Overview

Under the UK’s Extended Producer Responsibility (EPR) scheme, the Recyclability Assessment Methodology (RAM) assigns packaging a Red, Amber, or Green (RAG) rating. This rating determines the fees producers pay:

• Green: lower fee (easily recyclable)

• Amber: base fee (recyclable with limitations)

• Red: higher fee (poorly recyclable)

However, medical packaging is subject to special provisions under the Environment Agency’s guidance, recognising that regulatory requirements often limit material choices and affect recyclability.

How Medical Packaging Is Treated in RAM

1. Red Ratings for Medical Packaging
   Medical packaging may receive a Red rating because of unavoidable regulatory requirements (e.g. safety, sterility).

2. Amber-Medical Classification
   Where this is the case, the EA allows producers to report the item as Amber-Medical instead of Red.

3. Evidence Requirement
   Producers must retain supporting evidence to show that the Red rating is caused by regulatory requirements, not by design choice.

4. Fee Implications
   By reporting as Amber-Medical, the packaging will be charged at the base fee, the same as other Amber-rated packaging, rather than the higher Red fee.

Current Limitation in RAM Assess

The RAM Assess platform does not yet support this special provision for medical packaging.

• The system will display medical packaging as Red or Amber, without adjusting for Amber-Medical.

• This means users will need to identify medical packaging manually and apply the Amber-Medical classification outside the system for this submission period.

What You Need to Do

• Review your exported data to identify medical packaging items.

• Apply the Amber-Medical classification where appropriate, in line with EA guidance.

• Ensure you retain evidence demonstrating that the Red rating is due to regulatory requirements.

• Report these items manually for now, as the system will not adjust them automatically.

Looking Ahead

We will update RAM Assess to incorporate support for medical packaging in future releases. Until then, users are responsible for managing the Amber-Medical classification manually.

For further detail, you can review the Environment Agency’s RAM guidance on medical packaging.