2025, and the rest of the UK is developing parallel schemes. DRS containers have distinct reporting requirements within the EPR framework.

The downstream buyers and applications for recycled material output. In the RAM assessment, the Application stage checks whether there is sufficient demand and viable end markets for the reprocessed material. A packaging material that can be collected and sorted but has no end-market demand will still fail the RAM assessment.

The regulator responsible for enforcing packaging EPR compliance in England. The EA has powers to issue civil penalties of up to £100,000 for non-compliance, and criminal prosecution for persistent offenders. Equivalent bodies operate in Wales (NRW), Scotland (SEPA), and Northern Ireland (NIEA).

A UK-wide regulatory scheme requiring producers who place packaging on the market to cover the full cost of managing that packaging once it becomes waste. This includes collection, sorting, recycling, and disposal costs. The revised scheme (pEPR) began in April 2025, replacing the previous PRN/PERN system where producers paid only a fraction of end-of-life costs.

Under the previous packaging regulations, Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) served as proof that packaging waste had been recycled or exported for recycling. While pEPR transitions to a new fee-based model, PRNs/PERNs continue to operate in a transitional capacity alongside the new system.

The mechanism by which EPR fees are adjusted based on packaging recyclability. Packaging with a Green RAM rating pays the lowest fees, Amber-rated packaging pays a moderate premium, and Red-rated packaging pays the highest fees. Modulation multipliers increase over time: by 2028-2029, Red-rated packaging will cost up to 2.0x the base rate.

A packaging material that combines paper or cardboard with other materials such as plastic linings or aluminium foil (e.g. drinks cartons, coffee cups). Fibre-based composites are a specific material subtype in the RPD file and often receive Amber RAM ratings because the mixed materials complicate recycling.

Thin, pliable plastic packaging such as films, wraps, bags, and pouches. Flexible plastics are one of the most challenging packaging types for UK recycling infrastructure. Many flexible plastics currently receive Red or Amber RAM ratings because kerbside collection and sortation for flexibles is not yet widespread.

A material category covering bottles, jars, and other glass containers. Glass has well-established recycling infrastructure in the UK and is infinitely recyclable without loss of quality. Standard glass packaging typically achieves a Green RAM rating, though coloured or coated glass may face additional assessment considerations.

The best possible outcome in a RAM assessment, indicating that packaging is fully recyclable through existing UK infrastructure. Green-rated packaging passes all five RAM stages and benefits from the lowest EPR fee rates. Common Green-rated materials include clear PET bottles, aluminium cans, and standard glass bottles.

In the context of EPR, to "handle" packaging means to perform any obligated activity including manufacturing, filling, importing, branding, or selling packaged goods. The amount of packaging an organisation handles (measured in tonnes) determines whether it meets the tonnage threshold for EPR obligations.

Packaging that ends up in household waste streams, typically from consumer goods purchased at retail. Household packaging is a key packaging type in the RPD file and faces the full weight of EPR fees because local authorities bear the collection and disposal costs. It is distinct from non-household (commercial/industrial) packaging.

A rigid plastic polymer commonly used for milk bottles, detergent bottles, and household product containers. HDPE is one of the most widely recycled plastics in the UK with well-established collection and reprocessing infrastructure. Natural (uncoloured) HDPE bottles typically achieve a Green RAM rating.

An organisation that brings packaged goods into the UK from outside the country. Importers carry EPR obligations for the packaging on products they import, using the "importer" activity code in their RPD submissions. The "from country" and "to country" columns in the RPD file are used to track imported packaging flows.

The fee paid by obligated producers to fund local authority packaging waste collection infrastructure. Under pEPR, these payments replace the previous system and are calculated based on the type, weight, and recyclability of packaging placed on the market. The Scheme Administrator distributes payments to local authorities.

The doorstep collection of recyclable packaging waste by local authorities. In the RAM Collection stage, whether packaging is accepted for kerbside collection is a primary criterion. The UK's Simpler Recycling reforms aim to standardise kerbside collection across all local authorities by requiring a consistent set of recyclable materials.

Under EPR regulations, producers will be required to display standardised recyclability labels on packaging indicating whether it is recyclable. Labels must align with RAM ratings and OPRL guidance. Mandatory labelling requirements are being phased in alongside the broader EPR scheme.

An obligated organisation with annual turnover exceeding £2 million AND handling more than 50 tonnes of packaging per year. Large producers have the most extensive reporting requirements, including bi-annual data submissions (H1 and H2) and mandatory RAM ratings for every packaging item.

A council or local government body responsible for collecting household waste and recyclables. Under pEPR, local authorities receive infrastructure payments from the Scheme Administrator funded by producer fees. These payments cover the net cost of collecting and managing packaging waste from households.

The primary classification of packaging material in both the RPD file and RAM assessment. Material categories include plastic, glass, aluminium, steel, paper/card, wood, and fibre-based composite. Each category has distinct RAM assessment pathways, fee rates, and recyclability profiles.

