0:04
Hello everyone, and welcome to today's webinar, which is on the Recyclability Assessment Methodology or RAM update, hosted by our professional affiliate members, Ecosurity.
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First of all, thank you to everyone for coming today.
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We hope that you found the content useful.
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There will be a Q &A at the end, so please put any questions that you have into the questions box and we'll do our best to go through as many as we can at the end of the webinar.
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Following the webinar, we'll be sending you an aftercare email in the next of working days and this will contain a recording of the webinar, a copy of the slides and the contact information of today's presenters.
0:38
So without any further ado, I will hand you over to today's presenter, Louisa Goodfellow.
0:44
Hi everyone and thank you for joining our second webinar on the RAM with FDF.
0:51
You'll probably be aware that since our last webinar, we now have the finalised version of the RAM methodology.
0:59
So we can go kind of into the specific material details and requirements without having to caveat that things might have changed, you know, they might change mid-year or anything.
1:09
So we do have the finalized version now, which is obviously good news.
1:15
By way of an agenda, so I'm gonna just do a recap on the context of the RAM and how it kind of should be applied to packaging.
1:26
I'll then pass over to Alison, our packaging sustainability specialist, who will cover the specific materials and any updates.
1:34
And then finally to Emma, who is one of our partnership managers, who will talk over kind of how we can help you with the new RAM requirements this year.
1:47
So context of the RAM, I'm just gonna cover off the basics now.
1:53
I'm aware that you will all be kind of familiar with this, but the local authority EPR disposal fees, They're starting this year, and the invoices will be raised in October.
2:06
Hopefully you'll get an indication of what they might be ahead of that, but they'll be formally raised in October.
2:12
Those invoices are just charged on the base fee per tonne of material, but then next year, so from 2026 onwards, those invoices and the fees will be modulated in terms of the packaging's recyclability.
2:27
So therefore packaging obviously needs to be assessed for its recyclability via the RAM so that it can be modulated next year.
2:37
So as an example packaging that's assigned as red for instance might be charged at around 1.2 times the base fee.
2:46
Amber likely will be charged at the flat base fee rate and then green packaging is kind of reduced in price accordingly.
2:53
We haven't had those on confirmed modulation factors or anything but it's just an example of what they might look like and those might be kind of the starting figures and then they'll likely increase on an annual basis.
3:05
So that's the purpose for why the RAM is being implemented this year.
3:12
So just to re-emphasize, this does mean that all household packaging placed on the market by large EPR producers from the 1st of January this year, they do need to be submitted, it does need to be submitted with the RAM assessment output.
3:29
The definition of household packaging when we say household packaging is inclusive as well of that kind of subset of household packaging which is commonly street binned.
3:38
So when we say household packaging would be both those packaging types in terms of what needs to be assessed against RAM.
3:46
So for the H1 2025 submission, yep, sorry, deadline in October, just out of myself, and I'm sure many of you will work with the compliance scheme.
3:57
So although the kind of the government deadline is October, for those of you that work with us, Ecosurity, our deadline will be earlier in July. So that's so we can process the data, verify the RAM, make sure it's all correct.
4:12
and if you work with another compliance scheme it is worth checking with them what their kind of deadline will be for the October submission because it will be earlier than that October deadline so all in not a huge amount of time really to get the data ready and prepared ahead of the formal government submission in October.
4:33
So let's just briefly recap on how the packaging reporting and the fee cycle works.
4:40
So the invoice that you'll be receiving soon from PAC UK, the scheme administrator that concerns packaging that you've placed on the market in 2024 and as I've mentioned that won't be modulated via the RAM but in the red boxes starting from next year that will be based on this year's packaging supplied data fees will be modulated according to the RAM ratings that you report now so this year's submission and the six, once the modulation kicks in. So that's the timelines.
5:20
Again, I know you will be more than aware of this, but the output of the RAM is a simple kind of red, amber, green or rag status.
5:29
And that's what needs to be reported with the rest of your EPR data.
5:33
But obviously, a lot of information kind of needs to be collected to essentially arrive at those ratings.
5:40
So green packaging clearly is widely recyclable, widely recycled formats.
5:46
And there might be issues at any stage of the recycling process.
5:50
And red are the formats that are kind of most difficult to reprocess or collect.
5:59
Very quick reminder then that there are three situations where household packaging is exempt from the RAM assessments.
6:08
So firstly, exported household packaging.
6:12
In fact, this wouldn't be reported your EPR submissions at all so clearly no need to assess for recyclability either.
6:21
Reused packaging as opposed to reusable packaging is also exempt it would be assessed when it's reported when it's first placed on the market but not on any kind of subsequent reuses of that packaging.
6:35
And then finally drinks containers in scope of the future DRS they're also exempt from RAM assessments which is a change from the previous version of the RAM that we had.
6:48
So to be very clear, these are PET plastic, steel or aluminium containers between 150 millilitres and 3 litres.
7:00
They are exempt from waste management fees ahead of DRS implementation, so they therefore again don't need to be assessed against the RAM in terms of their recyclability.
7:11
Glass bottles, as I'm sure you're all aware, are not in scope of the DRS in England, Wales and Northern Ireland as it stands, so they do need to be assessed against the RAM because they will be charged EPR fees this year.
