The reuse duties that reach Henkel, Colgate-Palmolive and Marico sit mostly outside their refill programmes

Two rulebooks, two theories of reuse

The EU and India legislate reuse from opposite ends of the supply chain. The EU starts in the warehouse. Its targets attach to whoever uses transport packaging or makes beverages available, and the Commission’s June 2026 guidance places the duty on the manufacturer, importer or distributor placing the product on the market (Commission Notice C/2026/3084, section 18; SPI tracker record PR-EU-006). India starts on the shelf. Its share attaches to the brand owner of a rigid consumer pack, measured against what it sells each year (clause 7.4(b)(II)).

The definitions point the same way. India’s new rule 3(ub) defines reuse as using an object or resource material again, for the same or another purpose, without changing its structure (G.S.R. 237(E)). The PPWR’s recital 86 requires open or closed loop re-use systems, and recital 87 requires reconditioning before each reuse. In both systems a pack that is shredded and remoulded counts as recycling, not reuse, and a refill pouch that is thrown away after one use is single-use packaging.

Refill sits in a different box in each. The PPWR’s recital 89 calls refill a specific waste prevention measure that counts toward the prevention targets, and recital 90 asks operators that offer refill to protect consumer health and safety and to tell users how to refill safely. There is no refill quota for brand owners. India’s rules have no separate refill duty: a brand owner’s refilled rigid pack simply counts toward its clause 7.4(b) share, provided the structure is unchanged.

What the three companies report

SPI read each company’s latest own report for any reuse or refill figure and any named programme (Exhibit 2). The picture is thin. Only Colgate-Palmolive gives a reuse number, and it measures reusable or refillable packaging as a share of total packaging weight, a unit that neither the EU nor the Indian rule uses.

Two cautions apply. Colgate-Palmolive (India)’s release also reports 2,716 tonnes of waste reused in FY2025-26, but that figure belongs to waste diverted from its four plants, not to packaging placed on the market. And Henkel’s report gives two scopes for the same idea: page 18 says almost 100% of Consumer Brands packaging is designed for recycling or reuse, while page 50 reports 88% for the group, without reconciling them.

The direction of travel is clear in the targets. Henkel’s 2025 target was 100% of packaging designed for recycling or reusability; its 2030 target, set on 14 April 2026, is 100% designed for recycling and at least 35% recycled plastic in consumer packaging, excluding dangerous goods (report, pp. 21 and 28). Colgate-Palmolive’s 2025 target was all packaging recyclable, reusable or compostable; its 2030 target, restated by Colgate-Palmolive (India) on 28 July 2026, is to design all packaging for recycling and cut virgin plastic by 33% against 2019. Marico’s 2030 goals are 100% recyclable packaging and a 60% recycled share in non-food packaging (data book, p. 8). The scorecards for these goals are in SPI’s home and personal care piece and need no repeating here; what matters for this piece is that reuse has left all three companies’ headline metrics just as the law starts to count it.

The EU: reuse is a logistics duty

Exhibit 3 sets out the PPWR provisions that touch reuse and refill, and when each starts. The binding numbers are all in Article 29, and they start on 1 January 2030.

Three details matter most for a home and personal care manufacturer. First, sales packaging counts only when it has an evident transport function. The Commission’s guidance says plainly that “Only sales packaging with an evident transport function is covered by the re-use targets” (Notice, section 18), and SPI’s tracker record notes its examples: re-use is feasible for cereal drums, bulk bags and fruit crates, while paint buckets may be disproportionately costly (PR-EU-006). A litre of detergent in a bottle is not caught; the case it travels in is.

Second, imports count from the first warehouse in the Union, not from the factory gate abroad (Notice, section 19). A consignment for a single final destination need not be repacked, but distribution centres and logistics hubs are not final destinations (PR-EU-006). For a group that makes toothpaste outside the EU and ships it to an EU hub, the onward flows from that hub are in scope.

Third, the exemptions are narrow but relevant. Article 29(4) leaves out transport packaging for dangerous goods carried under Directive 2008/68/EC, and custom packaging for large-scale machinery, equipment and commodities (Notice, section 21). The Commission adopted in February 2026 a delegated act exempting operators that use pallet wrappings and straps from what its implementation page calls the 100% reuse targets (Green Forum). Henkel’s own 2030 recycled-content goal already excludes dangerous goods, a sign that part of its adhesive range ships under that regime; SPI has not yet confirmed what share of Henkel’s EU transport packaging would fall under the Article 29(4) exemption.

The refill provisions are softer. Recital 90 says operators offering refill must give users information on refilling safely and on using their own containers, and must not hand out packaging free of charge at refill stations outside a deposit and return system. The 10% sales-area goal for refill stations binds retailers, not brand owners, and only as an endeavour. Verpact, the Dutch producer organisation, describes it as an aim for end distributors with at least 400 square metres of sales area. Member States can go further: the Commission Notice lists Article 29 and Article 33(6) among the provisions that leave room for national measures (section 25), and recital 149 says Member States should actively encourage re-use and refill solutions. Spain already has national reuse targets for commercial and industrial packaging under Royal Decree 1055/2022 (PR-ES-002).

India: reuse is a pack-size duty

India’s duty is narrower in scope but nearer in time. Clause 7.4(b) of Schedule II to the Plastic Waste Management Rules, 2016, as substituted on 31 March 2026, applies only to brand owners using Category I rigid plastic packaging. It sets a minimum share of rigid packaging sold each year that must be reused, by pack size and, for large packs, by contents (G.S.R. 237(E)). The full table and its history are in SPI’s guide to the 2026 rules; Exhibit 4 turns it into the question a packaging team actually asks: which of my packs is caught, and at what share?

