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Refillable is a service, not a property

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The rule Which puts the claim outside the container So a screw-top bottle is not refillable for this purpose Two ways to earn the word The second is the ordinary route And our shelf is shaped for it Which is the only shelf in this library whose shape matches its use There is a deliberate pair with another property here One provision compels the word and the other restricts it Then there is a finding about our own catalog Which makes a blank indistinguishable from a negative Three of four leaves are not rigid containers either References

Unless the marketer provides the means for refilling the package.

The rule

It is deceptive to misrepresent, directly or by implication, that a package is refillable. And a marketer should not make an unqualified refillable claim unless the marketer provides the means for refilling the package.

Which puts the claim outside the container

Every other spine in this library is about what a package is or does. This one is about whether a service exists around it.

So a screw-top bottle is not refillable for this purpose

Anyone can unscrew it and pour something in. That is a physical fact and it is not what the word claims.

Two ways to earn the word

Provide a system for the collection and refill of the package, or offer for sale a product that consumers can purchase to refill the original package.

The second is the ordinary route

Sell the refill. Which is why a refill shelf has a small dispensing container and a large refill container, and ours does.

And our shelf is shaped for it

57 of 83 containers are under 120 mL and 26 are over 946 mL, with 29 at 59 mL and 13 at one US gallon. A bimodal distribution with an empty middle.

Which is the only shelf in this library whose shape matches its use

Most of them are a capacity window with a cluster in it. This one is two clusters, and the gap between them is the point.

There is a deliberate pair with another property here

The pet grooming property quotes 40 CFR 156.140, which REQUIRES a refillable container to bear the statement "Refillable Container." This section makes saying it deceptive unless you provide the means.

One provision compels the word and the other restricts it

Same word, two schemes, opposite pressure. Which is worth knowing before assuming a label term is either safe or required.

Then there is a finding about our own catalog

We publish a Recyclable specification on 803 rows and the value is Yes on all 803. There is no other value in the field anywhere.

Which makes a blank indistinguishable from a negative

And makes every one of those 803 an unqualified claim. It has its own section and it is a flag against our site rather than against a buyer.

Three of four leaves are not rigid containers either

A refill pouch, a concentrate pod and a tablet. Only bulk refill is something we sell.

References

16 CFR 260.14, "Refillable claims.": "It is deceptive to misrepresent, directly or by implication, that a package is refillable." The section continues: "A marketer should not make an unqualified refillable claim unless the marketer provides the means for refilling the package." And: "The marketer may either provide a system for the collection and refill of the package, or offer for sale a product that consumers can purchase to refill the original package." The section also gives two examples, which are described rather than quoted here. law.cornell.edu

The Davis Pack Supply catalog, measured 19 October 2026. A "Recyclable" specification is published on 803 rows catalog-wide and the value is "Yes" on all 803; there is no other value in the field anywhere. On this group's shelf it is present on 39 of the 83 containers, all of them Yes. So a blank cannot be distinguished from a negative, and a bare Yes is an unqualified recyclable claim. Nothing in our data says which programs or collection sites are available to anyone.

The Davis Pack Supply catalog, measured 19 October 2026. 307 rows: 83 containers and 224 closures. 5 to 3,785 mL with a median of 59, and the distribution is bimodal: 57 of the 83 containers are under 120 mL and 26 are over 946 mL, with 29 at 59 mL alone and 13 at 3,785 mL, which is one US gallon. 26 HDPE, 24 PP, 20 Glass and 13 PET, which is the most balanced material mix measured anywhere in this library. 44 jars, 26 bottles, 9 jugs, 3 tubs and pails, 1 tube. 14 glass boston rounds, 12 PET single wall jars, 9 PE F style bottles, 9 double wall round base jars, 7 PE industrial round bottles, 7 double wall straight base jars, 5 glass straight sided jars, and one twin neck bottle. 27 white, 13 natural, 13 clear, 11 black, 9 amber, 6 blue, 2 frosted, 2 green. Closures: 141 continuous thread polypropylene lids, 34 metal or aluminum CT caps, 15 dome lids, 7 sealing discs, 5 flip top caps, 5 phenolic, 4 round tub lids, 3 spouted caps, 2 plastic round pail lids. Buyability, a snapshot: 65 of 83 available, 17 not, 1 unrecorded; 20 quote only; 27 full case only.

Written from 16 CFR 260.12 and 260.14 and from the catalog as it stood on 19 October 2026. Our own Recyclable specification has exactly one value, Yes, on all 803 rows that carry it, which means a blank and a negative cannot be told apart and a bare Yes is an unqualified claim. Nothing here states whether any container is recyclable or whether programs are available anywhere. The Green Guides are guidance on claims and nothing on these pages describes the rest of them, nor state recycled-content or labeling statutes.