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

> The EU's binding reuse targets fall from 1 January 2030 on transport packaging (40%) and grouped packaging (10%), not on the detergent, soap and toothpaste packs these companies refill, while India's reuse shares already bind brand owners of rigid plastic packs from 0.9 litres or kilograms, at 15% in 2026-27; none of the three publishes a reuse figure in the units either rulebook tests.

Publisher: Strategic Packaging Insights  
Published: 2026-10-29  
Last updated: 2026-10-29  
Page: https://www.strategicpackaginginsights.com/insights/refill-reuse-henkel-colgate-marico-eu-india-duties/

**The EU's binding reuse targets fall from 1 January 2030 on transport packaging (40%) and grouped packaging (10%), not on the detergent, soap and toothpaste packs these companies refill, while India's reuse shares already bind brand owners of rigid plastic packs from 0.9 litres or kilograms, at 15% in 2026-27; none of the three publishes a reuse figure in the units either rulebook tests.**

Strategic Packaging Insights (SPI) read the reuse and refill provisions of Regulation (EU) 2025/40 and of India's G.S.R. 237(E) of 31 March 2026 against the latest reports of three home and personal care companies. Their refill offers are real but small and voluntary, and the packs the law counts, such as pallets, crates, drums and one-litre jars, are the ones their reports do not describe.

## Executive summary

Refill is the part of packaging strategy that home and personal care companies talk about most and measure least. Henkel names refill bottles for Dial hand soap and a refill bar for salons. Colgate-Palmolive runs a Softsoap refill business and reports that 1.1% of its packaging by weight is reusable or refillable. Marico publishes no reuse figure at all. Yet two rulebooks now write reuse into law, and neither is aimed at the formats these programmes use.

The EU's Packaging and Packaging Waste Regulation (PPWR) has applied since 12 August 2026. Its Article 29 sets binding reuse targets from 1 January 2030: 40% for transport packaging, 10% for grouped packaging and 10% for beverages offered by final distributors (Exhibit 1). Refill of sales packs is treated as waste prevention, with information and hygiene duties but no quota. India's clause 7.4(b), recast on 31 March 2026, goes the other way: it puts a reuse share on the brand owner's own rigid packs, by size, and it is already running.

The result is a mismatch. For Henkel and Colgate-Palmolive, the EU duty sits in the logistics chain: pallets, crates, drums and intermediate bulk containers, including flows between their own sites, which recital 95 says should use only reusable transport packaging. For Marico, the Indian duty reaches Category I rigid packs of 0.9 litres or kilograms and above, at 15% this year and 25% from 2028-29, while its retail hair-oil bottles below 0.9 litres fall outside every row.

None of the three companies publishes the numbers that would show where it stands: no reusable transport packaging share, no reuse share by Indian row, no exemption basis (Exhibit 9). Their 2030 goals have also moved away from reuse. Henkel's 2025 goal counted packaging "designed for recycling or reusability"; its 2030 goal counts design for recycling only.

For leaders, three moves follow. Map transport packaging flows now, because the Commission's calculation rules are due by 30 June 2027 and the targets apply from 1 January 2030. Band every Indian rigid SKU by row before the 2027-28 shares apply on 1 April 2027. And report reuse in the rulebooks' own units, not as a share of portfolio weight.