7:32
So in terms of the overall responsibility for the RAM sits with the scheme administrator PAC UK, but the methodology will be reviewed and updated every year by this technical advisory committee that is currently being appointed.
7:51
So this is a slide just so you're aware that RAM isn't a fixed methodology unfortunately and we do expect that changes will be made most if not every year to the data that needs to be collected behind the methodology and it might change as the methodology itself improves because they've got more information or the UK recycling infrastructure kind of changes as well so just so you're aware we expect that there will be very regular changes to the methodology so that will keep us all on our toes.
8:27
So in terms of how the packaging or packaging components are assessed, so if a finished piece of packaging is made of two or more components, if those components are easily separated by hand, then they are assessed separately through the RAM.
8:43
If they aren't separable by hand, they are assessed through the RAM as one unit, and that's under the predominant material by weight.
8:51
So that's kind of the first rule when looking at how a piece of packaging is made up of several components needs to be assessed.
9:00
As an example, if we take a glass jar, so the paper label is obviously not easily separated kind of from the body of the jar by hand, but the lid is.
9:12
So this would mean two separate assessments are made, one for the glass jar and label and one for the metal lid.
9:19
However, there is a condition for undersized components within the methodology.
9:25
So if the lid is under this threshold, so it's smaller than 40 millimeters in at least two dimensions, but it can be reattached to the jar, which in this case it can, then the whole package is assessed as one component.
9:40
If it couldn't be reattached to the jar, so it's different kind of packaging, and it just doesn't be attached, then it would continue as a separate RAM assessment and because it's under the size threshold would likely receive a red rating.
9:54
So something to be aware of in terms of undersized components and whether or not they can be reattached to the original packaging.
10:05
Continuing with this example, so let's say the lid is not undersized, so two assessments are made for the lid, firstly, and the glass jar.
10:15
For the glass jar, glass is obviously the predominant material by weight.
10:20
So the whole thing, including the label, is assessed by the glass material stream.
10:26
If the glass jar achieves a green rating, which it likely would, then the secondary material, i.e. the paper label, inherits that green rating too.
10:37
So under the EPR made data submissions, the paper and the glass still kind of reported separately as normal, but because that paper label has inherited the green status from the glass jar, it's also recorded as green in the main EPR data submissions.
10:58
So it can be a bit confusing, but it's just important to go through the steps in terms of do you assess the package as a whole thing or do you assess individual components?
11:07
Hopefully that makes sense.
11:10
I'll just point out here that the the final version of the RAM that was published in April, a condition has been removed so under the previous version if there was a label covering over 60 percent of the surface of the glass jar for instance this would have triggered an amber rating but this is no longer the case for glass so no need to worry about that condition this year.
11:39
So again, as a reminder, there are a few instances where packaging will get an automatic red result.
11:46
So if any of these substances that you can see on the screen have been intentionally added, or if there's any integrated electrical components in the packaging, then you will have to report that packaging as red.
12:01
Note that another change from the previous version is that intentionally added PFAS to glass, steel or aluminium packaging no longer triggers an automatic red result either.
12:14
But for other types of packaging, plastic packaging for instance, that has got intentionally added PFAS, it would still trigger an automatic red result.
12:23
So that condition has just been removed for glass and metal packaging.
12:33
So just to finish up kind of before I hand over to Alison.
12:37
This is an overview of how the methodology is like it's split out essentially.
12:42
So you'll assess your packaging or components of packaging under the appropriate material stream.
12:48
And then the packaging will be assessed via these five stages of recycling.
12:53
So all the way from material classification and collection to reprocessing and how the output of that reprocessing can be applied.
13:06
And then finally, then so if a given piece of packaging achieves, for instance, a green status at collection, so is widely collected by local authorities, and also it doesn't kind of pose an issue at reprocessing facilities, but does encounter issues at sortation.
13:25
So it's therefore given a red rating for the sortation stage, then you must kind of, basically you must report that packaging as red.
13:32
So the highest result red being the highest must be the reported result essentially It obviously is we would recommend say if you kind of hit a red result at the collection stage or the sortation stage We would recommend continuing through the RAM So you know how your packaging behaves in the other stages of recycling But if you have hit a red then you must report that packaging as red Okay, so that's the kind of background and context, which I'm sure many of you were familiar with by now anyway.
14:04
I'm going to pass over to Alison, who's going to go into material specifics.
14:11
Thanks, Louisa.
14:11
Hi, everyone.
14:13
As Louisa said, I'm Alison.
14:14
I'm Packaging Sustainability Specialist as a part of the advisory team at eGosharedi.
14:19
And today, I'm just going to talk you through some of the changes to the RAM.
14:23
So the REM was initially published as a final version in December last year.
14:30
After that point, a significant engagement from industry with DEFRA and the Scheme Administrator PAC-UK highlighted that there were a few items that required simplification or that there were what DEFRA's referred to or PAC-UK's referred to as impossibilities.
14:49
So there were changes that were made and version 1.1 was published in April this year.
14:58
So what I'm going to do today is take you through each of the material types and just highlight the changes that were made.
