For UK foodservice packaging, “made from paper” is no longer enough information for a recyclability assessment. Under the UK Recyclability Assessment Methodology for 2027, the result can depend on coating weight, total non-paper content, whether components are separable and whether the pack is designed for food to be heated inside it.
These details can move a packaging SKU from Green to Amber or Red. Because RAM ratings are used to modulate household packaging waste disposal fees under extended producer responsibility for packaging, design decisions made at the specification stage can affect downstream compliance cost as well as product performance.
This guide focuses on paper cups and lids, coated kraft boxes and other paper food containers. It is intended as a procurement and design-screening tool, not a substitute for a producer’s own legal assessment.
RAM 2027 in five points
- It applies to the 2027 reporting year, from 1 January to 31 December 2027.
- Large obligated producers must assess relevant household packaging and packaging that commonly ends up in public bins.
- Packaging is classified first, then assessed through collection, sortation, reprocessing and application.
- A Red result at any stage makes the final rating Red. Missing evidence also leads to a Red result.
- The commercial question is SKU-specific: material names and general supplier declarations are not sufficient.
What Is RAM 2027 and Who Must Use It?
RAM is the method used under UK packaging EPR to assess whether packaging can move through the recycling system in practice. It does not look only at whether a material is technically recyclable. It assesses four operational stages: collection, sortation, reprocessing and application of the recovered material.
According to the official RAM 2027 overview, large producers must use the method for relevant packaging they supply during the 2027 calendar year. Under current EPR guidance, an organisation is classed as large when it has annual turnover of at least £2 million and is responsible for supplying or importing more than 50 tonnes of packaging in the UK. The liable party may be a brand owner, packer or filler, importer, online marketplace operator, reusable-packaging operator or supplier of empty packaging, depending on how the packaging enters the UK market.
For foodservice packaging, the scope question deserves particular attention. Cups, takeaway boxes and similar formats may become household packaging or packaging commonly discarded in public bins even when the immediate customer is a café, restaurant, distributor or catering business. The UK organisation responsible for the packaging should confirm both its producer role and the packaging type before applying RAM.
Why Paper Packaging Is Not Automatically Green
RAM 2027 requires every item or component to pass all relevant stages. A final Green rating requires Green at every stage. Green or Amber results at all stages produce a final Amber rating, while any Red result makes the final rating Red. If the producer cannot support an Amber or Green result with evidence, the packaging must be reported as Red.
This is why a paper claim, an FSC claim or a fibre percentage on a sales sheet cannot determine the RAM outcome. A kraft box may be collected with paper but still encounter a Red criterion during reprocessing. A cup may be predominantly paper by weight but fall into the fibre-based composite category because of its plastic coating. A box with a clear window may also need a different component assessment from a plain uncoated carton.
Paper or Board Versus Fibre-Based Composite
Classification comes before the Red, Amber or Green assessment. RAM 2027 states that paper or board packaging containing more than 5% plastic by mass must be assessed as fibre-based composite, or FBC. This threshold is specifically about plastic content. It should not be confused with the later 10% and 15% thresholds for total non-paper content.
| Question | RAM 2027 significance | Procurement evidence |
|---|---|---|
| Is plastic content more than 5% by mass? | If yes, paper or board packaging must be assessed as FBC. | Base paper GSM, coating GSM, number of coated sides and plastic mass percentage. |
| Is total non-paper content more than 10%? | This can trigger Amber during paper or board reprocessing or FBC non-liquid application. | Weight breakdown for coating, film, window, adhesive, ink and other integrated materials. |
| Is total non-paper content more than 15%? | This triggers Red for paper or board reprocessing and for FBC non-liquid collection. | A documented SKU calculation, not a general range for the product family. |
RAM defines paper content using the mass of specified non-separable paper elements, including wood-based cellulose fibre, fillers, papermaking additives, mineralised colour coatings and water. Barrier films, polymer coatings, windows and many other added materials therefore require separate identification in the calculation.
A simple GSM screening calculation
For a uniform coated sheet, GSM data can provide an initial screening calculation:
Plastic content by mass = plastic coating GSM ÷ total finished material GSM × 100
For example, a hypothetical structure using 250 GSM paperboard and an 18 GSM PE coating has a plastic share of approximately 6.7%. It would pass the 5% classification threshold and should therefore be assessed as FBC. A second hypothetical structure using 300 GSM paperboard and a 12 GSM plastic coating has a plastic share of approximately 3.8%, before adhesives, inks and other layers are considered.
These examples are screening calculations only. A finished cup or box may include seams, rim materials, glue, printing, windows or other components that change the SKU-level result. The producer must also decide whether each component is assessed separately or as part of an integrated item.
Why a Paper Cup May Receive a Direct Red Rating
RAM 2027 lists single-use beverage containers such as coffee cups as Red at the collection stage when they are assessed as FBC non-liquid cartons. This creates an important sequence for coated cups:
- Measure the plastic content of the finished cup structure.
- If plastic content is more than 5% by mass, classify the cup as FBC.
- Apply the FBC non-liquid criteria, including the format-specific Red criterion for single-use beverage containers.
