Separate EPR reporting, the RAM result, consumer disposal instructions and marketing claims before approving on-pack recycling wording.
GOV.UK’s Recyclability Assessment Methodology supplementary guidance states that RAM does not include recyclability-labelling guidance and that there are no legal obligations for recyclability labelling under EPR for packaging. That was the official position checked on 1 September 2026.
This does not mean that any recycling statement may be printed without evidence. Product-specific rules, voluntary labelling-scheme requirements, retailer policies and requirements in other markets can still apply. Environmental wording must be accurate for the exact finished pack, clear about what it covers and supported by current evidence.
| Decision | Purpose | What to retain |
|---|---|---|
| RAM rating | Supports relevant EPR recyclability reporting and fee modulation for the applicable reporting year. | The assessed pack, component data, methodology version, decision path and result. |
| Consumer disposal instruction | Tells the user how and where to dispose of the pack under the chosen scheme and market. | The scheme criteria, market, exact artwork, component instructions and approval. |
| Environmental claim | Describes a claimed benefit such as recyclable content or recycled content. | The scope, evidence, qualifications, whole-pack limitations and current market context. |
| EU-market label | Meets the phased EU Packaging and Packaging Waste Regulation requirements where the pack is placed on the EU market. | The applicable PPWR requirement, market, implementation date, technical file and artwork version. |
| 1. Define the market | Record where the product will be sold. A UK-only pack and a pack placed on the EU market may need different legal and scheme reviews. |
|---|---|
| 2. Freeze the pack configuration | Identify the bottle or pouch, cap, liner, label, adhesive, sleeve, fitment, seal and any removable parts by supplier reference. |
| 3. Verify the intended statement | Distinguish “contains recycled material”, “recyclable”, a disposal instruction and a resin identification code. They do not mean the same thing. |
| 4. Check the evidence | Use current supplier declarations, the applicable RAM assessment where relevant, the chosen labelling-scheme rules and market-specific requirements. |
| 5. Qualify the wording | Make clear whether the claim applies to the body, cap, label or complete pack. Do not imply that every part is recyclable when an attached component prevents that outcome. |
| 6. Control the artwork | Retain the approved wording, artwork version, evidence sources, review date and change triggers. Recheck after a component or regulatory change. |
A resin name identifies the main material, not the whole-pack recycling outcome. Colour, barrier, label, adhesive, sleeve, closure, liner, fitment and product residue can affect the assessment or disposal instruction.
The Mobius loop or a resin identification code does not substitute for evidence. The meaning of a mark and the conditions for using it must be understood before artwork approval.
UK EPR/RAM and EU PPWR are separate regimes. A label prepared for one market should not automatically be carried into another without a market-specific review.
The CMA’s Green Claims Code says environmental claims must not imply that a product is recyclable when only parts are and other parts prevent recycling. State the scope accurately.
Only when the business has current evidence for the exact claim, pack configuration and market, and the wording does not overstate the result. Review the body, closure, liner, label, adhesive, sleeve and fitment together.
The current GOV.UK RAM guidance says EPR does not impose a recyclability-labelling obligation. OPRL is a separate labelling scheme with its own membership and evidence requirements. Other contractual or market rules may still require a specified label.
No. A label communicates a decision; it does not change the pack’s material, separability, sorting or reprocessing behaviour. Design and evidence must come first.
The EU PPWR applies to packaging placed on the EU market and introduces phased harmonised labelling and other requirements. Use the PPWR guide for UK exporters and obtain market-specific advice.
Review after a change to material, supplier, label stock, adhesive, ink, coating, sleeve, cap, liner, fitment, pack weight, intended market, collection guidance, assessment methodology or labelling-scheme rules.
Request packaging information for artwork review Open the claims checklist
This guide explains evidence and procurement questions. It is not legal advice or approval to use a particular symbol or claim.