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Making beauty greener: refillable packaging solutions
Hi everybody,
Hope everybody is doing OK.
I would like to hear your opinions in this regard. Refilling pumps and jars with cosmetic products is very common in hotels and public centres, now some brands are also selling refills as a eco-friendly solution.
Definitely it reduces production costs, but how safe for consumers is this practice?
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15 Replies
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In my experience cleaning a used bottle or pump of lotion is almost impossible.
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Bulk refilling pumps is a problem. Don’t!!
There’s a bunch of reports of contamination - e.g. https://www.jstor.org/stable/26329181
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thank you
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I would check with your country’s cosmetics compliance authority. In our case I had our QC Manager do the checking with our local authorities and those of the destination countries of the brands we manufactured for, and in all cases, it was a no no.
The only option we had was if the brands we were manufacturing for returned the used containers to us and these were cleaned under our GMP conditions. And cleaning pumps was mission impossible, therefore pumps needed to be replaced.
And I question the eco-friendliness of this approach. Shipping empty containers back to us is not cost and carbon-free.
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Mike, can you say more re “no no”? Is this a regulation - is it local or national?
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It was “local” in Viet Nam and Malaysia (under the ASEAN Cosmetics Guidelines), and for the international brands we were manufacturing for. With the international brands, each product was Notified with the cosmetics regulation authorities of each destination country.
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Can you share the reg?
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There is no one regulation covering all countries. For example, under the ASEAN Cosmetics Guidelines combined with the terms/conditions of our GMP Licence, there is no capacity for refilling returned bottles. And at the same time, our QC Manager asked the question during our regular compliance inspections.
Similar applies to other countries.
The best approach is to raise the question with the regulatory authority in your own country.
And the reason I employed a QC Manager to sort out these issues. It is not a good idea to have bottle recycling raised and rejected during a GMP compliance inspection.
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We provided input drafting of ASEAN reg’s many years ago and don’t’ recall such a provision from that time. There is no such a reg in US.
Please - many of us work in a global context. If ASEAN has installed relevant reg’s, we’d certainly like to know. Could you please ask your QC guy for specifics?
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<div>Hi PhilGeis, within the ASEAN Cosmetics Guidelines there is no specific reference to the use of recycled containers. Which, in my opinion, is fair enough. Any container must comply with the GMP standards.</div><div>
As a company, we went into this in great detail. But at the end of the day, the cost to our brands of returning the used containers, our cost of cleaning to meet the cosmetics compliance requirements, plus the carbon costs, it was just not economically viable or environmentally friendly.
The other option was to supply local and international brands with bulk containers (we found 5 Kg the optimum size) where customer bottles could be refilled in-store. But again, the cosmetics compliance authorities, both local and international, had issues with this. There were two main objections: (1) in-bottle contamination of the customer-returned bottles being refilled and (2) contamination during the filling by in-store staff.
The academic paper you cited (https://www.mdpi.com/2079-9284/9/2/27) gives some insight into how these objections could be mitigated, but most of these are impractical.
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Thanks mike - agree, any bulk refill is high risk. What is the practice in public/group bathrooms?
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What do you mean by”What is the practice in public/group bathrooms?“
It’s not a term I’m familiar with.
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Here are a couple of articles addressing cosmetic refills. 1st two by academics so take with a grain of salt, last by regulators so expect stupid stuff.
https://www.sciencedirect.com/science/article/pii/S2667378922000360
https://www.emerald.com/insight/content/doi/10.1108/07363769810219134/full/html
https://www.mdpi.com/2079-9284/9/2/27
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I can’t provide too many details, but many of my clients are moving away from refillable products. Simply, the safety of your product relies upon the end user properly sanitizing the bottle and pump. Unfortunately, this is an area where there is low compliance. Some lines are moving towards cartridges and similar components. The expense of packaging is a barrier, so many of our lines have moved to components with other sustainability claims.
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Yes, I would agree. For the compliance efforts required, brands can leverage other areas to gain more brand traction and increase revenue.
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