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Navigating Overpackaging in China: the State, Consumer Perceptions and Regulatory Landscape

The problem with overpackaging in China has become a pressing concern across various industries, and beyond the ecological level. This article aims to shed light on the development status of overpackaging in China, exploring consumer perceptions and attitudes towards excessive packaging, and examining the regulatory framework established to tackle this issue.

In today's consumer-driven society, the pervasive issue of excessive packaging has become a pressing concern across various industries. China, as one of the world's largest producers and consumers, faces significant challenges in addressing the environmental impact of overpackaging. This article aims to shed light on the development status of overpackaging in China, exploring consumer perceptions and attitudes towards excessive packaging, and examining the regulatory framework established to tackle this issue.

The Problem with Overpackaging in China 

Excessive packaging/overpackaging refers to the use of materials and resources in the product packaging process that exceed the actual needs, or the design of packaging that is excessively complex, large, or redundant, surpassing the reasonable needs for product protection, logistics, and marketing.

In China, overpackaging has become a common problem in various consumer product industries, and has also caused many environmental and social problems. The most direct aftermath is the impact on the environment and sustainability. An investigation from Environmental Protection and Resources Conservation Committee of the National People's Congress finds that: (1) packaging waste in China accounts for over 10% of urban household waste, and its volume accounts for over 30% of household waste; (2) the total amount of packaging waste each year reaches 150 million tons, of which more than 70% is caused by excessive packaging.1

A large amount of paper, adhesive tape, plastic foam and other materials are consumed in packaging, which will cause waste if they are not recycled in a timely and effective manner; Moreover, it can also lead to excessive product volume and waste of transportation space. In addition, excessive packaging can increase the garbage disposal volume and cause environmental pollution. Packaging bags, adhesive tapes, foam and other wastes are difficult to treat and degrade, especially those made from chemicals. Improper disposal will bring great negative impact on the ecological environment.

On the other hand, overpackaging essentially undermines consumer rights. For consumers, although the oversized packaging boxes are elaborate, the only destination of them is being discarded, while the true value lying in the product inside the boxes. However, the cost of packaging is part of the product price, ultimately passed on to the consumers.

Lastly, excessive packaging can contribute to detrimental social norms, particularly in the Chinese market, where products such as mooncakes and tea, which symbolize social status when given as gifts, are especially prone to be excessive packaged. This will foster a culture of extravagance, wastefulness, and excessive competition, promoting an atmosphere of showmanship and ostentation.

Consumer Attitudes and Perceptions 

As per the survey conducted by the China Consumer Association, more than half of consumers have strongly recognized the overpackaging issue in the market, with only 6.1% of the respondents unaware of the problem.2

The top three occasions where respondents have noticed overpackaging are "encountered or seen when shopping", "seen from news reports or social media", and "received overpackaged products". It indicates that the phenomenon of overpackaging of goods is ubiquitous, and reflects that it has attracted widespread social attention.

When respondents received overpackaged products, 66% felt it was "wasteful," and 37% said "there was a huge psychological gap before and after opening the packaging, which was not a good experience." Overall, consumers have more negative experiences than positive ones when receiving excessively packaged products, suggesting that the packaging used for gift should also be moderate.

op2.pngIn consumers' perception, the overpackaging issue can be found in almost all consumer goods, especially certain product categories. Luxury goods are voted as the top category with the most overpackaging, followed by various food products, including mooncakes, health supplements, alcohol, and tea, as well as cosmetics.

Two main suggestions are proposed by respondents regarding the governance of excessive packaging. Firstly, the government should strengthen consumer education including advocating consumers to actively refuse to purchase such products. Secondly, enterprises should use more eco-friendly and sustainable packaging.

Anti-Overpackaging Regulatory Efforts 

Back in 2009, China's State Council issued a notification regarding the control of excessive packaging of commodities, outlining four major strategic directives:

  • Fully understanding the significance of managing excessive packaging of commodities;

  • Speeding up the formulation and improvement of standards, regulations and policies to prohibit the production and sale of excessively packaged commodities;

  • Increasing publicity and education efforts to mobilize the whole society to refuse excessive packaging;

  • Strengthening organizational leadership and enhancing supervision and inspection.

Afterwards, regulatory authorities have placed paramount importance on the issue of product overpackaging. A series of relevant laws, regulations, standards, and government notifications have been introduced, thereby a fundamental framework for China's current oversight of excessive packaging have been established. Among these legislations, the most pivotal and direct ones are two mandatory national standards and one recommended national standard.