A more specific classification within a material category. For example, within "plastic," subtypes include PET, HDPE, PP, PS, PVC, and others. The material subtype field in the RPD file provides DEFRA with granular data about the exact composition of packaging being placed on the UK market.

Short for fee modulation, the process of adjusting EPR fees based on packaging recyclability. Modulation creates a financial incentive for producers to improve packaging design: easier-to-recycle packaging costs less, while hard-to-recycle packaging costs more. Modulation multipliers are being phased in gradually from 2025 to 2029.

A facility where mixed recyclable waste is sorted into individual material streams using a combination of manual and automated processes including NIR (near-infrared) sensors, eddy current separators, and screens. The Sortation stage of RAM assesses whether packaging can be correctly identified and separated at MRFs.

Packaging composed of two or more different materials that are not easily separable, such as laminated pouches or blister packs. Multi-material packaging often receives Amber or Red RAM ratings because the combined materials complicate sorting and reprocessing. Designing for mono-material solutions is a key strategy for improving RAM ratings.

The "from country" and "to country" columns in the DEFRA RPD file that track the geographical flow of packaging. These fields record where packaging originates (e.g., imported from France) and where it is placed on the market (e.g., England, Scotland, Wales, or Northern Ireland). Nation data is used to allocate fees across UK jurisdictions.

An automated sorting technology used in MRFs that identifies materials by reflecting infrared light off packaging surfaces. NIR is critical to the RAM Sortation stage. Packaging that interferes with NIR detection, such as carbon black plastics, opaque sleeves over bottles, or heavily contaminated items, may fail the sortation assessment.

Packaging that enters commercial, industrial, or institutional waste streams rather than household bins. Examples include bulk containers, industrial wrapping, and catering packaging. Non-household packaging has different fee structures under EPR and is reported separately in the RPD file using the "non-household" packaging type.

Any organisation that meets the turnover and tonnage thresholds and performs an obligated packaging activity (brand owner, packer/filler, importer, seller, online marketplace, or distributor). Obligated producers must register with DEFRA, submit packaging data, and pay EPR fees. There are approximately 10,000 obligated producers in the UK.

A digital platform that facilitates the sale of packaged goods from third-party sellers to UK consumers. Under EPR, online marketplaces carry specific obligations for packaging on products sold through their platforms by overseas sellers, ensuring these goods are not exempt from UK packaging regulations.

An independent not-for-profit organisation that provides evidence-based recycling labels for UK packaging. OPRL works closely with WRAP and developed the RAM methodology. OPRL's labels (Recycle, Don't Recycle, Recycle at a larger store) help consumers dispose of packaging correctly and align with RAM ratings.

The specific role a producer plays in relation to packaging. The DEFRA RPD file requires an activity code for each packaging item: brand owner, packer/filler, importer, seller of empty packaging, hirer/loaner, or online marketplace. Different activities carry different levels of EPR obligation.

The functional classification of packaging within a supply chain. There are three classes: primary (sales packaging in direct contact with the product), secondary (grouped packaging for retail display), and tertiary (transport packaging for shipping). Each class is reported separately in the RPD file and may have different fee implications.

In the RPD file, packaging type distinguishes between household and non-household packaging. Household packaging ends up in consumer waste streams and is subject to full EPR fees covering local authority collection costs. Non-household packaging enters commercial/industrial waste streams and has a different fee structure.

An organisation that fills or packs products into packaging. This is a distinct activity code in the RPD file. Contract packers who fill packaging on behalf of brand owners may share EPR obligations depending on the contractual arrangement and whether the brand owner or packer holds the primary obligation.

The specific UK implementation of Extended Producer Responsibility for packaging, often styled as "pEPR" to distinguish it from EPR schemes in other sectors. pEPR launched in April 2025 and requires producers to fund the full net cost of managing household packaging waste, replacing the previous PRN system with direct fee payments.

A widely used plastic polymer for bottles, trays, and thermoformed packaging. Clear PET bottles are among the most recyclable plastic packaging formats in the UK, with well-established collection, sortation, and reprocessing infrastructure. Clear PET bottles typically achieve a Green RAM rating.

The innermost packaging layer that is in direct contact with the product and is typically what the consumer takes home. Examples include a drinks bottle, a crisp packet, or a shampoo container. Primary packaging makes up the majority of household packaging waste and carries the highest EPR fee weighting.

Any organisation that performs an obligated packaging activity and meets the threshold requirements. In the EPR context, "producer" is a broad legal term covering brand owners, importers, packers/fillers, sellers, and distributors. All producers must register, report data, and pay fees according to their activity type and organisational size.

A standardised 5-stage methodology developed by OPRL and WRAP for assessing the recyclability of packaging in the UK. RAM evaluates packaging across Classification, Collection, Sortation, Reprocessing, and Application stages and assigns a Red, Amber, or Green rating. RAM ratings are mandatory for large producers and directly determine fee modulation under EPR.