15:05
I won't kind of talk through every single trigger that occurs for each material type.
15:09
If I did, we would be here for quite a while.
15:11
It is 7 ,000 words, the RAM.
15:14
So we'll just take you through the kind of key points to be aware of what's changed within your packaging.
15:19
So if we just go to the next slide please, Louisa.
15:22
Before I jump into the material types, just wanted to remind everyone, for those of you that attended the webinar that we did on the RAM earlier this year, paper and board and fibre-based composite.
15:37
The definition of how you should be defining your packaging is now dependent on plastic percentage by weight and this will now proceed the definition of fiber-based composite for EPR reporting as well.
15:52
So if your, I guess, fiber-based composite in a historical sense, material has less than 5% plastic by weight or equal to 5% by weight, then it can be assessed under the RAM as paper and board and also reported under EPR as paper and board.
16:12
But if it's more than 5% plastic by weight, then that would be as fiber-based composite and assessed under fiber-based composite as well for the RAM.
16:21
And there is a detail within the RAM itself with, I've got on the screen there, just an equation on how to determine what that percentage makeup is.
16:33
So if we just jump to the next slide please.
16:36
So jumping into paper and board, the lowest possible result that you can receive for paper and board is green, so it is possible to have a green outcome for your paper and board packaging component.
16:50
However, there are many instances where there could be a red or amber outcome.
16:56
So you can see there, for example, under sortation, small components, less than 40 millimetres in at least two dimensions would result in a red outcome.
17:05
That's because smaller items can fall through the tunnel screens within the MRFs or material recovery facilities.
17:13
There were a couple of changes that were made for paper and board in the latest version of the RAM.
17:19
So that included, if you just click once more please Louisa, the removal of residue impacting the outcome for packaging.
17:30
So previously it indicated that if there was hard to remove by hand residue of product remaining on the packaging, then it would be a red outcome.
17:41
that's now been removed and isn't in this version of the RAM.
17:45
And then also under the application stage there was removal of references to PA additives, ultraviolet, cured varnish and inks containing mineral oils.
17:56
Something that I do want to highlight before we jump onto the next material type is just to be aware that these particular triggers for these materials have been removed for version 1.1, but the reason we're highlighting these today is because one, so you're aware for the assessment for your first assessment for October, but also that, as Louisa mentioned earlier, the RAM will go through review and there'll be guidance provided by the technical advisory committee each year.
18:24
So there is a possibility that these things may be re-added in future. So it's still good to be aware of the types of things that may come back.
18:32
We don't have confirmation on if they definitely will and if so, when, but it is good to be aware of what was removed so that as you start to capture more information and more data on your packaging that you have this level of detail.
18:45
So if we just jump to the next slide please, fiber-based composite is separated into two within the RAM.
18:53
So first section is on liquid cartons and the second section is on non-liquid cartons.
18:59
The only element that was removed under the liquid cartons was a reference to residue. So we just click once more please.
19:07
This is under the reprocessing stage and sorry also the reference to PAE additives was removed at application as well.
19:16
This is again quite similar to the paper and board outcome.
19:21
For liquid cartons the kind of best result so the lowest result that you can achieve is amber unfortunately.
19:29
That is because the collection phase, as you can see there on the screen, it isn't possible to achieve a green rating at the collection stage, which means that amber is the lowest result that could appear within the assessment. We jump on to the next slide that will take us to non-liquid cartons.
19:52
The residue again was removed in this instance and these are the same conditions that were removed under the paper and board, reference PAE additives, ultraviolet varnishes and mineral oils within inks.
20:08
The non-liquid cartons can however receive a green outcome when completing the assessment unlike the liquid cartons. Moving on to the next material, flexible plastics.
20:22
At the moment The lowest result that can occur is AMBA and that is because of collection.
20:29
At the moment, collection for flexibles isn't available at kerbside everywhere.
20:33
There are trials, such as those with the FlexCollect program that's part of Iga Shiridi's work that we do in partnership with several brands, but at the moment that isn't at the scale necessary to meet the access to population thresholds that are a requirement for the stage within the RAM.
20:53
So in order to achieve an AMBA outcome there has to be a viable take-back scheme. So that is the best option at this stage.
21:02
The change for flexible plastics was in reference to carbon black.
21:07
So previously under the sortation phase there was an indication that if there was carbon black pigment in 50% of the surface area of the material contained carbon black then it be red.
21:22
This has now changed to where the carbon black is present within the master batch of the material. So that is quite a big change.
21:33
The reason for that is that carbon black can actually impact the near infrared scanners within the MRFs and material recovery facilities because it can't read what type of plastic it is.
21:47
So that's why that is a trigger that exists within the RAM.
21:52
And jumping onto the next slide, I think it's rigid plastics.
21:56
Here, we also see a change for carbon black pigments.
22:00
If we just do one more click, please.
22:04
This, again, changes from 50% surface area to just presence within the master batch.
22:09
So it's becoming a little bit, I guess, stricter in terms of presence.
22:12
But the ease of which you can determine where the carbon black is present is easier rather than trying to work out the surface area as well and that's in relation also to labels and sleeves sizes has been removed for rigid materials.
