Reusable Packaging Europe and the New European Reuse Alliance have led a joint industry statement calling for the European Union to introduce a ‘clear and enforceable’ symbol for consumer-facing reusable packaging, yet allow exemptions for individual assets in B2B operations.
Seventy-eight organizations have signed the statement, which backs the EU’s ambition to lessen packaging waste – in particular, the Packaging and Packaging Waste Regulation’s mandate to introduce a label indicating a pack’s reusability (Article 12.2) by August 2026 (Article 12.6).
The signatories assert that this symbol must be visually attractive and memorable, remaining legible through different application methods (e.g. labels, embossing, marking, digital applications) and when scaled up or down in size.
Similarly, its shape should not resemble existing symbols for different end uses, such as recycling symbols. It should remain recognizable across various applications, contexts, languages, and cultures, and should be simple to reproduce.
The statement encourages the Commission to design a symbol that encourages end users to adopt reusable packaging and envisions its unification across Europe.
To avoid greenwashing allegations, the signatories argue that the symbol should only be used to label packaging that is demonstrably reused in practice, preventing consumers and end users from mistaking it for a single-use solution.
This means the labelled packaging must operate in an established reuse system. The statement suggests that certain processes (collection, sorting, washing, repair, and redistribution) should be enforced in line with the packaging type (primary, secondary, and tertiary) for packaging producers to use the symbol.
The packaging should safely withstand a set number of rotations in accordance with Article 11.1.e of the PPWR, and producers should be expected to verify their compliance through traceable systems or certified average calculations. An entity or third party should also be responsible for maintaining the system’s performance and holding participants accountable, the signatories say.
Additionally, the reuse symbol should only apply if the reusable pack achieves a high return rate and is designed with a clear end-of-life strategy in mind – for example, recyclability.
Further suggestions to avoid the symbol’s inappropriate use include general and sector-specific guidelines that outline implementation, current market practices, and different uses depending on the packaging type. Regulatory authorities and authorized NGOs should oversee and audit compliance without enforcing additional costs for packaging operators, and penalties should be introduced for companies that mislabel their non-reusable packaging.
The statement raises the possibility of protecting the symbol via a quality or certification trademark, which could be obtained via a licensing agreement between a non-governmental owner and issuer and the companies using the trademark. This would require a small fee and a set of criteria, as well as audits to ensure compliance.
However, the signatories emphasize that none of this should stifle the sector’s ability to innovate its services and products.
When it comes to reusable transport packaging (RTP) operated in a pooling system for business-to-business operations, the signatories urge the Commission to allow an exemption from displaying a reuse symbol on their individual assets. They suggest that doing so ‘does not align with the B2B reality of RTP operations’.
“RTP poolers already implement robust identification systems, including markings, logos, and colour schemes, that effectively indicate reusability and ensure high return rates, fully aligning with the labelling requirements outlined in Articles 12.1 and 12.5 of the PPWR,” the statement reads.
“These systems are supported by tracking features and financial incentives, which ensure (proven) high rotations and return rates, and are complemented by contractual documentation such as agreements and delivery notes, providing clear and enforceable proof (and instructions) of reusability.
“Moreover, the application of a physical symbol on RTP assets shows numerous operational restrains. RTP undergoes extensive handling, making symbols present, for instance, on labels or physical marking, prone to wear, removal, or damage, leading to high maintenance costs that outweigh potential benefits.”
Relieving closed-pool RTP from reusable labelling requirements is set to level the playing field with RTP in open-loop systems and ‘avoid unnecessary duplication’ of existing reuse measures in the sector. Instead, RTP poolers are said to be on their way to including a similar symbol for digital documentation like shipping or rental records – theoretically ensuring transparency while avoiding unnecessary physical applications and reflecting operational realities.
If these measures are enforced, the European Commission is encouraged to work with national competent authorities, including Producer Responsibility Organizations, to conduct education and awareness-raising initiatives, both online and offline.
In other news, EUROPEN, FoodDrinkEurope, Cepi, and Cosmetics Europe joined other signatories in a joint statement urging EU policymakers to clarify the Green Claims Directive’s substantiation and verification requirements, loosen its transition period, and reconsider its rules on hazardous substances.
European Plastics Converters (EuPC), Plastics Europe, and Petcore Europe have also asked the European Commission to maintain its €0.80/kg levy for non-recycled plastic packaging and earmark the proceeds to fund a circular economy for the plastics sector.
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