## Key findings

1. The PPWR's binding reuse targets apply from 1 January 2030 to transport packaging (40%), grouped packaging (10%) and beverages made available by final distributors (10%); sales packs of detergent, soap or toothpaste carry no reuse quota (Regulation (EU) 2025/40, Article 29; Commission Notice C/2026/3084).
2. India's clause 7.4(b) binds brand owners of Category I rigid plastic packs from 0.9 litres or kilograms: 15% in 2026-27, 20% in 2027-28 and 25% from 2028-29 for packs under 4.9, and 75% rising to 85% for large drinking-water packs (G.S.R. 237(E), 31 March 2026).
3. Colgate-Palmolive's reusable or refillable share was 1.1% of packaging by weight at the end of both 2024 and 2025, against 96% recyclable, reusable or compostable in 2025 (company reports).
4. Henkel's Sustainable Impact Report 2025 gives 88% of packaging designed for recycling or reusability, and its 2030 goal of 100% designed for recycling drops reuse from the measure (report, pp. 21 and 50).
5. Marico's ESG Data Book for FY 2025-26 reports 26,306.87 tonnes of plastic packaging and 28,013 tonnes managed under EPR, but no reuse share for its rigid packs (data book, pp. 9 and 12).
6. **SPI calculation:**  for every 1,000,000 Category I packs of 0.9 to under 4.9 litres a brand owner sells in India in 2027-28, 200,000 must be reused; at three refill trips a container a year, that means about 66,667 containers in circulation (Exhibit 7).

## 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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.

SPI analysis

The difference decides who in a company owns the problem. In the EU it is the logistics and procurement team that buys pallets, crates and drums. In India it is the brand and packaging team that sets pack sizes. A refill programme run by the marketing team can be a success on its own terms and still count for nothing under either law.

## 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](https://www.strategicpackaginginsights.com/insights/home-personal-care-packaging-colgate-henkel-reckitt-kimberly-clark/) 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/)).

SPI analysis

For a brand owner, the 2030 exposure is a pallet and crate problem before it is a refill problem. The stricter rule is the one in recital 95, because a group with plants and warehouses in one Member State moves much of its freight between its own sites, and those flows are expected to use only reusable formats. The [PPWR after August 2026 piece](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) covers the rest of the Regulation's calendar.

In practice: Henkel.

Henkel is headquartered in Düsseldorf and registers its household packaging in Germany's LUCID register under [PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/), according to its SPI profile, which links its B2B adhesive shipments to [PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/). Its Sustainable Impact Report 2025 describes refill in general terms, saying it provides products designed for efficient resource use or refillable packaging intended for reuse (p. 49), and credits compact laundry formats with saving 1,300 tons of plastic and 4,000 tons of CO2 from transportation a year, in the report's units, partly because smaller bottles fit more cases on each pallet (p. 44). Its packaging page cites the donation of 130,000 lbs of used and broken pallets. Its February 2026 interpack release presents adhesives and coatings that support PPWR recyclability. None of these sources gives a reusable share of transport packaging, a pallet pool or a count of returnable drums or intermediate bulk containers, the units Article 29 will measure.

## 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](https://www.strategicpackaginginsights.com/insights/india-plastic-packaging-rules-2026/); 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/)).

In practice: Marico.

Marico's ESG Data Book for FY 2025-26 reports 26,306.87 tonnes of plastic packaging, 95% of packaging recyclable, 32.2% recycled content in the non-edible portfolio and 28,013 tonnes of post-consumer plastic recycled or disposed under the EPR guidelines (pp. 9 and 12); its BRSR for FY26 lists EPR compliance at 100%. Its SPI profile places Parachute and hair-oil bottles among the rigid packs facing [PR-IN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/) and notes that Saffola edible oil and food packs remain bound by food-contact limits. Neither the data book, the BRSR pages SPI read nor the circular economy page gives a reuse share, a split of rigid packs by size, or any exemption Marico relies on. SPI has not yet confirmed what share of Marico's rigid tonnage sits at 0.9 litres or kilograms and above, or whether an FSSAI provision bars reuse of its edible-oil containers; if one does, those packs drop out of the base once the provision is cited in the return.

In practice: Colgate-Palmolive (India).

Colgate-Palmolive (India) Limited said on 28 July 2026 that 100% of the toothpaste it makes in India is now in recyclable tubes, that 95% of its packaging is recyclable, reusable or compostable, and that it maintained 101% plastic waste neutrality under India's EPR framework in FY2025-26. Its SPI profile links it to [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/) and [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/) but not to the reuse rule, and tubes and toothbrush packs are not Category I rigid packs of 0.9 litres or more. SPI has not yet confirmed whether any of its Indian packs reaches the 0.9 litre threshold; if none does, clause 7.4(b) asks nothing of it beyond reporting rigid sales.