22:30
Rigid plastics is quite a large chunk of the RAM and that is because it is broken out into different sections for polymer type but also for format so there are specific conditions that are related to PET bottles, PET trays and then HDPE items and polypropylene items.
22:52
Currently, the only formats that are recognized for collection under the RAM are bottles and then pots, tubs and trays.
22:59
So it is possible to have green outcomes for rigid plastics but not all rigid plastics will necessarily have that outcome.
23:10
Some of the triggers that have been removed under the reprocessing stage for all of them is referenced to label adhesives and whether or not they're removable in 80 degree hot washes.
23:21
Specifically for PET bottles, references to nanocomposite additives.
23:26
PET trays relating to PE seal layers, and then HDPE looks at additives that impact density.
23:35
And then within the application phase, there is removal for all materials, and there's also clear call-outs within the polypropylene and HDPE about reference to paper labels and sleeves impacting the RAM outcome.
23:49
PET bottles, it was removed heavy colors.
23:53
There was significant comment from what does heavy, what is defined as heavy.
23:57
So that's been removed now.
23:59
And that was also present for polypropylene alongside also clarifier additives, which have been removed and PET light inserts.
24:09
If we jump to the next material, steel, I don't believe there's any changes to steel if we just click once more.
24:19
Steel and aluminium both remained the same between version 1 and version 1.1.
24:27
It is possible to have green outcomes and in many instances a lot of materials that are within steel and aluminium will likely be green.
24:34
However, there are conditions that do impact its recyclability in particular size.
24:41
So while some materials such as plastics and papers have reference to minimum size thresholds of 40 millimetres within at least two dimensions, for aluminium and steel it's actually the opposite so it's to do with how large an item is.
24:57
So, if a component exceeds 300 millimetres or 30 centimetres in any dimension, then it would be red unless it either has its own take-back scheme or it can be dismantled or folded to sit below that 300 millimetre outcome.
25:17
The other item that does impact recyclability and RAM outcome for aluminium and steel is to non-aluminium or non-steel content within the respective material type.
25:29
So if the component contains more than 30% non-aluminium or non-steel within it then that will result in an amber outcome for those items. Now next material, glass.
25:43
There was one major change to glass and that was in reference to labels.
25:48
So it has now removed reference to labels covering more than 60% total surface area.
25:56
Again, for many glass products, it is likely to be green, but there are still triggers again that can impact the outcome and it could result in red or amber.
26:07
So it is still important, I guess not to just assume that all glass and aluminum and all steel are going to be green.
26:14
There are still features that could impact its outcomes under the RAM.
26:19
And then last but not least we have wood and other materials. There were no changes here for either of those.
26:27
Unfortunately in both instances it is red no matter what because there isn't currently sortation reprocessing or applications at scale for these materials.
26:39
So for any wood packaging and any other packaging that is your primary material by weight, those will be read at this stage within the system.
26:50
I'll now pass over to Emma, who will talk through what EcoSurity is doing to help.
26:56
But if you do have any questions, please do pop them in the Q &A and we should have time to answer some questions for you, as Liz mentioned at the start of the webinar.
27:04
But thanks for me, over to you, Emma.
27:09
Hi, I'm Emma.
27:10
I am a partnerships manager here at EcoSurity and I'm just going to go over in a little bit more detail what products that we've developed.
27:20
So over the last couple of months, we've been working really hard developing products and resources, which we will make available to help our members successfully complete the RAM for the next submission.
27:29
I'm here today to walk you through our offering, make sure you're aware of all the help that's available from us and to guide our members.
27:37
Next slide, please.
27:41
So where to start?
27:42
This is the big question.
27:43
There is a huge amount of information required from producers to understand successfully complete the RAM.
27:49
There's no getting away from the fact that the RAM will require additional data collection beyond what you currently have and are used to providing, which will of course require internal action to ensure you're equipped with the correct data.
28:01
I think one of the most important takeaways from today is that it would not be acceptable to just apply a RAG status to a piece of packaging.
28:11
You will need to provide evidence of how you've reach that result for each component and then maintain that evidence on record, it is key that the assessment is made on each component that you place on the market or each component that is identical in format across a range of products.
28:29
However, if you are unable to carry out an assessment, it will lead to what we're now referring to as a default red output, As all these products will be red unless they can be proven otherwise.
28:43
With regards to when to start, the simple answer is to begin as soon as possible to make assessment of as many pieces as possible to avoid the outcome of getting a default red output, especially if that packaging could have been amber or green instead.
29:00
The RAM is going to be hard work for everyone, but you're not alone and we will do our best support our members and outside of our membership to give the best advice we can to make sure that everyone is as prepared and as well equipped as possible. Next slide please.
29:21
So our focus since the release of the RAM has been ensuring basically that we have as much information available to our members as possible.
29:33
Over the last few months we've worked hard to create a comprehensive collection of articles for our members on the hub.
29:40
These include FAQs to cover the basics, which is a great place to start to get a grounding and some much-needed answers.
29:49
Another area that we've focused on heavily is that we provide articles about making material-specific assessments.
29:58
These are really useful for businesses that place on market-specific material types or formats that perhaps need a more detailed assessment.
30:08
If Allison's whistle stop material tool has highlighted an area worth digging into, this would be an excellent resource, for example. Next slide.
