Sustainable supplement packaging: recycled bottles and honest claims

In short

  • A recycled or lower-impact pack is possible for a listed medicine. We sourced 100% recycled PET bottles for Vitable's TGA-listed hair capsule and managed the supply through to delivery.
  • The pack is part of the product. TGA guidance says ongoing stability testing is of the finished packed product, and a different pack may need its own study, so a new material is planned into the stability program.
  • Some medicines need child-resistant packaging under TGO 95, and a pack presented as tamper-evident follows the TGA's code of practice for tamper-evident packaging. A new pack has to keep meeting both where they apply.
  • Environmental claims fall under the Australian Consumer Law. The ACCC's guide for business, published in December 2023, sets out eight principles, starting with "Make accurate and truthful claims" and "Have evidence to back up your claims".
  • The safest claim is a specific, checkable one about the pack itself, worded so it doesn't overstate the benefit.

What changes when the pack changes

A supplement's shelf life rests on stability data for the product in its pack. TGA guidance says ongoing stability testing is of the finished packed product, that products grouped in one study should share the same primary packaging materials, and that a change to a product needs a risk assessment to decide whether a new study is needed. A different pack, such as a glass bottle, a particular plastic bottle, a blister or a laminated tube, may need its own study (stability testing).

So moving to a recycled bottle, a thinner wall or a compostable pouch starts with the formula. A moisture-sensitive capsule, a probiotic or an oil may behave differently in a new material. We plan the pack into the stability protocol for the shelf life the label will carry, rather than swapping it in after launch.

What a medicine's pack still has to do

  • Tamper evidence. The TGA's code of practice for tamper-evident packaging isn't mandatory, but it applies to a pack presented as tamper-evident: at least one tamper-evident feature, two for two-piece capsules, and a statement on the pack describing it.
  • Child resistance, where required. Under TGO 95, a listed medicine needs child-resistant packaging if it contains one of the substances the Order lists, in the strength or pack size it sets, such as iron in a pack with more than 250 mg of elemental iron, or if its pack says or implies it is child-resistant. A blister pack generally counts when it seals each tablet or capsule on its own and isn't made of cellulose film or unlaminated paper.
  • The label. A listed medicine is labelled to TGO 116, whatever the pack is made of (supplement labelling).

The packaging and labelling page covers each of these in more detail.

Making a green claim you can stand behind

Environmental claims on a pack or in marketing are covered by the Australian Consumer Law, which the ACCC enforces. Its guide for business, A guide to making environmental claims for business (12 December 2023), sets out eight principles:

  1. Make accurate and truthful claims.
  2. Have evidence to back up your claims.
  3. Don't hide or omit important information.
  4. Explain any conditions or qualifications on your claims.
  5. Avoid broad and unqualified claims.
  6. Use clear and easy-to-understand language.
  7. Visual elements should not give the wrong impression.
  8. Be direct and open about your sustainability transition.

The ACCC notes the guide doesn't yet reflect the higher maximum penalties that took effect on 28 March 2026. In practice, that means saying exactly what is recycled and how much ("bottle made from 100% recycled PET"), not a broad word like "eco-friendly"; keeping the supplier's evidence for it; and making sure leaves, greens and earth tones don't suggest more than the claim does. A claim about a medicine's health benefits is a different matter, governed by the TGA (TGA advertising).

The formats in our records

Bottles in glass, HDPE and recycled PET; blister packs; sachets in stick, square or rectangular formats; pouches in a range of sizes, materials and closures; and tubs. Each comes with its own minimums, costs and stability questions, and a brand's own pack can be used where it meets the product's needs, as Nivari's own pouch did.

From our records

  • Vitable: a complex TGA-listed capsule with more than 13 ingredients, including a clinically studied Biota orientalis extract, AnaGain™ under licence and Quatrefolic®, in a 100% recycled PET bottle, beside a matching serum on the cosmetics pathway. We formulated both, managed their manufacture and sourced the recycled bottles. Both delivered in 2024 and 2025.
  • The Belly Solution: a travel gut-health powder in a 14-day pouch, with a 36-month stability program.
  • Nivari: a founder's first powder supplement, packed in the brand's own pouch for a mid-August 2026 launch.

Questions

Frequently asked questions

Yes. Vitable's TGA-listed hair capsule ships in a 100% recycled PET bottle that we sourced. The bottle is covered by the product's stability program like any other pack.

Possibly. TGA guidance says a change to a product needs a risk assessment to decide whether a new stability study is needed, and a different pack may need its own study. We plan it with the change.

Broad, unqualified claims are the ones the ACCC's principles warn against. A specific claim about the pack, with evidence behind it, is safer: what the material is, how much is recycled, and any conditions.

It depends on the product. A pouch has to protect the formula for its whole shelf life, and a stability study with the product in that pouch is what shows it can.

Sources

General information, checked against these sources between 26 and 29 October 2026. It isn't advice on a particular product. Our work is from Take Friday Off's records.

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