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Reuse + Refill Policy: Is it fit for purpose?

Until recently, packaging policy centered on making single-use lessbad. Food safety, recyclability, and recycled content were morethan 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 yet, 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.

Packaging policy related to reuse and refill is in its infancy. As a result, do policymakers really understand what ‘designing for reuse’ means?

Policy confusion around reuse and refill

Packaging policy related to reuse and refill is in its infancy and can be confusing:

  • Does product design policy cover a refillable pack, or is it captured appropriately under policy designed solely for the recyclability of single use (i.e. EPR)?
  • Why is refillable packaging not incentivised by policy mechanisms?
  • Do policymakers really understand what ‘designing for reuse’ means?

Round-up of anticipated policy updates

In Europe, the Circular Economy Action Plan sets out the direction of travel for reuse of packaging.

Reuse and refill is being considered in the upcoming European Packaging and Packaging Waste Directive update, due out at the end of November. A recent leak suggests that reuse and refill will be a central component of the update. It’s also anticipated that the directive will set minimum targets for the ‘On the Go’ sector, covering takeaway beverages and ready-to-eat take-out foods.

Also expected is an obligation for member states to increase the rollout of systems that allow reuse of packaging, and refills. These include mandating businesses to:

  • offer a minimum % of products in refillable or reusable packaging
  • take part in deposit return systems for reusable containers
  • offer economic incentives to support take-up of The Single Use Plastics Directive

Countries already taking the initiative:


  • Luxembourg and Ireland plan to replace single-use items with reusable alternatives
  • In the Netherlands, reuse and recycling targets are tied together, e.g. X% is reused or recycled by 2025.
  • In the USA, 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.

Root's Impact Analysis Metrics methodology highlighted policy areas that urgently required clarification to protect consumers on health and safety and misleading greenwash claims

Misleading reuse and refill ‘Greenwash’ Claims

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.

Where better policies are needed

  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

Get in touch

Root is one of Europe’s leading sustainable consultancies, advising brands on how to use less and transition to becoming a regenerative, inclusive and kinder organisation to people and our planet.

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