## 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.

SPI analysis

The map suggests a simple order of work. Move the hidden duties into counted assets first, because they carry dates and penalties. Treat voluntary refill as a brand and prevention tool, and stop presenting it as the company's answer to reuse law, because the law counts different packs.

## 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.

SPI analysis

The scenario also shows why the calculation act matters. Recital 98 bases the calculation on quantities made available, by sales units or by weight or volume, and recital 94 allows transport packaging to be counted by number of uses. If the June 2027 act counts uses, a crate that makes 20 trips a year carries more weight than 20 single-use cartons, and the reusable fleet needed could be far smaller than the unit counts in Exhibit 6. Operators should hold their flow data in both units until the act is published.

## 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.

SPI analysis

For most brand owners the cheapest route is to shrink the base before building the channel. Packs that a mandatory standard bars from reuse leave the base once the provision is cited, and a pack resized from 1 litre to 850 ml leaves row A altogether. Neither is a reason to avoid reuse, but both should be decided before a company invests in collection for packs that may not count. Clause 10.5 of the 2022 Guidelines already allows deposit-return and buy-back schemes for separate collection, which can feed refill volumes ([PR-IN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/)).

## 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](https://www.strategicpackaginginsights.com/insights/home-personal-care-packaging-colgate-henkel-reckitt-kimberly-clark/) 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](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/).

SPI analysis

The fee gain from reuse is real but small next to the cost of running a return system, because Valorlux's plastic lines run from EUR 0.2498 to EUR 1.7580 per kg. The stronger case for reuse in Europe is regulatory: from 2030 the transport and grouped targets apply whatever the fee. In India, where EPR is met through certificates rather than per-kilogram fees, the reuse share is a duty in its own right.

## Industry reaction

The European Commission's [guidance on Regulation (EU) 2025/40](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), Commission Notice C/2026/3084 of 10 June 2026, says in section 19 that the targets apply from the first warehouse located within the Union, a rule for transport packaging in international trade that brings imported consumer goods into the 40% base once they reach an EU warehouse.

> "Refill should be understood as a specific waste prevention measure that counts towards, and is necessary for, meeting the prevention targets set out in this Regulation."

***European Parliament and Council** , legislators, [Regulation (EU) 2025/40, recital 89](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), 22 January 2025*

The recital frames refill as prevention, which is why the Regulation sets duties of care for refill but no refill quota for brand owners.

Henkel's [Sustainable Impact Report 2025](https://www.henkel.com/resource/blob/2147522/8941c6fb4e08be9facee9fd4ee20ae64/data/sustainable-impact-report-2025-en.pdf), published on 14 April 2026, describes refill in one clause on page 49: it provides products designed for efficient resource use or refillable packaging intended for reuse, with no reuse share attached.

> "1.1% of our packaging by weight is reusable or refillable."

***Colgate-Palmolive** , brand owner, [2025 Sustainability & Social Impact Report](https://www.colgatepalmolive.com/content/dam/cp-sites-aem/corporate/corporate/common/pdf/cp-2025-ssi-report.pdf), eliminate plastic waste section, 30 June 2026*

Colgate-Palmolive's 2024 report gave the same 1.1% as of 31 December 2024, and described its Softsoap at-home refill business, which lets consumers refill smaller containers.

## 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](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/)). A brand owner that has filed a reuse figure with the CPCB already holds the number its investors would need.

