Introduction

Until recently, packaging policy centered on making single-use less bad. Food safety, recyclability, and recycled content were more than enough for packaging teams to stay on top of.

The increasing trend in mandatory and modulated Extended Producer Responsibility schemes is already putting additional pressure on retailers, brands, and packaging producers, but again, these centre on recyclability, not reuse.

The presence of reuse and refill in policy was pretty much absent until a few years ago. Slowly, governments have begun to recognise the need for enforced systems that help reduce litter, yield greater value from existing resources, and protect our environment and nature.


Existing policy confusion

Packaging policy related to reuse and refill is still in its infancy and can be confusing. For example, does product design policy cover a refillable pack, or is it captured appropriately under policy designed solely for the recyclability of single use, such as EPR?

Refillable packaging is generally not incentivised by policy mechanisms yet, with no clear signals that policymakers really understand what ‘designing for reuse’ means.

New Extended Producer Responsibility (EPR) for packaging in the UK started to be phased in from 1 January 2023. For the first time, organisations must report reusable packaging under a new packaging activity of ‘Service provider’, when they hire or loan packaging.

It will predominantly be used for items such as pallets by most producers, and what is not yet clear is how this category of reporting will manifest in the calculation of financial obligations, including waste management fees and PRNs. This will need to be the real driver to encourage reuse and refill under packaging EPR, but to what extent it will is yet to be seen.


Recent EU policy updates

In Europe, the Circular Economy Action Plan sets out the direction of travel for reuse of packaging. In the proposed European Packaging and Packaging Waste Directive update, published at the end of November 2022, reuse and refill were a key component in the drive to reduce the amount of single-use packaging.

The proposal outlined minimum food packaging reuse and refill targets to achieve by 2030:

  • 10% for non-alcoholic beverages, increasing to 25% by 2040

  • 20% for hot and cold take-away beverage containers, increasing to 80% by 2040

  • 10% for consumer-facing businesses such as restaurants and cafes, increasing to 25% by 2040

  • 5% for wine bottles, excepting sparkling wine, increasing to 15% by 2040

Further legislation is expected from the European Commission to help avoid excess greenhouse gas emissions caused by transporting reusable packaging over long distances to be refilled, with widespread decarbonisation of transport networks not expected before 2035.


Countries already taking the initiative

Luxembourg and Ireland plan to replace single-use items with reusable alternatives and in the Netherlands, reuse and recycling targets are tied together, with a % to be reused or recycled by 2025.

In the USA meanwhile, some states, such as California, are beginning to pass legislation that sets the scene for reuse and refill.

Municipal collection pilots in cities such as Jakarta are driving greater awareness and bringing more visibility to reuse and refill strategies. Indonesia is beginning to include reuse provisions in policy, however, this is mainly the reuse of industrial and manufacturing waste.


Future policy clarifications required

When it comes to designing for reuse, the absence of coherent policy means brands lack an even playing field. We recently applied our Impact Analysis Metrics methodology to compare single-use vs refill for a multinational healthcare brand. The process highlighted policy areas that urgently need clarification to protect consumers concerning health and safety, as well as guard against misleading greenwash claims.

Clearly, better policies are needed to specify:

  1. When and how reusable packaging should be cleaned

  2. To define a ‘life’ for key packs and uses. Currently a business can make a ‘refillable’ claim if the pack can only withstand being refilled twice. In contrast, many businesses already offer packaging components that have a much longer life than ‘single use’

  3. To specify the minimum number of times a component can be reused in order to make a ‘refillable’ claim. Many businesses and industry bodies are coming up with numbers that don’t translate effectively across a packaging portfolio


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Root is a sustainable packaging consultancy supporting global brands and packaging producers. Root helps clients to use less and reduce the impact of their packaging on people and the planet by shifting their focus to a more regenerative approach.

To learn more or schedule a call with a Root sustainability expert, please visit www.root-innovation.com.


Tracy Sutton Root

Tracy Sutton

Founder and Lead Consultant, Root

Tracy Sutton set up Root in 2013 to help organisations use less and focus on becoming regenerative, inclusive and kinder to people and our planet. She oversees a diverse collection of specialists, handpicked to be part of the wider Root Network.