30:19
This upcoming submission will be the first time that the RAM assessment will be applied to EPR submissions.
30:27
We hope that all the producers will be able to process the data gathering in advance and needing to submit both of their EPR data and in the same manner as before and obviously preparing the additional data points in order to provide a rag rating.
30:44
For our members, we've always offered a range of submission type based on what our members need.
30:51
For producers who don't place on market any household packaging waste, commonly street bin items or drinks containers that are excluded from the upcoming deposit return scheme, this will remain exactly the same as before because they're not going to need to carry out a RAM assessment.
31:07
However, for producers whose packaging does fall in scope of the EPR waste management fees and therefore the RAM, we have developed new submissions port levels which they will be transitioned onto.
31:20
I've got a quick covering of this here.
31:24
This outlines what will be included within this for the various levels of support.
31:29
Membership is going to remain the same with access to resources and account management as before, and what's outlined on the slide is just what we're now offering in addition to that.
31:41
So the basic level submission is a simple framework for companies that are very data confident, happy to provide finalised data.
31:49
For these members, we've given access to all of these I've just spoken about, and the RAM component checker.
31:56
That's something I'm gonna go into a bit more detail on in a minute.
32:00
Review level members have additional support around their methodology and data.
32:06
So in addition to the basic support resources, they also receive additional review of their calculations and RAM methodology.
32:15
Calculate members will continue to work with us collaboratively on their data with the support of the resources I've already mentioned, and then with Ecosurity consolidating their EPR and RAM data into a submission, and that's ensuring that we have additional support there where required.
32:32
And finally, our outsourced members who want the full package, full support for their submission, they will get access to all of our resources, the whole suite, and we will ensure that we work with them comprehensively on their data to complete a submission and RAM assessment.
32:49
At the bottom there, you'll notice a bit about complex RAM data processing.
32:53
I'll go into a little more detail on this later, but certain producers are obviously going to have more complex data and they're going to have larger needs when it comes to the RAM.
33:06
This can be due to large skew volumes or very diverse formats.
33:10
So we've created a separate support product to allow, to ensure that this is resourced and that these members are getting the support they need.
33:22
So I'd like to now go into a little bit more detail on the RAM component checker that I mentioned.
33:29
Now this is something that we've been working on really, really hard here at Ecosurity and to be fair we're very proud of it because it's a fantastic tool, incredibly useful.
33:42
The component checker is available to all of our members regardless of submission support level and will be available through our hub.
33:50
But to basically summarize, this works by condensing the huge number of different RAM criteria and assessment points into a series of user-friendly questions separated by material.
34:03
As you can see on the slide, there are 12 material categories, which seems a little daunting, but it's mainly to cover the variety of plastic formats more specifically.
34:12
I know that Alison's covered this earlier a little bit about the need for a detailed breakdown and the categories also allow for separate review by material and by certain specific item types, which overall does make the process simpler because you can aim specifically based on an individual product.
34:30
Where items need to be assessed together, which we mentioned before, where they're not separate by hand, you just go to the category with the predominant material by weight.
34:39
So a glass bottle, for example, the paper label would be assessed through the glass set of or an aluminium ***** lid with a small inbuilt with a plastic seal would be assessed as aluminium.
34:52
So each question will have a simple yes, no, don't know and then once all the questions are completed you get a RAM result. Fantastic.
35:00
This is if this is red or amber it will then flag up which area or areas have resulted in this outcome which would be really useful longer term if you make packaging format improvements or decisions, or actively work to reduce your non-green write results.
35:19
Another great feature, in fact, possibly my favorite feature, is this can be saved as a PDF.
35:25
And this is a brilliant way to create a record of methodology which can be saved.
35:31
And then if a producer is audited, which we all know can happen, this means that they have a thorough record of how they carried out the RAM assessment methodology.
35:41
and means that they can comprehensively look up any individual item and say I've classified this as amber for example and it is because of this particular feature here.
35:55
Moving on, just to summarize the benefits of the component tracker, again I've gone through a lot of this already but just to do some quick bullet points, you can identify from this what is causing a red or amber outcome, which means that then you can create an action plan for improvement.
36:15
You have a record of any don't knows you've recorded and this is in turn a great way to look for data gaps. And then we can also ensure that we are completely up to date.
36:25
So we have already implemented the changes that Alison's outlined and obviously we will stay on top of this in future and it just means you will have access to a tool that is up to date without having to make sure that you're checking through about different versions that could have come of the regulations. Next slide, lovely.
36:47
So for our calculate and outsource members, probably the biggest priority is saving time and ensuring data accuracy, especially with the somewhat tight timeframe we're working with.
37:00
So we're front loading as much assessment as possible by carrying out pre-assessments.
37:04
This means we use the previous data submissions to kind of go through and run through and we can highlight areas or materials of concern earlier and offer the best chance for these producers to identify data gaps.
37:16
We can then address these collaboratively using the component checker to address these issues and create action points if further data is required to avoid those default red outputs we're trying to avoid.
37:30
Obviously I touched on earlier that some of our members are going to have, no, no, next slide's fine, that some of our members are going to have more complex data than others.