The coating name alone does not answer the question. A single wall paper cup and a double wall paper cup may use different paper and coating weights, so their plastic percentages should be calculated separately. The cup lid may also be a separate component with its own material category and assessment.
Buyers should therefore avoid requesting a general statement that “all paper cups are recyclable under RAM.” The defensible request is a bill of materials and weight calculation for each cup SKU, followed by an assessment against the applicable format criteria.
The 10% and 15% Non-Paper Boundaries
For packaging that remains in the paper or board category, non-paper content greater than 10% by weight triggers Amber at the reprocessing stage. If non-paper content is greater than 15%, the result is Red at that stage.
For FBC non-liquid cartons, more than 15% non-paper content is Red at collection. More than 10% non-paper content is Amber at the application stage, provided no Red criterion has already been triggered.
| Total non-paper content | Paper or board pathway | FBC non-liquid pathway |
|---|---|---|
| 10% or less | No Amber or Red solely from this threshold. | No Amber or Red solely from this threshold, but format and contaminant criteria still apply. |
| More than 10% and up to 15% | Amber at reprocessing. | Amber at application. |
| More than 15% | Red at reprocessing. | Red at collection. |
The boundaries must be read together with classification. A paper pack containing more than 5% plastic is already directed to the FBC pathway, even if total non-paper content remains below 10%. Conversely, a paper or board item may contain non-paper material that is not plastic and remain in the paper or board category while still being affected by the 10% or 15% thresholds.
How Coatings, Films, Windows, Adhesives and Inks Affect the Assessment
Food packaging needs resistance to moisture, oil and heat, but those functions are often provided by non-paper materials. RAM 2027 makes the mass and chemistry of those materials relevant. Buyers comparing PE, PLA and aqueous barrier systems can review our earlier guide to PE, PLA and water-based coatings in paper food packaging, but RAM assessment still requires the finished SKU data.
| Design element | Why it matters | Information to request |
|---|---|---|
| PE or other plastic coating | Plastic content above 5% changes classification to FBC. Coating also contributes to total non-paper content. | Polymer type, coating GSM, coated sides and plastic percentage by mass. |
| PLA coating | A bio-based or compostable claim does not establish a Green RAM rating. Plastic content and the applicable material criteria still need assessment. | Exact polymer identity, coating weight, certification scope and finished-SKU composition. |
| Water-based barrier coating | “Water-based” describes the application system, not necessarily the dry coating composition or its RAM result. | Dry coat weight, polymer or binder chemistry, mineral content and recyclability evidence. |
| Transparent window | A plastic window adds non-paper mass and may be assessed as an integrated or separate component depending on its design and intended separation. | Film polymer, film weight, adhesive weight, dimensions and consumer separation instructions. |
| Adhesive or lamination | Adhesives add non-paper mass. Certain internal PET, metallised PET or PET-PE laminations are Amber, while specified PVC, PVDC and aluminium structures can be Red. | Adhesive chemistry, dry application weight, laminate structure, layer thickness and location. |
| Printing ink | RAM 2027 includes an automatic Red criterion where inks are not manufactured in compliance with the EuPIA raw-material selection and exclusion charter. | Ink system, supplier declaration, coverage assumptions and food-contact suitability where relevant. |
A component is not automatically “separate” simply because a consumer could tear it off. RAM asks whether it is distinct from the main body or needs to be separated to use the product and cannot be reassembled. Components not intended to be removed may be assessed as part of an integrated item using the predominant material by weight. The producer should document that decision rather than relying on an unsupported disposal icon.
This is especially important for kraft food boxes with a window. The paperboard, window film and adhesive need a weight and material breakdown. A plain version and a windowed version should not share one generic recyclability statement.
Why Heating Food Inside the Pack Can Trigger Red
RAM 2027 assigns Red at the reprocessing stage to both paper or board packaging and FBC non-liquid packaging when the item is designed for food to be heated within it. The stated reason is the likelihood of contamination when the packaging is discarded.
This criterion should not be confused with ordinary hot-food service. A kraft takeout box designed to receive already-hot food is not necessarily the same as a pack designed for microwave, oven or in-pack reheating. The product specification, instructions, symbols and marketing claims should all describe the same intended use.
If a SKU is sold as microwaveable or suitable for reheating food in the container, the buyer should flag it for Red assessment rather than treating heat resistance as a minor performance feature. If the intended use is hot-fill or hot-food holding only, the technical file should state that clearly and avoid contradictory heating instructions.
How Red, Amber and Green Affect EPR Disposal Fees
RAM ratings affect the household packaging waste disposal fee through fee modulation. Under PackUK’s current producer disposal fees modulation statement:
- Red: the household packaging waste disposal fee element is multiplied by the applicable Red modulation factor.
- Amber: the fee is not changed by modulation and acts as the base position.
- Green: the fee receives a discount funded by the additional amount raised from Red-rated material.
| Assessment year | Current Red modulation factor |
|---|---|
| 2026 to 2027 | 1.2 |
| 2027 to 2028 | 1.6 |
| 2028 to 2029 | 2.0 |
These are factors, not fixed packaging prices per tonne. Final modulated fees depend on the relevant disposal fee and reported market data. The Green discount cannot be confirmed in advance because it depends on the amount of Red premium available for redistribution and the volume of Green-rated material. The modulation years in the policy table should also not be treated as interchangeable with a RAM version or reporting year.
