The reusable packaging industry calls for establishing a clear and enforceable reuse symbol

10 September, 2025

The reusable packaging industry calls for establishing a clear and enforceable reuse symbol

The undersigned 78 organisations, led by the New European Reuse Alliance and Reusable Packaging Europe on behalf of the reusable packaging industry as well as other civil society organisations, fully support the European Union’s ambition to reduce packaging waste and acknowledge the initiative laid down in the Regulation (EU) 2025/40 on packaging and packaging waste (hereinafter, PPWR) to introduce a label to indicate the reusability of packaging (Article 12.2). On this basis, we call for a symbol on reusability -in line with the labelling requirement laid down in the PPWR- that is clear, enforceable, and resistant to misuse from packaging that is not truly reusable. In the present statement, we outline a vision for such a symbol, including key requirements the pictogram should (implicitly) represent, enforcement mechanisms required to ensure that only genuinely reusable packaging can bear the symbol, the specific case applicable to reusable transport packaging, and suggestions for key visual criteria for a powerful reuse symbol.

Since implementing acts on the development of labelling requirements are expected by August 2026, as set in Article 12.6 of the PPWR, we would like to ensure that the reuse symbol effectively supports the EU’s circularity goals while aligning with the operational realities of all reusable packaging systems, in particular those of reusable transport packaging operating in pooling system for business-to-business (B2B) operations.

Context

Our priority is to support the European Commission in defining clear and robust criteria for the application of a reuse symbol. These criteria must ensure that only packaging that is truly reused in practice would be allowed to use the symbol. This will help prevent greenwashing. The symbol should also serve as a tool to inform end users and consumers easily about the reusability of the packaging.

We aim to support the European Commission in choosing a bold, clear pictogram that not only embodies reusable packaging but also ties reuse to concrete guidelines. This will safeguard the integrity of reusable packaging systems and accelerate genuine circularity across Europe.

What the symbol will convey

The reuse symbol must be reserved exclusively for packaging that meets well-defined reusability criteria, ensuring that it is not mistaken for single-use without a reuse function or reuse system behind it. As such, the reuse symbol should be coherent with the reuse criteria laid down in the PPWR (Articles 11, 12, 26, 27, 29). To uphold trust and credibility in the symbol, the symbol should only be used on packaging that complies with the following criteria:

- Packaging is part of a reuse system: Reusable packaging should be part of a system for reuse, which includes certain components (e.g., collection, sorting, washing, repair, and redistribution) that are specific to the type of packaging (primary, secondary and tertiary), and an entity or party responsible for the performance of the system as a whole to increase accountability.
- Packaging is conceived and designed for reuse and safe multiple rotations: As laid down in the PPWR (Article 11.1.e), packaging placed on the EU market is defined as reusable when it has been conceived, designed and placed on the market with the objective to be able to withstand repeated handling, cleaning, and refilling.
- Demonstrated minimum number of rotations in packaging lifetime: As laid down in the PPWR (Article 3.27), reusable packaging shall be used again multiple times for the same purpose for which it was conceived. Moreover, Article 11.2 of the PPWR states that the European Commission will adopt a delegated act setting up a minimum number of rotations for reusable packaging. Alignment and consistency between the legislation setting a minimum number of rotations and labelling should be ensured. Compliance with this requirement should be verifiable through traceable systems or certified average calculations.
- A demonstrated high return rate: For a reuse system to function effectively, a high return rate and a functioning system for return are essential. The reuse symbol should be granted only to reusable packaging that achieves a high return rate, in accordance with the delegated act setting the minimum number of rotations, ensuring that the majority of packaging is reintegrated into the system.
- Packaging is designed for and within a system with responsible end-of-life treatment: In line with PPWR Article 11.1.i, reusable packaging must be designed with a clear end-of-life strategy. While the priority is maximising reuse cycles, all reusable packaging must remain recyclable at the end of its lifecycle to minimise environmental impact.

Enforceability measures to prevent misuse

We propose to the European Commission a series of enforcement measures to ensure the credibility and integrity of the reuse symbol and avoid it being used for packaging that is not truly reusable. We suggest the following measures to be further defined and enforced by the European Commission:

- Guidelines: In accordance with Article 12.8 of the PPWR, both general and sector-specific guidelines should be elaborated by the European Commission, in active discussion with industry representatives. Such guidelines should allow the reusable packaging industry to clearly understand how to adequately implement the labelling requirements, acknowledging the current market practices and different uses depending on the type of packaging. At the same time, these guidelines should allow the sector to continue to innovate its services and products, in line with the requirements laid down in the PPWR.
- Penalties for misuse: Companies falsely labelling non-reusable packaging as reusable should face penalties and restrictions for employing the reuse symbol. National authorities should further define penalties, including labelling requirements as laid down in Article 68 of the PPWR.
- Oversight mechanisms: National or EU regulatory authorities and (authorised) non-governmental organisations (NGOs) should oversee and audit the compliance of the reusable packaging industry with the requirements set down for their assets to bear the reuse symbol. Such operations should not, however, imply an additional economic cost on reusable packaging operators.
- Education and awareness-raising initiatives: The European Commission, together with national competent authorities, including Producer Responsibility Organisations (PROs), should support reusable packaging companies and associations through several initiatives, both online and offline, to introduce end users and consumers to the reuse symbol and what it entails.