37:45
And for these producers, it will represent a significantly larger challenge.
37:51
These are companies that place a very large number or a wide range of different components on the market to avoid a large volume of default red outputs, which obviously we want to avoid.
38:04
we need to ensure that these members get additional resourcing.
38:08
We've set up additional product to basically ensure that we resource these, that we can give them the time and priority that they deserve in order to get the best possible results.
38:20
Next slide, please. I'm going to briefly touch on the what next.
38:28
If after an initial assessment, you feel a bit of further support is needed.
38:34
So obviously after an initial assessment, you may find that you have a large volume of red or amber results.
38:43
And obviously some companies, some sectors are constrained by format due to a myriad of reasons, safety requirements, maintaining the sterile status of products, chemical containment or food safety for example.
38:59
So, where this is the case, there may be little that you can do about the format because you are constrained by these and they can't change.
39:08
However, for some other companies, this might not be the case and you might be keen to see what you can improve.
39:15
Where this is the case, we can bring in our lovely advisory team to work with you to improve those outcomes.
39:23
Obviously, you've heard earlier from Alison, she's a fairly integral part of that team.
39:27
We can arrange to work with a producer to address where improvements can be made to packaging formats.
39:35
And in the next slide, we can go through how that looks. So there are two stages to this.
39:43
What we'll do after we've met with you to assess the scope of the project and what we can provide, we would run a discovery workshop, which would look at areas to address and improve.
39:56
so you can quickly understand basically what the potential is and where you could go next.
40:02
It may be that you're happy with that, which would be great.
40:05
That's set you off in the right direction.
40:07
Otherwise, what we can do is we can do a follow-up where we can work with you further on actioning those issues, set some targets.
40:16
We can model costs and sort of compare how sustainability works versus cost and what the best options are going to be to kind of optimize your results both cost wise and with getting the best results possible and sort of managing to future proof your packaging where you can.
40:36
Fantastic and I think that is the end of my section so I will hand you back over for any questions.
40:51
Thank you very much, guys.
40:53
I think very useful stuff there that hopefully everybody found very interesting.
40:57
We have had quite a few questions that have come in already, so we'll try our best to get through as many of them as we can.
41:03
So the first one that we've gotten is if it's classed as one unit under EPR, is the weight total of both components reported as one or just the weight of the main component reported?
41:17
So I can take one, so that one, sorry.
41:21
So the, in terms of how you report based on market under the EPR data submissions hasn't changed.
41:28
So say if you've got a piece of packaging that's made of two components that's plastic and paper, as is the case now, as has always been, you will report that separately under plastic and paper.
41:40
However, if when you are assessing it during the RAM and it's not hand So you're assessing it as one component, that's fine, you do it by the dominant material by weight, and then it's still recorded under two material types under EPR, but whatever RAM output, the lesser material inherits that.
42:02
So you're not reporting it now as one component under EPR data submissions, you're still reporting the separate materials, but you might have to assess it as one component by the RAM.
42:12
and in which case both those reported materials inherit the same rag red amber green status.
42:19
I'm sorry I didn't go explain that very well but I hope that makes sense.
42:23
It's quite a confusing aspect of it. Thank you very much Louisa.
42:28
The next question that's coming is on a product that someone's struggling to assess.
42:32
So it's a product that is a glass bottle with a plastic cap.
42:36
The cap can be removed by hand however it has a plastic tongue for evident that will be left on the glass bottle.
42:42
Does this make the glass bottle assessment, Amber, as it's a non-glass attachment that can't be removed by hand?
42:51
It is possible.
42:53
So unless, without knowing the full context of the particular material type, I don't want to give a definitive answer.
43:00
But yes, a part of the references of triggers within the RAM for glass does reference non-glass attachments.
43:09
There is, I guess, clarifications as to what that includes.
43:14
So, for example, it does actually say for metal caps, if you still have a metal ring remaining, it actually excludes that as within that non-glass attachment.
43:26
But if there is particular items that you'd like to, I guess, talk through, I'd probably say let's take that off of this call, or I guess off this webinar, and we can engage directly to see what that particular format is. But without knowing the full context, I can't give a direct answer, unfortunately.
43:43
Thank you.
43:45
We've had another one that's come in which is on for flexible plastics, does the fact that they can be recycled at front of store count as the take back scheme?
43:57
So this is something that not just us will try, everyone is just trying to get some clarity on essentially. So the criteria to have a take back scheme under the RAM is quite high.
44:13
it's quite a high bar to meet so it has to be accessible for instance by 75% of the UK population, brand agnostic, all of these kind of things.
44:24
So it loosely follows the OPRL methodology of what A defines a take-back scheme.
44:32
We do think currently without having had done having done the calculations just yet that the flexible plastic front of store UK collection system probably does cover 75% of the population.
44:45
How the intricacies of how that's reported and who reports that under the RAM and whether that means you can have an amber and rag status as opposed to a red, that's still TBC.
44:55
Alison, I don't know if you want to add any more context to that, but our feeling is that the flexible take back system in the UK must be one of the ones with the widest coverage.
45:08
So we're hoping that it does meet the criteria for a take-back system under the run?
45:14
It is something that we engage directly with government to hopefully get a definitive answer on.
