On 7 April 2025, the Australian Packaging Covenant Organisation (APCO) released its consultation paper, “From Collective Action to System Impact,” outlining plans to introduce an Extended Producer Responsibility (EPR) scheme in Australia. This initiative aims to help the industry achieve the National Packaging Targets and advance sustainability in the Australian packaging sector.
APCO has conducted consultation sessions nationwide to engage with industry stakeholders and gather feedback ahead of the planned scheme implementation in mid-2025. Nicholas Payne, Head of ESG & Quality at Star Group, attended these sessions and provides the following report:
Overview and Context
The APCO consultation paper, which details the future funding framework for APCO, represents a significant step forward in packaging regulation in Australia. While some gaps remain that must be addressed to ensure the scheme sends the right market signals, it is crucial to prioritise progress over perfection and embrace changes that will guide Australia towards a circular economy.
To understand the significance of the proposed EPR scheme, it is important to consider the context:
- In 2018, APCO announced the “2025 National Packaging Targets,” which included four key objectives:
- 100% of packaging to be recyclable, reusable, or compostable
- 70% of plastic packaging to be recycled or composted
- 50% average recycled content across all packaging
- Phase-out of problematic and unnecessary single-use plastic packaging
Although these targets were ambitious, it soon became clear that, without significant changes in market and consumer behavior, they would not be met. The 2022–23 Packaging Consumption and Recovery Data revealed that progress had stalled, with no signs of improvement.
At the same time, each Australian state and territory introduced single-use plastic bans with varying approaches. This created a fragmented and complex regulatory environment, increasing compliance costs for businesses.
As a result, federal and state environment ministers agreed to review the current co-regulatory model. APCO responded by releasing its 2030 Strategic Plan, outlining a new eco-modulated membership fee model. Fees would be calculated based on packaging output, incentivising packaging design focused on reduction, reuse, and recovery.
Meanwhile, the Department of Climate Change, Energy, the Environment and Water (DCCEW) published its own consultation paper (closing October 2024), which revealed:
- 80% of respondents preferred Commonwealth regulation of packaging
- 65% supported an EPR scheme with mandatory requirements
Key Features of the Proposed EPR Scheme
Given this context, there is both a clear need and a strong mandate for a new, consistent, and collaborative approach that emphasises and incentives lasting change.
The APCO consultation paper presents a comprehensive plan for brand owners to take responsibility for their packaging footprint. Under the scheme, brand owners would pay a sliding-scale fee, based on packaging material (with higher rates for soft plastics), to fund collection and recycling initiatives that support a circular economy.
Fee Model Overview (Scenario B):
| Packaging Material | Fee per Tonne |
|---|---|
| Glass | $1 |
| Fibre | $2 |
| Rigid Plastic | $9 |
| Soft Plastic | $49 |
| Other | $1 |
This model, along with proposed EPR discounts, sends a strong signal to brand owners while generating capital to support Australia’s transition to a circular packaging economy.
Considerations and Recommendations
Currently, the fee model only applies to APCO members. As a result, businesses that have led the way in sustainable packaging continue to bear the brunt of costs, while non-members are under no obligation to contribute.
To foster a fair and effective system, a national approach should be adopted to ensure:
- Consistent regulation across all states and territories
- Clear and unified consumer messaging around recyclability
- Incentives for brand owners to design packaging that works within current recycling infrastructure
Star Group is committed to working alongside our customers and industry partners to support the evolution of packaging in Australia. We will continue to advocate for strong, practical reform and provide ethical, sustainable sourcing solutions for future-ready packaging portfolios.
Need assistance preparing for the EPR scheme? Contact us today.