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To: Food and Drug Administration - Philippines

Mainstream Refilling

Mainstream Refilling

We call on the Food and Drug Administration to help save our seas from single-use plastic waste by enhancing existing regulations in order to establish safe, widely accessible refilling stations for cosmetics and household products through the following:

1. Redefining refilling as an activity separate from manufacturing
2. Defining refilling stations and their safety and sanitary requirements
3. Defining the minimum information that needs to be shown on refilled product labels and refilling stations

Join our push for safe, sustainable, widely accessible refilling stations of daily household and cosmetics products!

Why is this important?

A five-year waste audit by the Global Alliance for Incinerator Alternatives (GAIA) estimates the Philippines throws away 163 million sachets everyday. 79% of “branded” plastic waste comes from food packaging, 12% from household and 8% from personal care products.

Plastics can remain for 2,000 years or longer in our natural environment. If we continue business as usual, by 2050 there could be more plastic than fish in the sea by weight. Because it is produced from petroleum-based chemicals, it could account for one-fifth of the world’s total oil consumption, further accelerating global warming and deadly climate change.

Government policy can be a decisive driving force for widespread transformation. The FDA Philippines safeguards public health by ensuring the safety and efficacy of food, medicine, household and cosmetics products. With the support of key government agencies such as the Environmental Management Bureau and the Department of Trade and Industry, the FDA is in a unique and powerful position to influence and transform the usage of plastic at the source through the thousands of brands it regulates.

We envision that the presence of safe, appropriately regulated cosmetics and home care refilling stations that are as accessible as water refilling stations will spark a radical change in the way people and organizations consume goods and manage plastic waste. An Illinois case study showed that a single mobile water refilling station saved the equivalent of 99,000 12-ounce plastic bottles a year.

In order for this transformation to take place, we raise the following three opportunities to enhance the implementing rules and regulations of Republic Act No. 9711 - The Food and Drug Administration Act of 2009:

FIRST: Instead of classifying refilling activities under “filling”, a manufacturing activity under AO 2016-0003 (Guidelines on the Unified Licensing Requirements and Procedures of the FDA) and Good Manufacturing Practices, we propose that a new, separate classification be developed such as “Refilling/Repacking Stations” within a retail outlet similar to how RONPD (Retail Outlets for Non-Prescription Drugs) were developed.

SECOND: To fulfill the FDA requirement of protecting consumers’ health, we propose these Refilling/Repacking Station requirements:
1. Business permit
2. Sanitary permit
3. Products (cosmetics and household) for refilling must be FDA-notified
4. Authorized refilling representative trained and certified by the company to conduct safe and sanitary refilling (patterned after food establishments’ safety compliance officer) and not necessarily a pharmacist or a graduate of an allied science profession.
5. Refilling procedures to ensure the safety of refilling
6. Flat rate fee for the refilling License to Operate similar to government agencies such as Bureau of Animal Industry (BAI) and Philippine Drug Enforcement Agency (PDEA), and not based on business capital.

THIRD: If the packaging to be used is the emptied product bottle, the minimum mandatory information is already in the label. The Batch No. and Expiration Date will be
stamped on the label for every refill.

If the packaging to be refilled will be different from the emptied product bottle, the existing minimum mandatory requirement should be displayed on the Refilling/Repacking Stations for the consumers’ information. We propose that the following be stamped/stickered on the label for every refill:
1. Product Name
2. Batch No.
3. Expiration Date
4. Special precautions to be observed (if applicable)

With this proposal, we seek to bridge the policy gaps and promote a sea change in the way responsible Filipino companies and ordinary citizens use plastics - not just temporary measures, but permanent and lasting policies, structures and systems. We hope to prepare the way for more brands to become better stewards of our earth and of human health.

Join our push for safe, sustainable, widely accessible refilling stations of daily household and cosmetics products!

Read the full text of the petition at bit.ly/mainstreamrefilling-pdf

Signed:

Anna Oposa, Co-founder & Executive Director, Save the Philippine Seas
Anna Meloto-Wilk, Co-founder & President, Human Nature (Gandang Kalikasan Inc.)
Sonia S. Mendoza, Chairman, Mother Earth Foundation
Joel Palma, President/CEO, WWF Philippines
Abigail Lois P. Aguilar, Campaigner, Greenpeace Southeast Asia-Philippines
Dr. AA Yaptinchay, Executive Director, Marine Wildlife Watch of the Philippines
Froilan Grate, Executive Director, GAIA Philippines/President, Mother Earth Foundation
Sef Alba Carandang, Trustee & Vice President for Community Development, Philippine Reef
and Rainforest Conservation Foundation, Inc.
Gregg Yan, Founder & Director, Best Alternatives Campaign
Angelica Mata, Founder, Zero Waste Filipina
Bryan Madera, Founder, Plastic Battle
Jennifer Horn, Founder, MUNI Cultural Creatives, Inc.
Bryan McClelland, Founder, Bambike (Bamb Ecological Technologies, Inc.)
Melissa Yeung-Yap, Founder, Got Heart Foundation, Inc.
Jose Dante Albao, Executive Director, Sea Waste Education to Eradicate Plastics
Binggirl Clemente, President, LAHAT Community Empowerment, Inc.
Rodne Galicha, Country Manager, Climate Reality Project


Reasons for signing

  • We need less plastics!
  • I am truly surprised when I saw this. The idea of repacking and refilling has been in my mind for the whole time and finally, someone decided to allow the same thought to be shared. I'm looking forward to this movement :)
  • I was amazed with their products

Updates

2019-04-10 18:42:54 +0800

5,000 signatures reached

2019-03-31 12:27:19 +0800

1,000 signatures reached

2019-03-30 12:31:09 +0800

500 signatures reached

2019-03-29 17:27:11 +0800

100 signatures reached

2019-03-29 16:08:10 +0800

50 signatures reached

2019-03-29 15:44:34 +0800

25 signatures reached

2019-03-29 14:22:05 +0800

10 signatures reached