Refillable & Reusable Claims

A reusable claim does not meet FTC guidelines unless the packaging is meant to be refilled with the same product. To use an unqualified claim that a package is refillable or reusable:

  1. it must be able to be reused/refilled for its original purpose,
  2. it must have been designed with the intent to be reused/refilled, and
  3. there must be a system in place to collect and return the item, or facilities or products that allow consumers to reuse or refill the package in the market in which it is sold.

Special Requirements in Alameda County for Reusable Bags

In Alameda County, a law went into effect in 2013 that encourages the use of reusable bags instead of single-use plastic carryout bags that create litter and waste. This law specifies that reusable bags sold by retailers in the county must have—either printed on the bag or on a tag permanently affixed to the bag—the name of the manufacturer, the country where the bag was manufactured, a statement that the bag does not contain lead, cadmium, or any other heavy metal in toxic amounts, and the percentage of postconsumer recycled material used, if any.

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Labeling tips

  • DO qualify the claims to the extent necessary to avoid consumer deception about the limited ability to reuse or refill the item, and to inform consumers about the means provided for refilling/reusing the packaging.
  • DO ensure all claims are substantiated.
  • DON’T make an unqualified refillable/reusable claim unless you provide the means for refilling the package.


Example/Claim Right or Wrong? Why?

“This is a refillable container. Please bring it to ABC Corp. to have it refilled.”


This claim explains the means provided by the company for obtaining refills.

“This container will withstand being refilled at least three times.”


Assuming the manufacturer has established no collection program, this unqualified claim is deceptive, because of the lack of means to return the container to the manufacturer for refill.