Bulk retail and refill systems: The regulatory framework and sectoral guidance applicable in France

Rethink Plastic member ECOS and Réseau Vrac & Réemploi released a report on bulk retail and refills system in France.
This report builds on the French legal framework and on the sectoral guidance developed by Réseau Vrac & Réemploi. Its objective is to support the implementation of the Packaging and Packaging Waste Regulation (PPWR), in particular article 28 on obligations relating to refill systems, article 51 on measures promoting refill systems, and annex VI, Part C on requirements applicable to refill stations.

In France, bulk retail sales (referred to as “refill” under European terminology) constitute a retail distribution model for fast-moving consumer goods (FMCGs). They represent both a means of preventing packaging waste at source and a form of packaging reuse by consumers, while maintaining a high level of consumer protection, consumer information and product safety1. France
provides one of the most advanced regulatory frameworks in this field. Bulk retail sales are legally defined, consumers may use reusable containers under clear conditions, and retailers and suppliers have developed best practices covering hygiene, traceability, labelling and metrology. This report builds on the French legal framework and on the sectoral guidance developed by Réseau Vrac & Réemploi. Its objective is to support the implementation of the Packaging and Packaging Waste Regulation (PPWR)2, in particular article 28 on obligations relating to refill systems, article 51 on measures promoting refill systems, and annex VI, Part C on requirements applicable to refill stations.

Key findings

• Bulk retail systems can be regulated as robust reuse models without compromising consumer protection rules.
• The absence of primary packaging requires adapted point-of-sale information, not a reduction in information provided to consumers.
• Consumers’ right to use their own reusable containers can be combined with clear responsibilities regarding information on hygiene and suitability requirements.
• Metrology rules are essential: consumers must be able to choose the quantity purchased and must not pay for the weight of their container.
• Suppliers and retailers require a clear allocation of responsibilities to ensure product safety and traceability.
• Implementation of the PPWR should promote a harmonised and proportionate approach rather than fragmented national solutions.

Although the recommendations set out in this document primarily concern bulk retail sales, many of them are equally relevant to takeaway food services where consumers use their own containers or reusable containers provided by the food business operator. Principles relating to consumer information, hygiene requirements, the allocation of responsibilities between operators and consumers, the acceptance of reusable containers, traceability, and product safety represent good practices that can be applied to the HORECA sector and support the consistent implementation of the PPWR provisions on refill systems.
The main policy recommendation is therefore straightforward: the PPWR implementation framework should treat bulk retail and refill systems as a central pillar of packaging waste prevention and reuse, supported by practical EU-level guidance that is sufficiently clear for retailers, suppliers, enforcement authorities and consumers.