GB 23350 Requirements of Restricting Excessive Package–Foods and Cosmetics 

On March 31, 2009, China unveiled the mandatory standard GB 23350-2009 Requirements of Restricting Excessive Package–Foods and Cosmetics, which stipulates binding requirements on anti-overpackaging for food and cosmetic products. This standard establishes "interspace ratio" and "package layers" as key indicators for controlling excessive packaging.

Over a decade later, on August 10, 2021, China updated this standard and released GB 23350-2021 to address the persistent and growing overpackaging issue. Compared to the previous iteration, the new standard expands its application scope to encompass 31 food categories and 16 cosmetic categories, while introducing a changing indicator—the "necessary spatial coefficient of commodity" (k-value) —to further regulate the standardization of product packaging. The K value varies among different product categories, and is used as a coefficient to calculate the interspace ratio of the commodity with other coefficients including the measured volume of sales package and the volume of contents. Additionally, the new version divides the requirements into three distinct components: interspace ratio, package layers, and cost. Any breach of these three indicators would be deemed a case of excessive packaging.

Building upon this revised standard, two amendment sheets to GB 23350-2021 were subsequently released on May 24, 2022, and March 25, 2024, respectively. The first amendment introduces more stringent packaging requirements for two prominent Chinese traditional festival foods: mooncakes and zongzi (rice dumplings). The second focuses on regulating the packaging of tea and baby food products.

Necessary Spatial Coefficient of Food Commodity (Excerpt)

Item

K value

Grain and its processed products

4.5

Edible oil, fat and their products

4.5

Seasoning

5.0

Meat products

7.0

Dairy products

4.5

Beverage

5.0

Convenient food

9.5

Necessary Spatial Coefficient of Cosmetic Commodity (Excerpt)

Unit

Item

K value

General liquid

Hair care and cleaning products

9.0

Skin care liquids

9.0

Hair dyes and perms

9.0

Gels

9.0

Cream & lotion

Skin care cleaning products

9.0

Hair care products

9.0

Hair dyes and perms

9.0

Interspace Ratio of Foods and Cosmetics

Net weight of single piece a (Q)

mL or g

Interspace ratio b

%

≤1

≤85

1<≤5

≤70

5<Q ≤15

≤60

15<≤30

≤50

30<Q ≤50

≤40

≥50

≤30

Notes: This table does not apply to product that only has single layer for sales package.

a For cosmetics ready for use after mixing, single piece refers to mixed product.

b The interspace ratio of multiple products should follow the value for single maximum net weight product in the package.

GB 43284 Requirements of Restricting Excessive Package-Fresh Edible Agricultural Products 

On September 8, 2023, China released GB 43284-2023 Requirements of Restricting Excessive Package-Fresh Edible Agricultural Products, further expanding the regulatory efforts to curb the pervasive issue of overpackaging. This new standard applies to the sales packaging of both domestic Chinese and imported agricultural products sold within the Chinese market, encompassing a wide range of fresh products such as vegetables (including edible fungi), fruits, livestock and poultry meat, aquatic products, and eggs. Same as GB 23350-2021, three aspects and indictors are established in this standard for the judge of overpackaging of fresh edible agricultural products, namely, interspace ratio, package layers and cost.

Packaging Layer Requirements for Fresh Edible Agricultural Products

Item

Packaging layers

Vegetables (including edible mushrooms and fungi)

≤3

Fruits

≤4

Livestock and poultry meat

≤4

Aquatic products

≤4

Eggs

≤3

GB/T 31268 Restricting Excessive Packaging for Commodity-General Rule

For commodities that fall outside the scope of food, cosmetics, and fresh edible agricultural products, enterprises may still refer to the recommended national standard GB/T 31268-2014 Restricting Excessive Packaging for Commodity-General Rule as a guiding framework to avoid overpackaging. As a non-mandatory standard, GB/T 31268 provides principles and guidelines to help stakeholders control excessive packaging across all manners of consumer goods, such as general principles, packaging design, and packaging cost.

Notably, on April 25, 2024, an updated version, GB/T 31268-2024 was published, slated to take effect on November 1, 2024. Compared to the old version, the new standard brings several key changes:

  • The application scope is refined.

  • The terms and definitions of "sales package", "original package" and "necessary spatial coefficient“ are added.

  • The "general principle" is changed to "basic requirements" with updated contents.

  • The requirements for material selections are added under the section of "package materials".

  • "Package structure and interspace ratio" is added as a new chapter, incorporating some contents under "package design".

  • The requirements for "package layers" are added.

  • The requirements for "package cost" are modified.

  • "Corporate self-declaration" is added as a new chapter.

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