The table rewards small packs. Retail packs below 0.9 litres or kilograms, such as the 100 ml and 600 ml bottles in Exhibit 4, owe no reuse share at all. The duty begins where family packs and bulk packs begin, at 0.9 litres or kilograms, and it becomes heavy only for large drinking-water containers.

Three provisions decide how much a brand owner actually owes. The exemption in clause 7.4(b)(I) removes packs where a law, regulation, rule or mandatory standard does not permit reuse, and the brand owner must cite the barring provision in its annual return on the CPCB portal. The carry-forward lets a 2025-26 shortfall roll into the next three years, with at least one third cleared each year on top of that year’s share. And a proviso keeps the brand owner responsible for product quality, authenticity and mandatory standards when packs go round again (G.S.R. 237(E)).

What the notification does not say is how a reused pack is counted: once per refill trip, or once per unit placed on the market. SPI’s tracker record notes that the CPCB’s audit approach will decide the measure (PR-IN-003). Reuse also stacks with recycled content rather than replacing it: a returnable jar made of virgin resin still counts against the 40% Category I recycled-content share for 2026-27 (PR-IN-002). Penalties run through environmental compensation under clause 9 of Schedule II, and contraventions of the Rules can draw from INR 10,000 up to INR 15 lakh under section 15 of the Environment (Protection) Act as amended in 2023 (PR-IN-003).

A framework: the reuse duty map

Putting the two rulebooks side by side with what the companies run gives four positions (Exhibit 5). The axes are simple: does a binding reuse quota apply to this flow, and does the company publish a reuse programme for it?

Hidden duty. This is where all three companies sit for the flows the law will count. The duty is real and dated, but the company’s report says nothing about it, so a reader cannot tell whether the operation is close to the line or far from it. For Henkel and Colgate-Palmolive the hidden duty is logistic; for Marico it is a pack-size question.

Counted asset. No company in this set has a programme that it reports in the units of a binding quota. This is the position to aim for: a returnable crate pool or a returnable jar line that is already counted the way the Article 30(3) act or clause 7.4(b) will count it.

Voluntary refill. The programmes the companies name, Dial refill bottles, a salon refill bar, Softsoap’s at-home refill, sit here. They count as prevention under recital 89 in the EU and could count toward the Indian share only for rigid refill packs of 0.9 litres and above, which none of the named programmes is reported to use in India.

Watch list. National measures can move a format from here into the hidden-duty box. Member States may set reuse or refill requirements beyond Article 29 under the Regulation’s flexibility provisions, and large retailers’ refill-area goal will pull brand owners into retail refill systems through supplier terms rather than law.

Scenarios: what the EU transport target means in units

The 40% target is easy to state and hard to size, because the base is every transport pack an operator uses in the Union, and the own-site rule can bind harder than the headline. Exhibit 6 runs one illustrative operator through three readings. All figures are units, not money.

The high case is the one to notice. Once more than 40% of an operator’s transport packs move between its own sites or within one Member State, recital 95, not the 40% target, sets the floor. For a manufacturer with a large plant serving its home market, that can mean most of its pallets and crates. The low case shows how much the dangerous goods exemption can matter for a chemicals-heavy portfolio such as adhesives.

Scenarios: what India's share means in containers

India’s share is measured against sales, but compliance depends on how many containers come back. Exhibit 7 turns the row A share into units and then into containers in circulation under three assumptions about refill trips.

The spread between the low and high columns is a factor of six, and it comes entirely from a counting question the notification leaves open. Under a per-trip reading, a brand with a working refill channel needs a modest fleet. Under a per-unit reading, every reused pack must be a distinct container brought back and refilled, which for a household brand without a return channel is close to a new business.

What the fee schedules say about reuse

Reuse duties come with a quieter incentive: some EPR schemes charge reusable packaging little or nothing. Exhibit 8 shows the clearest case, Luxembourg’s Valorlux schedule for 2026, in one currency.

Two readings follow, both within one schedule. A reusable pack declared under PV00 pays EUR 0.0000 per kg against EUR 0.3058 for an HDPE bottle, so reuse removes the fee line for every trip. And a refill pouch in PE film pays EUR 0.7120 per kg, 2.33 times the HDPE rate by SPI’s calculation, so a single-use refill pouch saves fees only if it is much lighter than the bottle it replaces; Ledger 29 works through that break-even for Oregon and Colorado.

Other European schemes send similar signals in their own ways. SPI’s fee notes record a Verpact reuse tariff of EUR 0.015 per kg in the Netherlands in 2026, a Citeo brand-owner reuse contribution of 0.0140 euro cents a unit in France, with reuse reporting following in March 2027, and a Fost Plus accreditation for 2024 to 2028 that includes a 5% increase in reusable packaging. Fee levels across schemes are in EPR fees per tonne in 2026.

The disclosure gap

Exhibit 9 lists the numbers the two rulebooks will ask for and whether each company publishes them today. It is the clearest single view of the gap between refill as reported and reuse as regulated.

The gap is partly timing. The EU targets start in 2030 and the calculation act is not yet published, so no company can yet report in final EU units. But the Indian shares have applied since 2025-26, and returns for that year were due on 30 June 2026 (PR-IN-003). A brand owner that has filed a reuse figure with the CPCB already holds the number its investors would need.