The legal fee is charged to the obligated producer, not automatically to the overseas packaging manufacturer. However, an importer may reflect the expected fee, assessment work and documentation risk in landed-cost comparisons. A slightly lower unit price can lose its advantage if a structure creates a Red rating or lacks evidence needed to support a better result.
SKU Information UK Importers Should Request from Suppliers
A useful RAM data pack should be specific to the SKU, structure and production specification. It should contain:
- Base paper GSM: paper or board grade and basis weight for every paper layer.
- Coating type and coating weight: chemistry, dry coat GSM, coated side and number of layers.
- Total non-paper content by weight: both grams per item and percentage of the finished item or assessed component.
- Component material breakdown: lids, windows, liners, films, sleeves, inserts and closures.
- Adhesive and printing ink information: chemistry, application weight and relevant supplier declarations.
- Food-contact compliance documents: documents matched to the actual material structure and intended conditions of use.
- Heating declaration: whether the pack is designed for microwave, oven or other in-pack heating, or only for hot fill and holding.
- Component separation instructions: how the consumer is expected to remove, reattach or dispose of each component.
- SKU-level packaging weight: the finished packaging item and each separately reported component.
- Recyclability assessment evidence: calculation sheets, test reports and supplier statements supporting the proposed classification and rating.
A supplier’s product-family brochure is not a replacement for this pack. A 12 oz cup and a 16 oz cup may have different paper and coating ratios. A paper to-go box with a PE barrier and the same box with a water-based barrier may follow different calculations. A plain kraft carton and a windowed carton must also be controlled as separate specifications.
Paper Packaging Design Review Checklist
- Confirm the obligated producer and packaging scope. Establish whether the SKU is household packaging, public-bin packaging or outside the RAM assessment scope.
- Map every component. Include the main body, lid, window, liner, sleeve, film, insert, adhesive and other attached parts.
- Decide whether components are separate or integrated. Record the reason using the RAM component rules.
- Calculate plastic content. If paper or board contains more than 5% plastic by mass, move to the FBC assessment pathway.
- Calculate total non-paper content. Check the 10% and 15% boundaries using finished-SKU data.
- Screen automatic Red criteria. Review food-contact compliance, restricted substances, PFAS information and ink declarations before the material-specific assessment.
- Check format-specific Red criteria. Pay particular attention to FBC single-use beverage containers and packaging designed for food to be heated inside it.
- Review barrier chemistry and construction. Check coatings, two-sided laminations, waxes, silicone, PVC, PVDC, aluminium and PET-based structures against the relevant criteria.
- Assess collection, sortation, reprocessing and application. Do not stop after confirming kerbside collection.
- Record the final rating and evidence. Keep the calculation, documents, test evidence and approval history under the SKU record.
A Practical Procurement Record for Each SKU
| Record field | Example entry | Control point |
|---|---|---|
| SKU and revision | KTB-750-PE, Rev. 03 | Do not combine structures under one SKU record. |
| Finished item weight | Supplier measurement in grams | State tolerance and measurement method. |
| Paper and non-paper mass | Grams and percentage | Recalculate after any material change. |
| RAM classification | Paper or board, or FBC non-liquid | Support with the plastic mass calculation. |
| Intended use | Hot food holding; not designed for in-pack heating | Align specification, artwork and sales claims. |
| Assessment outcome | Green, Amber or Red with date and approver | Reassess when design or official criteria change. |
RAM 2027 requires producers to retain evidence supporting their assessments for seven years and provide it to regulators if requested. Procurement files should therefore preserve the supplier version, calculation inputs and approval trail rather than overwriting an old specification when a coating, window or adhesive changes.
Design for Performance and Document for Assessment
Barrier performance still matters. A takeaway pack that leaks, collapses or contaminates food is not a successful redesign. The practical objective is to meet the required use conditions with the simplest defensible material structure and a complete evidence pack.
For buyers developing kraft food containers, this means defining the food type, temperature, oil level, holding time and heating instructions before selecting the coating and component structure. For cups, it means evaluating the paper and coating ratio for every size while recognising the specific FBC rule for single-use beverage containers.
RAM 2027 turns small specification details into commercial variables. Base paper GSM, coating weight, window construction and intended-use wording can affect classification, rating and EPR exposure. The strongest supplier file is therefore not the one with the most environmental logos; it is the one that allows the UK producer to reproduce the calculation and defend the result for each SKU.
Official Sources
- GOV.UK: Assess packaging recyclability, RAM 2027
- GOV.UK: RAM 2027 materials assessment guidance
- GOV.UK: RAM 2027 overview
- GOV.UK: PackUK producer disposal fees modulation statement
- GOV.UK: Who is affected by packaging EPR
Regulatory guidance and fee policy may be updated. Producers should check the current GOV.UK version when completing an assessment or preparing a data submission.