## What leaders should do now

1. **EU logistics and procurement leads, by 30 June 2027:**  map every transport and grouped packaging flow by route (own sites, one Member State, intra-EU, imports from the first EU warehouse) and by format, in units and in uses, so the operation can be scored the day the Article 30(3) act is published.
2. **EU compliance teams, by 31 December 2026:**  list the flows that may fall under the Article 29(4) exemptions, dangerous goods and custom packaging for large machinery, and the pallet wrapping and strap act, and document the basis for each.
3. **India packaging and brand teams, before 1 April 2027:**  band every Category I rigid SKU into row A, B or C or no row by declared volume or weight and contents, and record any FSSAI, CDSCO or other provision that bars reuse.
4. **India sustainability leads, before the 30 June 2027 return:**  decide how reuse will be counted and evidenced, per trip or per unit, keep wash and refill logs by row, and plan to clear at least one third of any 2025-26 shortfall in 2026-27.
5. **Pack designers, at the next range review:**  test whether packs just above 0.9 litres or kilograms should stay there, and if they stay, design them for return and refill without structural change, as rule 3(ub) requires.
6. **Sustainability reporting teams, for the 2026 report cycle:**  publish reuse in the rulebooks' units, reusable transport share and Indian row shares, alongside any portfolio share by weight.
7. **Sales teams serving large EU retailers, during 2027 contract talks:**  ask how each customer plans to meet the 10% refill-area goal and the beverage target, and which of your ranges it expects in refill systems.

## Questions for your board

- Which of our EU flows will Article 29 count, and how many pallets, crates and drums move between our own sites today?
- Do our refill programmes count toward any binding reuse duty, or only toward our brand story?
- How many of our Indian rigid SKUs sit at 0.9 litres or kilograms and above, and what reuse share did we report for 2025-26?
- Which of our packs rely on a mandatory standard that bars reuse, and have we cited it in the return?
- Why did reuse drop out of our 2030 packaging goals, and should it come back in statutory units?
- Who owns reuse: logistics, packaging or marketing?

## What to watch

- **12 Feb 2027:**  Commission guidelines on the beverages covered by the reuse targets (Article 29(8)), the delegated act on minimum rotations for reusable packaging (Article 11(2)) and the European Observatory on Re-use (Article 31(7)) are due.
- **1 Apr 2027:**  India's 2027-28 reuse shares apply: 20% for row A, 80% for row B and 15% for row C ([PR-IN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/)).
- **30 Jun 2027:**  the Commission's implementing act on calculating the reuse targets is due (Article 30(3)), and Indian annual returns for 2026-27 fall due on the CPCB portal.
- **1 Apr 2028:**  India's final shares apply: 25%, 85% and 15%.
- **31 Mar 2029:**  the last year to clear a carried-forward 2025-26 reuse shortfall ends.
- **1 Jan 2030:**  EU reuse targets apply: 40% transport, 10% grouped and 10% beverages, with retailers' refill-area goal ([PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/)).

## Methodology

- **Data used:**  SPI Regulation Tracker rule notes [PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/) and [PR-IN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/), with [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/), [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/) and [PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/); SPI Packaging Buyers Database profiles for Henkel, Colgate-Palmolive and Marico, written 14 October 2026; and the primary sources in the list below, consulted 29 October 2026.
- **Rule text:**  EU provisions are taken from the recitals of Regulation (EU) 2025/40 in the Official Journal and from the article text as reproduced in Commission Notice C/2026/3084 and the Commission's implementation page. Points the Notice does not reproduce, namely the grouped packaging target, the Article 29(7) and (8) beverage provisions, the Article 30(3) act and its 30 June 2027 date, Article 11(2) and Article 31(7), are taken from the unofficial German text of the Regulation published by LX Gesetze; SPI has not yet confirmed them against the article text in the Official Journal. India's rules are from G.S.R. 237(E) of 31 March 2026. Paraphrases are SPI's reading.
- **Company figures:**  each company's own latest report or page, in its own scope and year. Figures are not compared across companies.
- **Calculations:**  Exhibits 6 and 7 are SPI calculations on stated, illustrative assumptions, in units only. Exhibit 8 ratios are within one EUR schedule. No currencies are added, averaged or ranked.
- **Cut-off:**  29 October 2026.
- **Limitations:**  the EU calculation rules and minimum-rotation act are not yet adopted, and India's counting method for reuse is not stated in the notification, so the scenarios bracket readings rather than predict them. Absence of a figure in a company's report does not mean the company does not hold it. This is SPI analysis, not legal advice; check with counsel.

## Sources

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