The colour-coded outcome of a RAM assessment. Red means the packaging is not recyclable, Amber means partially recyclable, and Green means fully recyclable. The RAG rating is the final column in the DEFRA RPD file and is the primary driver of fee modulation under EPR.

The worst possible outcome in a RAM assessment, indicating that packaging is not recyclable through existing UK infrastructure. Red-rated packaging fails at one or more RAM stages and incurs the highest EPR fee multipliers, reaching up to 2.0x the base rate by 2028-2029. Common Red-rated items include carbon black plastics, multi-layer pouches, and PVC packaging.

The fourth stage of the RAM assessment. Reprocessing evaluates whether UK reprocessors can recycle the sorted material at commercial scale. Even if packaging is collected and sorted, it fails this stage if there are no reprocessing facilities equipped to handle it. Capacity constraints and contamination tolerance are key factors.

The official 15-column CSV file format required by DEFRA for submitting packaging data under EPR. RPD files contain details of every packaging item a producer places on the market, including material, weight, activity code, packaging class, nation data, and RAM rating. Large producers submit RPD files bi-annually (H1 and H2).

The central body appointed to manage the operational aspects of pEPR. The Scheme Administrator collects fees from producers, distributes payments to local authorities, and manages the flow of funds for household packaging waste management. This replaces the previous system of multiple competing compliance schemes.

The middle layer of packaging used to group multiple primary packages together, often for retail display or ease of handling. Examples include cardboard multi-pack sleeves, shrink wrap around a pack of bottles, and display boxes. Secondary packaging is reported separately from primary and tertiary packaging in the RPD file.

A UK government policy requiring all local authorities in England to collect a consistent set of recyclable materials from households and businesses. Simpler Recycling is being rolled out alongside EPR to standardise collection infrastructure, which will improve the consistency and accuracy of RAM assessments over time.

An obligated organisation with annual turnover exceeding £1 million AND handling more than 25 tonnes of packaging per year, but below the large producer thresholds. Small producers have reduced reporting requirements: annual submissions instead of bi-annual, and no mandatory RAM ratings in the initial phase of pEPR.

The third stage of the RAM assessment. Sortation evaluates whether material recovery facilities (MRFs) can identify and separate the packaging into a clean material stream. Factors include NIR detectability, physical size (items under 40mm may fall through screens), and the presence of contaminants such as labels or adhesives.

A material category covering steel cans, tins, and containers. Steel is magnetically separable at MRFs, making it one of the easiest materials to sort. Steel packaging has well-established recycling infrastructure and typically receives a Green RAM rating. It is reported as a separate material category in the RPD file.

The time window covered by a packaging data submission. Large producers report in two half-year periods: H1 (January to June) and H2 (July to December). Small producers submit annually. The submission period is a required column in the RPD file and determines which deadline applies for each data submission.

The outermost packaging layer used for transport and logistics, such as pallets, stretch wrap, and shipping containers. Tertiary packaging is typically classified as non-household because it is removed before products reach the consumer. It is reported as a separate packaging class in the RPD file.

The financial and physical criteria that determine whether an organisation is obligated under EPR. Thresholds are based on two measures: annual turnover (£1M for small producers, £2M for large) and annual packaging handled (25 tonnes for small, 50 tonnes for large). Both conditions must be met for obligation to apply.

The weight of packaging measured in metric tonnes (1,000 kg). Tonnage is used to determine EPR obligation thresholds, calculate fees, and report packaging data. The RPD file records individual item weights in kilograms, which are aggregated into tonnage figures for fee calculations and threshold assessments.

Packaging used specifically for the safe transportation of goods between facilities, warehouses, and retail locations. Transit packaging overlaps with tertiary packaging and includes pallets, void fill, edge protectors, and pallet wrap. It is subject to EPR obligations and must be reported in the RPD file.

The minimum annual revenue an organisation must generate to be obligated under EPR. The turnover threshold is £1 million for small producers and £2 million for large producers. Turnover is assessed based on the organisation's most recent complete financial year. Groups of companies may need to aggregate turnover across subsidiaries.

A framework ranking waste management options in order of environmental preference: prevention, reuse, recycling, recovery, and disposal. EPR and RAM are designed to push packaging up the waste hierarchy by financially penalising hard-to-recycle packaging and incentivising recyclable and reusable alternatives.

A material category covering pallets, crates, boxes, and other wood-based packaging. Wood is primarily used as tertiary/transit packaging and enters commercial waste streams. Wood packaging is reported as a separate material in the RPD file and has its own RAM assessment pathway and base fee rate.

A UK charity that works with governments, businesses, and communities to improve resource efficiency and reduce waste. WRAP co-developed the RAM methodology with OPRL and publishes the technical guidance used for recyclability assessments. WRAP also manages the Courtauld Commitment and the UK Plastics Pact.