45:20
As Louisa said, it is one of the biggest take-back schemes for any kind of other materials within the UK.
45:27
So if that wasn't recognized, we don't know what probably would be recognized as a take-back scheme in terms of access to population.
45:34
But again, we're kind of doing that assessment at this point in time to determine where the population access levels meet those requirements.
45:43
So the RAM on the DEFRA website, there is actually three web pages.
45:49
So the 7 ,000 words I referred to earlier is just the material assessment section.
45:54
There is obviously a landing page with detail about the automatic reds and the process in terms of there being a technical advisory committee and that kind of thing.
46:03
And then there's also a third page which provides definitions, a little bit more detail what each of the, I guess, stages refer to, so what does it actually mean by classification, collection, sortation, reprocessing, etc.
46:16
But also as part of that, they do reference a take-back scheme protocol, which has been taken from OPRL's take-back schemes and those that are recognised under the OPRL system.
46:27
So once we do have, I guess, an answer on whether or not the front-of-store flexibles will be recognised, I guess once we know that, we'll be able to share that, but at this point, we don't have a definitive answer, unfortunately.
46:42
I would say, however, that it is important to note that simpler recycling is coming into play.
46:48
And as part of that, by 2027, there aims to be, I guess, flexible collection at household curbside.
46:57
By that point, which means within a couple of years, we're likely to then see the RAM be updated to indicate that there is actually collection.
47:06
So it may only be a a couple of years before that does change, but it's good to be aware of that and to be working towards, I guess, collection for those things and aligning with best practice design in the meantime.
47:23
We've also had another question on take-back schemes, which is, when it comes to plastic films, how best can producers evidence compliance against the take-back protocol, particularly in respect of the accessibility and traceability requirements?
47:37
Has any standard information been published on the current take-back schemes?
47:43
Unfortunately, it's just what I've just referred to.
47:45
So it's just what's on the website at this point in time.
47:48
So again, we're hoping for more detail, but we don't have that just yet.
47:52
The only thing we can go off as a whole industry at this point is what's currently on that web page as part of the RAM on Defraud's website.
48:02
Fantastic. Thank you.
48:03
I have another question that has come in which is on, does the exemption from RAM assessments for drinks containers subject to a future DRS applies at all for UK nations?
48:20
Yes currently it does, so there's no kind of reporting or exceptions for Wales.
48:28
So that is a big question Mark, obviously the person who asked the question understands that in order for the exemption for drinks containers to apply, it means that a DRS needs to be operational in England, Northern Ireland and Scotland by October, 2027, which is what's written in the legislation is still might happen or it might not.
48:50
So that's the backstop.
48:52
If the DRS is not implemented by then, then government have stated that those in scope containers, so plastic bottles and cans essentially might then be subject to EPR fees so then might have to undergo RAM assessments as well.
49:08
The Wales situation, I don't think we've had much new information other than they obviously still want to in theory include glass bottles in their scheme.
49:21
We're not quite sure on the timings yet, they have committed to working jointly with the other three but in terms of alignment between the four nations, various DRS, it's still really unclear at the moment.
49:33
But for now, until 2027, you should take it that PET bottles, steam-aluminium cans, regardless of where you're selling them, in which nation you're selling them, are exempt from EPR fees.
49:49
That said, the reason for that is because the producers, the brand owners supporters, etc.
49:55
of those drinks containers are expected to kind of foot the bill of DRS pre implementation costs.
50:02
So instead of paying those EPR waste management fees, they will to a degree be expected to help fund the startup costs of the DRS instead.
50:10
So that's the reason for that exemption.
50:13
Yeah, but as it stands, the intricacies of material in scope or out of the Welsh DRS have not been clarified.
50:24
Okay, thank you.
50:26
We've had a question that has come in on the OPRL guidelines.
50:30
So is it clear yet if the guidelines will change so that consumer behaviors are aligned to RAM assessment in terms of separable items, i.e.
50:39
where steel closures are oversized threshold, they're instructed to separate versus rinse recycle lid on instruction indicated currently?
50:47
So there's nothing within the RAM that requires that.
50:52
So the RAM is purely an assessment for reporting purposes.
50:56
Realistically, it's not there to be used as I guess the evidence base for unpacked claims.
51:02
If you are concerned about labeling, particularly in relation to OPRL, I would say to engage OPRL directly.
51:10
They mentioned on a webinar earlier this week that they've updated their kind of methodology for alignment with the ramp but in terms of the types of I guess directions that are provided within the OPRL whether that will be amended it would be best to engage with them to get that answer.
51:31
Okay thank you.
51:33
A nice quick question here was does the example for So for secondary packaging, is it a flat EPR fee?
51:45
So EPR waste management fees, or those local authority fees, just apply to household and recombinant treatment packaging.
51:53
As I mentioned, by default all primary shipment packaging is classed as household.
52:00
Secondary and tertiary packaging will always be classed as non-household.
52:04
There's no exemptions or moving around within the EPR data reporting.
52:08
So secondary tertiary is always non-household and non-household packaging just picks up a PRN cost.
52:16
So no, it's the short answer.
