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AgVetLink: Number 56, June 2006

To Fill Or Not To Fill (reusing plastic containers

The ACVM Group is aware of an initiative to manage wastes from used plastic containers by:

• recycling agricultural compound product containers (i.e. using the plastic in old containers to manufacture new plastic products); or

• reusing the containers (refilling old containers with the same or a different product).

The ACVM Group supports the intention to manage wastes. However, we wish to point out that there are significant risks associated with refilling used containers because the assessments of the product and the risk management conditions are no longer valid when a product is refilled into old or different containers.

A few registrants have developed reliable systems to minimise the risks associated with refilling. Those systems have been assessed and approved during their product registration. The ACVM Group accepts that refilling can be done safely, but only if significant planning and administration of distribution systems are used. Any party considering refilling as a means of managing wastes from old plastic containers should contact the ACVM Group early on in their planning.

In fact, unless there have been specific arrangements that will allow refilling old containers under controlled conditions approved as part of the registration process, refilling into the same container or a different container results in unregistered products. Sale or use of unregistered products is an offence under the ACVM Act and a person may be liable to a fine of up to $30,000 (or $150,000 for a corporation).