John Twitchen FCIWM, founder of Stuff4Life and Chair of CIWM’s Producer Responsibility Sector Expert Group, uncovers how EPR is having the unintended consequence of driving investment into commercial reuse and refill iniatives.
In October, the British Retail Consortium published research that showed over 80% of retailers plan to pass on the cost of the new packaging Extended Producer Responsibility (EPR) to consumers.
This led many to question if packaging EPR charges are set to just become ‘another inflationary pressure’ or is this the time of maximum opportunity? Or, to put it another way, what are the positive and/or unintended consequences for innovation and better consumer value for money, which reduce the cost on society?
Back to the future
The CIWM Presidential Report I authored in 2017, ‘Digital Technology and Consumer Trends’, for then President Professor Margaret Bates (who is now head of the pEPR Scheme Administrator) outlined growing evidence that UK packaging rules and the prospect of Deposit Return Schemes (DRS) – although at the time all talk of this was hushed – were creating unintended consequences shaping business behaviour.
Rising compliance costs, uncertainty over scheme design, and operational burdens were prompting retailers and brands to explore alternatives to conventional single-use systems – with an unintended consequence of driving some producers to using flexible, composite packaging and away from 100% recyclable materials.
This uncertainty, however, accelerated interest and investment in refill and reuse trials across grocery, personal care and online retail.
While several pilots showed strong consumer engagement and real potential for packaging reduction, inconsistent funding, operational complexity and policy delays continued to limit scalability. Overall, policy pressure was potentially driving innovation, but uncertainty undermined market adoption.
My report predicted that refill initiatives were likely to grow as the likelihood of EPR and DRS became unavoidable, pushing retailers to redesign packaging strategies. The most viable growth was predicted to come from automated, pre-filled or closed-loop models integrated into existing retail operations.
However, widespread adoption was predicted to depend on stable policy signals, shared infrastructure and consumer-friendly convenience.
And here we are now, eight short years, one pandemic and five Prime Ministers later.
Scio nescio: I know that I know nothing
There’s clear, documented evidence that the UK’s move to packaging EPR and the planned DRS is already changing behaviour – sometimes in unintended ways – including accelerating commercial interest and investment in reuse and refill models.
The UK EPR consultation and government analysis explicitly recorded respondents’ concerns about unintended consequences, such as loopholes, cost shifts, market complexity.
Written submissions to Parliament from industry representatives point to specific risks, like glass return bottlenecks, material substitution, DRS complexity, and also describe industry interest in alternative approaches, such as reuse and refill to manage risk.
Meanwhile, research has identified logistical problems, like collection/return, sorting capacity, for some materials that could reduce the practical effectiveness of DRS. A commercial response is to trial refill/reuse models to avoid or simplify returns.
Despite the UK EPR system currently lacking specific binding reuse targets like those proposed in the EU’s packaging regulations, WRAP and other bodies have published guidance and case studies specifically about mainstreaming refill and increasing citizen participation.
Meanwhile, retailers and industry groups are running trials to scale refill and reuse, projects framed as ways to reduce exposure to EPR/DRS costs and complexity.
And surely that’s the point – shifting to using less stuff. Scope 4 is the new cool!
Big retailers commit to reuse and refill
In 2025, nine major UK grocery retailers signed a joint Statement of Intent to explore reuse, and multiple retailers have run refill pilots – a market response consistent with firms hedging regulatory risk and seeking to avoid paying higher EPR and DRS costs.
Sector analyses have warned of perverse outcomes – for example, deposit designs encouraging smaller single-use containers, or material substitutions increasing environmental harm – which in turn push producers and/or retailers to consider packaging redesign, refill or reuse as mitigation.
And investors (e.g. Closed Loop Partners) have backed reuse/refill enterprises internationally, with those business cases informing UK pilots and commercial interest.
The future is bright
Here are eight UK refill and reuse pilots which demonstrate action by retailers and brands to test systems and products, customer engagement and service development.
