
Understand packaging refill and reuse policy
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.


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