Recommendation 1: Towards SDG No.

7 (Affordable and Clean Energy)

Purpose

To sustain and extend Lush’s role as an industry leader by adopting wholly renewable, science-

based energy practices and eliminating fossil-fuel reliance across all global operations.

Plan

Lush should expedite a transition to 100% renewable electricity globally, leveraging mechanisms

such as direct renewable procurement, power purchase agreements, on-site solar and wind

installations, and the acquisition of Energy Attribute Certificates.

By the end of 2028, at least 60% of manufacturing sites should be outfitted with solar PV arrays

and mini-grid energy systems, collectively targeting 30% self-generated clean power by 2030.

Lush must also establish an annual disclosure protocol for Scope 1–3 greenhouse gas emissions,

relying on third-party validation to ensure transparency and continuous assessment of progress

toward decarbonization goals.

Rationale

Transitioning Lush toward 100% renewable energy directly aligns with the mounting global

scientific consensus and increasing regulatory demands to curb carbon emissions (IPCC, 2022).

This strategic shift is not a one-off decision but a continuous journey that embeds renewable

energy use while systematically phasing out fossil fuels. Achieving this by 2030 would integrate

Lush into the RE100 initiative, an influential coalition of leading companies demonstrating

climate responsibility through clean energy procurement (The Climate Group, 2023).
Ongoing improvement in sustainability practices is further justified by legitimacy theory, which

argues that businesses must continuously meet societal expectations to retain legitimacy and

stakeholder confidence (Deegan, 2002). As Bernal-Torres et al. (2021) explain, verifiable and

audited sustainability actions enhance transparency, which reduces the risk of reputational

damage from accusations of “greenwashing.” This form of credibility is increasingly important,

as investors are shifting towards ESG-integrated decision-making, prioritizing companies that

demonstrate long-term environmental accountability (Khan et al., 2020).

Reducing dependence on fossil fuels is not only environmentally prudent but also a form of

strategic risk mitigation. It shields companies from regulatory volatility, unpredictable fossil fuel

prices, and potential carbon taxation (Barney, 1996). Continuous investments in renewable

energy capabilities such as owning or sourcing clean energy offer cost stability and operational

control.

Recommendation 2: SDG No. 9 (Industry, Innovation & Infrastructure)

Purpose

To evolve Lush from a single-location circularity showcase to a global engine for industrial-scale

waste minimization, infrastructure innovation, and circular business model leadership.

Plan

By 2028, Lush should establish four regional Green Hubs strategically located in Europe, North

America, Asia, and Australia. Each hub must be designed to process at least 5,000 tonnes of

operational and returned product waste annually by 2033, a significant leap from the Poole hub’s

benchmark of 1,702 tonnes in 2024.

500 by 2030, will anchor circularity into customer experience and logistical operations. These

stations should be complemented by a digital smart-packaging system: embedding QR or NFC

technology into every product pot, enabling end-to-end tracking, incentivized consumer returns,

and full integration with Lush’s Bring-It-Back rewards.

Customer engagement and feedback loops should guide ongoing improvements in system design

and return rates.

Rationale

Scaling Lush’s Green Hub network from a pilot project to regionally integrated facilities

responds to Valcozzena’s (2019) emphasis on the systemic nature of circularity, where

infrastructure plays a central role in enabling scalable, long-term transformation. These waste-

processing hubs serve as critical components in resource recovery networks, shifting

sustainability from fragmented recycling efforts to fully integrated circular business systems.

This type of continuous development fosters deeper collaboration with stakeholders including

suppliers, customers, and regulators in line with stakeholder theory, which highlights the

importance of managing diverse stakeholder interests through transparency and shared value

creation (Freeman, 1984).

Embedding modular refill and repair stations within retail operations also reflects a commitment

to ongoing sustainability improvement by directly shaping consumer behavior. As research by

Sanchez-Planelles et al. (2021) shows, consumer adoption of sustainable innovations depends on

a mix of psychological and institutional influences. Providing immediate, visible access to reuse

and repair facilities especially when reinforced by incentive schemes like Lush’s Bring-It-Back
program has been shown to increase participation and reduce waste significantly (Bernal-Torres

et al., 2021). The positive behavioral change observed through quantifiable increases in return

rates following outreach efforts illustrates the importance of sustained consumer engagement

strategies.

Incorporating smart packaging technologies such as QR codes offers another avenue for

continuous improvement by enabling real-time tracking of material flows and product returns.

This application of digital innovation supports the principles of innovation diffusion theory,

which identifies information and communication technologies as accelerators of sustainable

practice adoption (Rogers, 2003). Furthermore, this increased visibility enhances organizational

legitimacy in the eyes of consumers and regulators alike, reinforcing transparency and

traceability as critical expectations in modern supply chains (Deegan, 2002).

Recommendation 3: Towards SDG No. 12 (Responsible Consumption & Production)

Purpose

To scale Lush’s packaging circularity and ethical sourcing strategies, ensuring transparent,

responsible supply chains while setting new standards for sustainable consumer goods..

Plan

Expanding the Bring-It-Back program globally must be a strategic objective, aiming for a 30%

return rate by 2028 and reaching 50% by 2033, beginning from the current performance of 18%

return and 42.9 tonnes of plastic recaptured in 2024.

constructed to exceed forthcoming EU mandates for recycled content and recyclability (notably,

a minimum of 30% post-consumer recycled material by 2030).

Lush should develop and roll out an ingredient traceability platform accessible by customers,

displaying the origin and sustainability credentials of critical raw materials such as essential oils

and cocoa aiming for 100% certified, sustainable sourcing of ingredients by 2032 while

supporting net-zero deforestation standards. This can be reinforced through supplier partnerships,

third-party certifications, and regular public disclosure of traceability metrics

Rationale

Packaging represents a major contributor to plastic pollution, and studies by Sanchez-Planelles et

al. (2021) confirm that return-and-refill initiatives significantly reduce the use of virgin plastics

and the volume of landfill waste. With a current return rate of 18% and nearly one million

packaging items recovered, Lush has already achieved meaningful consumer participation.

However, setting progressively ambitious targets of 30% and 50% return rates reflects a

commitment to continuous improvement, supported by behavioral economics principles that

emphasize habit formation and incentive-driven behavioral change.

Lush’s commitment to introducing refillable packaging across all EU and UK stores by 2027 is a

strategic move that reinforces its dedication to continuous sustainability improvement. This early

rollout anticipates the European Union’s upcoming Packaging and Packaging Waste Regulation

(PPWR) (European Commission, 2025). The PPWR mandates that by 2030 all packaging must

be recyclable by design, and it introduces minimum recycled content thresholds along with reuse

targets (Greif, 2025). By moving ahead of these regulations, Lush mitigates operational and
reputational risk, avoids potential supply chain disruptions, and capitalizes on first-mover

advantages such as enhanced consumer trust and market differentiation. This proactive strategy

goes beyond meeting regulatory requirements and underscores Lush’s position as a leader in

sustainable business practices.

The development of an ingredient traceability dashboard supports continuous improvement by

enhancing supply chain transparency, a growing demand among ethically conscious consumers.

According to NielsenIQ (2022), 78% of U.S. consumers consider sustainability a key factor in

purchasing decisions, with especially strong emphasis among younger demographics. Full

ingredient traceability helps mitigate reputational and environmental risks in commodity

sourcing such as cocoa and essential oils where concerns over deforestation and unethical

practices are heightened (Deegan, 2002).