STATEMENT
LINERLESS LABELS – PACK UK
Published: Monday 29th September 2025
By: Ravenwood Packaging Ltd
On the 4th of September 2025, DEFRA published supplementary guidance to clarify the RAM / EPR Version 1.1 that was published in April 2025.
In the guidance at the bottom of Page 7/10 and the top of page 8/10, under Paper and Board ‘Siliconised paper’, they stated, ‘Both linerless labels and 2-ply (peel & read) labels use silicone. Any siliconised paper would receive a Red RAM rating unless there is a takeback scheme which meets the requirements of the RAM take back protocol is used’.
Ravenwood believe this is still ambiguous because the way in which they produce linerless labels, no siliconised paper is used. The Ravenwood system applies a small strip of a release coating to the pre-printed label surface which then has adhesive strips placed over it as the roll is wound up so at no point is a siliconised paper used.
Pack UK have advised that there will be no change to the current RAM Version 1.1 until July 2026 however, they are taking advice from their Technical Advisory Committee (TAC) for this next update.
Ravenwood are providing evidence to the TAC which shows that the way in which they produce linerless labels means that the amount of silicone in the release strip on average is less than 0.2% of the weight of the label.
In Australia, Ravenwood has achieved APCO accreditation for paper linerless labels to be classified as kerbside recyclable. In the final report APCO stated, ‘the addition of small amounts of silicone in the release layer did not have a demonstrable effect on the ash content. In fact, the ash content went down with the addition of the release coating’. They went on to say, ‘it can be concluded that the silicone in the release layer would be expected to have negligible impact on the recycling progress, given that it will be such a small fraction by weight’.
In August 2025, Ravenwood carried out their own repulping tests with CIRCPACK which simulates the behaviour of a paper-based packaging at the paper mill following the harmonised European laboratory test method from CEPI. The labels chosen were as much as was possible ‘worst case scenario’ with small, heavily inked labels which used 3 adhesive and silicone lines. The conclusion was as follows:
The recyclability score, for both labels, and as per the 4evergreen Fibre-based Packaging Recyclability Evaluation Protocol is +78/100’.
The 4evergreen Recyclability Evaluation Protocol is a system used to score the recyclability of fibre-based packaging, producing a score from -100 to +100 based on suitability for a standard mill. The protocol utilises test results from a standardised laboratory process, assessing factors that impact recycling efficiency and material quality for both conventional and specialised recycling mills. A positive score indicates better recyclability in a standard mill, while a negative score suggests it may be more suitable for advanced, specialised recycling processes. So the score of +78/100 achieved by Ravenwood Linerless Labels shows they are eminently suitable for recycling through normal local paper collection.
Ravenwood and their approved printers along with retailers, industry organisations and customers will continue to endeavour to show the TAC team and Pack UK that linerless labels which use tiny amounts of silicone should not be classified as Red.
In Summary, evidence of testing Ravenwood linerless labels as outlined in the RAM document, can be presented to show the recyclability of a linerless label. Ravenwood is able to show that through careful stewardship of the supply chain that the materials used to make labels in the Ravenwood’ Circle of Linerless’ are able to enter into the normal paper recycling chain giving a Green rating rather than a Red rating.
Ravenwood Packaging Ltd
For further information, email the team on EPR@ravenwood.co.uk