At the same time, sector-led initiatives can also be established to enhance the credibility of such a symbol, including protecting the symbol via a quality trademark or certification trademark. The reusable packaging sector is also open to having the reuse symbol as a quality trademark/certification trademark for genuinely reusable packaging, as it may act as a valuable solution to address the issue of potential misuse by non-reusable packaging. Moreover, a trademark would act as a guarantee of compliance, promoting trust in the system and encouraging responsible handling from end-users¹.

Following the example set in Germany by Arbeitskreis Mehrweg GbR, such a trademark could be obtained via a licensing agreement between the companies using the trademark and the owner and issuer (non-governmental) of such a mark. The companies would need to abide by a set of criteria to follow and would need to pay a small fee to the owner of the mark. The owner will need to carry out audits and check that companies using the mark are compliant with the criteria set down².

The case of reusable transport (tertiary) packaging

With implementing acts on labelling requirements anticipated by August 2026, we the undersigned parties, call on the European Commission to recognise the particularity represented by reusable transport packaging (RTP) operated in a pooling system for business-to-business (B2B) operations and to acknowledge that this type of packaging should not have to carry said symbol on their individual assets. While a physical labelling or symbol requirement may serve a purpose in consumer-facing (B2C) contexts – helping consumers distinguish between reusable and single-use packaging – this requirement 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. 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.

Per article 12.5, the “affixing, printing or engraving” of a reuse label/ symbol to RTP is therefore “not warranted on account of the nature […] of the packaging”, the nature being reusable transport packaging being managed in a closed-loop system by a system operator in a business-to-business environment where end-users of packaging are already informed of the reusability of packaging through the system-specific logos and colours as well as the supporting logistical infrastructure to enable return and therefore extended reuse.

The recognition from the European Commission that closed-pool RTP should not have to carry physical symbols or labels on individual assets would level the playing field with RTP used in open-loop systems and avoid unnecessary duplication of the work already being carried out by the RTP pool sector.

On their side, RTP poolers are ready to include such a reuse symbol to existing digital documentation (e.g. shipping or rental records) used within B2B systems. This method ensures compliance, informs end users of reusability, facilitates the tracking of the packaging and the calculation of trips and rotations, avoids additional physical applications of labels or symbols, and reflects operational realities, in line with Article 12.2 and 12.5.

Visual criteria for the reuse symbol

The sector self-consulted on the key visual principles that the reuse symbol should adhere to in order to ensure effectiveness and broad applicability across different packaging systems. We recommend the following suggestions, also in line with the global initiative currently being carried out by PR3³:

- The symbol shape should immediately convey to the end user that the packaging is reusable. To achieve this, the shape and design of the symbol should not resemble existing symbols conveying a distinct message (e.g., recycling). This would avoid creating confusion for end users/consumers and packaging industry operators.
- The symbol should be easily recognisable across various applications, visually attractive, simple to reproduce (e.g. easy to draw), and memorable.
- The symbol should be powerful enough to resonate with diverse audiences and represent the concept of reuse while being adaptable to various contexts, cultures, and languages.
- The symbol should inspire action and encourage the adoption of reusable packaging.
- The symbol should be unified across Europe.
- The symbol must remain clear and legible when scaled up or down in size, or for various applications to packaging (labels, embossing, marking, etc), documents, or online platforms.

¹ A concrete example of such initiative is currently being carried out worldwide by PR3, the global alliance to advance reuse, for both packaging and infrastructures set by the reuse systems.
² The system currently up in Germany is applicable to reusable beverage manufacturers, beverage and food retailer sector, and environmental and consumer organisations. It may only be used in connection with the reusable system for beverages. In concrete terms, this means that it may be used on labels and in communication measures by manufacturers who have signed the terms of use of the symbol. In retail, it is used to draw attention to reusable bottles. Environmental and consumer organisations, as well as the media, use it to provide information about the reusable system. More information are available here: Meaning: Reusable.
³ The initiative being carried out by PR3 is called “Rebrand Reuse”, with an open call for a global reuse symbol.

The reusable packaging industry calls for establishing a clear and enforceable reuse symbol

Context

What the symbol will convey

Enforceability measures to prevent misuse

The case of reusable transport (tertiary) packaging

Visual criteria for the reuse symbol

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