|
Who |
What |
Outcome |
|
1. Ocado — online reusable packaging pilot (Aug 2024) |
Two-phase online scheme (reusable vessels for staples, such as rice and pasta) run with the UK Refill Coalition, designed specifically for home delivery. |
Launched as the first major online grocer pilot and progressed to phase-two trials – positioned as an ongoing test rather than a full roll-out. |
|
2. Tesco x Loop — in-store reusable packaging trial (Sept 2021 — reflections 2022) |
Loop reusable container system in ten Tesco stores (customers bought products in durable containers and returned them to store). |
Strong initial customer interest and operational learning; Tesco published lessons from the trial but the wider Loop model struggled to scale in the UK. |
|
3. Unilever — refill trials including Asda Leeds (2020-2021) |
‘Return on the go’ and in-store refill trials (laundry/personal care brands) including a large Leeds refill zone. |
Uptake exceeded expectations in Leeds (weekly purchases of refill products outperformed packaged equivalents), prompting expanded trials — positive commercial signal. |
|
4. Asda — Middleton/Leeds sustainability concept store (2020-2024) |
Sustainability store with c.15 refill stations offering dozens of staples (2020 pilot). |
Early trials showed customer interest but Asda scrapped or refocused refill store trials citing commercial/operational challenges (announced 2024). |
|
5. Waitrose ‘Unpacked’ refill shops (2019-2022) |
Waitrose trialled ‘Unpacked’ refill shops across multiple locations offering loose goods and refill options. |
Reported sales growth (c. 9% uplift in refillables in an early period); later ended specific Unpacked pilots, noting learnings and planning further initiatives. |
|
6. Co-op x Unilever — convenience format refill trials (2021) |
Co-op worked with Unilever on small-format refill pilots in convenience stores to study consumer behaviour. |
Pilots ran to test convenience-store dynamics; Co-op has continued targeted recycling/reuse trials (+ other returns trials e.g. coffee-pod collection). |
|
7. Aldi x Refill Coalition trials (2023-2025) |
Refill Coalition pilots (own-container dispensers in stores, with Aldi hosting trials in Solihull and Leamington Spa). |
Trials demonstrated operational feasibility and customer interest, but Innovate UK funding withdrawal led to schemes being wound down in 2025. |
|
8. Sector-level efforts and coalition activity — mixed longevity (2021-2025) |
UK Refill Coalition and industry collaborations launched multi-retailer trials and projects (including a planned ‘world’s biggest’ multi-retailer trial). |
Delivered significant learning and some successful short-term uptake; coalition funding/scale constraints meant several initiatives wound down by 2025 — showed pilots are hard to scale without long-term investment. |
Government efforts
Despite the disappointing news that the Circular Economy Taskforce report has been delayed until 2026, and with nothing forthcoming on the long-promised EPR roadmaps for textiles, batteries and e-waste, the UK Government has issued an update to the Environmental Improvement Plan, which includes interim 2030 waste reduction targets.
The Act states that by 31 December 2042, the total mass of residual waste (excluding major mineral waste) ‘must not exceed 287kg per capita’ (c. 50% reduction from 2019 levels).
The November 2025 update sets out new interim targets that must be met by December 2030, including reducing residual municipal waste to ≤ 333kg per capita (c. 29% reduction), including specific targets for plastic waste (≤ 42kg, c.45% reduction) and glass (≤ 7kg, c. 48%).
Achieving this level of reduction is going to need significant change rather than just tinkering. However, because the targets are for residual waste left over after recycling, they don’t target true, substantial and meaningful waste prevention – they can be achieved by more recycling, which can, of course, lead to negative unintended consequences set out above.
What does this all mean?
Policy design risks – scope, deposit levels, materials included – create uncertainty and operational burdens for producers/retailers, who respond by testing alternatives such as refill, reuse, and packaging redesign.
Investor signals (retailer statements, WRAP guidance, external investments) show real commercial momentum behind refill/reuse, both as a sustainability strategy and as a hedge against EPR/DRS costs.
The many UK reuse and refill trials (examples listed in the table) show companies reacting ahead of full policy implementation by testing alternative models to reduce packaging and minimise future exposure.
Practical bottlenecks, such as collection, sorting, capacity, make DRS and large-scale recycling harder in the short term, encouraging pilots of refill systems that avoid takeback infrastructure.
These are examples of largely ‘unintended consequences’ in the sense that the policy isn’t just increasing recycling but is shifting business strategy towards reuse/refill – a welcome side-effect… as predicted.
And because reuse and refill models carry different costs and operational structures (return logistics, cleaning/refilling, consumer behaviour changes, stickier customers), their growth can become a new area of investment, innovation and infrastructure – an indirect effect of EPR and DRS policy.
In practical terms, more reuse/refill schemes mean the UK will import less stuff, and instead create economic activity – jobs and servitisation opportunities – in the domestic market, paying UK tax.
On the back of both my 2017 report and last year’s ‘EPR of everything, starting with batteries’ it shows that the role of the simple, humble measures like the right to refill and right to repair could have substantial impacts not just on the amount (and nature) of residual waste, but – much more importantly – on consumer and taxpayer value for money.
So the polar opposite of ‘another inflationary pressure’.
John Twitchen FCIWM is the founder of circular economy disruptor Stuff4Life and author of two reports for CIWM, ‘Digital Technology and Consumer Trends’ (Margaret Bates) and ‘EPR of Everything… Starting With Batteries’. John also chairs the CIWM’s Producer Responsibility Sector Expert Group.
