Today is international Refill day, so we thought we’d chip in a little more on how refill and closed loop systems work in practice. 

Customer or Consumer?

There’s an important distinction between a customer and a consumer:

• A customer purchases a product, whether to own it or sell it on
• A consumer uses a product, hopefully only as directed!

We find that this really helps when we need to talk about closed loop and refill, because in some cases we sell to customers who will use our products and in others we sell to those who will re-sell our products. In that latter case, the consumer is the person that our customers sell to. This comes into play in the next section when we talk about the legal stuff.

Refill For Law Nerds

Now, we’re not lawyers and we’re definitely not your lawyers, but to us closed loop is fairly straightforward in law. In sum, we sell the product in clean regulation packaging with regulation labelling using safe and legal transport, and we can reuse empties that match up to those regulations when they go back out again. What is less straightforward is the concept of supply to people who aren’t the end point consumer of the products, but who will instead refill the consumers’ containers.

There are two major considerations here:

• The Classification, Labelling and Packaging of Chemicals Regulations (a.k.a. CLP) states that at the point of filling a container with any mixture for sale, however benign, it has to pass certain requirements for what’s on the label. This includes an accurate list of ingredients and accurate hazard diamonds.
• It is the responsibility of the person filling the container to ensure that the labelling complies with the law.

Normally, for an ordinary closed loop supply, we’d be responsible for all of that as we would do any refilling. But for FILL, we have to be extremely clear to the folks running refill stores in the UK that this is their responsibility, as they are safeguarding the public against houses full of mystery liquids in inappropriate bottles. We’re super keen for people to avoid plastic waste, but a random soft drink bottle isn’t safe or legal to refill with laundry liquid!

Not Just For Show

The FILL glass bottles are stylishly screen-printed and contain all the correct information for one simple reason: we can ensure that our customers who re-sell our products at refill stores have an easy time doing their legal duty to consumers. We looked at all kinds of solutions from labels to etching, and came to the conclusion that there wasn’t really any other way to deliver safe and effective labelling that complied with the law.

While a sticky label with ingredients printed on would probably have worked, this generated its own plastic and/or paper waste and came with the morally grey area of having to decide when a consumer would have to replace it. This spawned other questions as well, such as whether we just sell labels or, if the label is the important bit, how could we encourage people to use long-term reusable containers? In the end the idea of a low-plastic, refillable, easy-to-use, easy-to-look-at, well-formulated and genuinely eco-conscious product line needed its own identity if it was going to make even a drop in the ocean. And there was no way we were going to sell this in plastic bottles, not even reusable plastic. 

So the next time you see a FILL bottle, remember that it’s stylish by necessity, not just for looks.

Closed Loop: In The Factory

At our factory we make our products, package them into reusable containers, palletise and ship them. When our laundry customers are done with the contents, they return their 20 L and 200 L containers to us and we wash them in our dedicated facilities. The washed containers are inspected for quality control and placed back into stock for re-use. As for the 10 L, 20 L and 200 L containers of FILL products? Absolutely the same story!

We’ve only a slight variation on the theme for our FILL products that we sell through Milk & More, and that’s because of scale. We wash each and every 500 ml glass FILL bottle that comes back to us in our bottle wash station.