To address enduring economic disparities impeding the achievement of the National Packaging Targets (NPTs), the Australian Packaging Covenant Organization (APCO) launched a consultation on a potential transition to a more robust, industry-led Extended Producer Responsibility (EPR) model on April 10, 2025. By midnight AEST on May 16, 2025, feedback can be sent in writing or on APCO’s website. 

Introduction of EPR

A legislative concept known as “Extended Producer Responsibility” holds producers—in this case, brand owners who put packaging on the market—financially and operationally accountable for the way their products are managed at the end of their useful lives. EPR encourages more sustainable package design and more investment in circular networks by shifting the cost burden from consumers and local governments to producers.

APCO now contends that a more comprehensive and industry-led version of the co-regulatory framework is required to ensure long-term viability and compliance with national targets, even though Australia already has one under the National Environment Protection (Used Packaging Materials) Measure 2011 (NEPM) and the Covenant mechanism.

Proposed Two-Part Fee Structure

APCO’s proposed shift involves a new member fee model beginning in FY27, comprising:

EPR fees will be used to fund direct interventions such as:

• To enhance material recovery, particularly for soft and hard plastics and fiber, service payments are made to operators, such as collectors and reprocessors.
• facilitation of the supply chain to support the growth of end markets for recycled materials, business-to-business (B2B) recycling, and specialized material programs.
• initiatives for consumer education to encourage recycling, especially at the kerbside (home) level. 

Proposed Recommended Pathway (Scenario B)

APCO is suggesting “Scenario B” as one of the evaluated options since it strikes a compromise between cost, viability, and systemic influence. The table below lists the scenario’s expenses, advantages, and evaluation.

Reuse, current recycling programs, and yearly turnover are all taken into account when calculating fees, and the financial model is adjusted to scale with the volume and environmental effect of each brand owner’s packaging operations. Packaging that is eligible for verified reuse loops or container deposit schemes (CDS), for instance, can be disqualified or given a discount.

Strategic Shift Toward 2030

APCO’s 2030 Strategic Plan is also activated by the new model, putting the company in a better position to coordinate group efforts throughout the packaging supply chain. As the manager of Australia’s sole legally mandated packaging stewardship program, APCO views this as a chance and a duty to spearhead the industry’s shift to circularity.

APCO’s 2030 Strategic Plan includes detailed activities, performance goals, and funding sources such as eco-modulated levies that modify producer contributions according to the packaging’s environmental performance. By encouraging recyclability, reuse, and decreased material consumption, these fees aim to encourage more environmentally friendly packaging options while discouraging problematic formats.

Crucially, the Plan has a transitional function and will continue to operate until the Department of Climate Change, Energy, the Environment, and Water (DCCEEW) has finished its regulatory reform process in its entirety. As the sector gets ready for a future regulatory environment that may be more prescriptive, this guarantees policy continuity and operational stability.

Stay ahead in sustainability compliance with Global PCCS —where expert insights meet the latest regulations. Unlock a future where compliance fuels sustainability, helping your business thrive in a greener, well-regulated world. For more information, contact us at info@globalpccs.com