52:17
The household packaging is the packaging stream that picks up the EPR local authority costs plus the existing PRN costs on them.
52:27
So with secondary packaging, I think it was tertiary or secondary packaging they're asking about, just it needs to be reported is non-household across the board and just has a PRN obligation. Okay thank you.
52:42
We've got a question here which is the RAM states that flexible plastic packaging types may progress via the take-back route if a valid scheme is available but are kept at amber.
52:52
It is the responsibility of the producer to prove they meet the criteria set out in the take-back protocol.
52:58
Will in-store collections be considered valid take-back and what are producers expected to provide as evidence where not their own take-back scheme but managed by the retailers.
53:10
I think we answered that a little bit earlier on.
53:13
Again, unfortunately, we have that detail, unfortunately, but again, once we do know and answer, we will be letting people know.
53:21
Louise, I don't know if you're going to say anything different.
53:23
No, yeah, it's like, it's obviously, it's a question that we really want answered and obviously say to lots of people under the webinar today as well, so we do definitely need clarity on that.
53:33
I would just highlight separate to the RAM, I know it's not the conversation, but if you are offering take back of hard to recycle materials, you can also be reporting that.
53:45
If it's you doing the take back or funding the take back, then you can report that under self-managed consumer waste, and that's the mechanism to get it netted off EPR waste management fees.
53:57
Again, there is data you need to collect that and the criteria that you need to reach but if just become FYI for everyone if you are part of a take back scheme it would be worth asking experts within your company or your compliance scheme that know about EPR about whether it can be reported under self-managed consumer waste separate from the RAM but still deals with the businesses companies that are room, take back or collection.
54:29
Brilliant, thank you and we've had a question which is asking if you could provide any advice or insight into how to gather store REG assessment data.
54:40
This feels challenging where assessment is not consistently made at SKU level or packaging item level but instead based case by case on how packaging should be presented to the waste room.
54:54
That is a tricky that everyone is facing at this point in time, mainly because most companies have their own, I guess, system for their own data collection on their products.
55:06
Many businesses haven't been collecting this data before, so unfortunately, there isn't a one-size-fits-all answer to this.
55:13
The main thing that I would be recommending is engaging your supply chains, speaking with your packaging suppliers, speaking with your packaging team.
55:22
Historically, what we see a lot is within companies under the previous regulations, a lot of the contacts that have been involved with reporting haven't necessarily been sustainability or packaging, I guess, individuals within a business.
55:39
It's often been within the finance team that it's fallen because of the relation to PRNs.
55:44
What's now really critical for businesses is making sure that this is a business-wide approach.
55:50
Packaging does realistically touch all elements within a business.
55:53
So we're starting to see businesses and we're starting to encourage businesses to kind of create their own kind of internal packaging groups and making sure you do have, you know, your packaging designers, your artwork designers, your sustainability teams, your finance teams, your marketing teams, kind of all involved in across this so that you can be asking the right people the right questions.
56:16
For again, Ecosurity members, the component checker is a great way to kind of do those and have, I guess, a record that you can save as that PDF, which Emma took us through.
56:26
But the engagement with the suppliers and your packaging teams, if you do have them internally, is gonna be crucial.
56:35
So it's gonna be quite a big data capture over the next little while.
56:39
And I think all of industry is aware of this and it's a little bit daunting, but that's why, as Emma said, when to start is as soon as possible.
56:48
I mean Emma, Louise, do either of you have any other comments?
56:53
No, only that, just the kind of, in terms of the enforcements of the environment agency in England and the other relevant environment agencies in the other three nations, the onus is kind of on you as the producer to kind of, they won't prescribe us what they think is good evidence, essentially.
57:13
They won't say if you've got XYZ that hits the criteria for evidence behind the RAM.
57:17
So the onus is on us as industry to ensure that we have correct evidence of a red amber green rating which I think just emphasizes what Alison said it's like it's really important to understand your supply chain get as much evidence as you can so you can be confident if it did come to an audit that you could produce those documents and say this is the reason why this is green but This is amber, this is red, et cetera.
57:47
Okay, thank you.
57:49
Conscious of time, we've only got a minute left.
57:51
There's still quite a few questions in there, so please do get in touch with the guys afterwards if you have anything that hasn't been answered.
58:00
We have been recording, of course, and we'll be sharing with you the recording and a couple of the slides afterwards, along with the contact details.
58:07
But I think there's one last question, which is probably a good one to wrap up on as well, which is, if I'm struggling to gather the data needed to perform RAM assessment from suppliers, can Ecosurity support?
58:20
Yes, that's the quick answer.
58:23
Yes, please get in touch.
58:24
We'd be very happy to support you with that.
58:28
Great.
58:28
Well, thank you very much, guys.
58:30
Thank you for answering all those questions.
58:31
I tried to get through as many of them as we could.
58:34
Again, if we haven't been able to answer yours, please do get in touch afterwards, and I'm sure people will be able to help you.
58:41
Yeah is there anything else from you guys? No thanks very much, thank you. Thank you.
58:48
Always a pleasure, well thank you guys very much and yeah we'll be sending you the slide deck along with the contact details afterwards so yeah hope you have a great rest of the week and see you again soon. Thanks, everyone. Bye.
