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Consultation on a strengthened industry-led EPR approach for packaging

Page last updated: 6 June 2025


Background

Despite significant industry effort and voluntary commitments, the National Packaging Targets remain out of reach. APCO’s 2023 review identified critical economic gaps that continue to hinder recycling, reuse, and circular outcomes for packaging in Australia. 


In response, APCO developed a proposed industry-led Extended Producer Responsibility (EPR) approach supported by a new membership fee structure. The intent: to create a fair and transparent model that enables industry to co-invest in the collection, sorting and processing systems needed to meet the Targets. 


Consultation Process

Between March and May 2025, APCO undertook a national consultation with Members and stakeholders on the proposed EPR approach and new fee model. This included a formal consultation paper, roadshow events across the country, webinars, and direct engagement with nearly 220 member organisations, along with key stakeholders across the packaging value chain. 


Throughout this process, members and stakeholders provided extensive feedback—supporting the overall intent of EPR, but calling for greater regulatory certainty, more detail on fee application, stronger governance, and a model that reflects the operational realities of different sectors. 


What we heard

Key feedback themes included: 

  • Regulatory certainty and a pathway that avoids duplication and confusion. 
  • A model that’s practical, fair and delivers results. 
  • A fee model that’s proportionate and reflects real-world packaging realities. 
  • Meaningful governance.  
  • Reporting that’s efficient, not onerous and support to build capability. 
  • A model that reflects the realities of your sector. 
  • More time to prepare and a transition that sets the system up for success. 

Next steps

In light of this feedback, APCO has confirmed that the proposed EPR fee model will not be introduced in FY27. The new ‘base fee + EPR fee’ structure will not be implemented next year. Instead, FY27 fees will continue to be calculated using the current turnover-based model. APCO will continue to consider adjustments in line with CPI and other cost recovery needs.  


This pause will allow APCO to further refine the model in collaboration with members and in alignment with emerging regulatory settings. In the next few months, we will be sharing a full consultation summary and more information on next steps with members and refining a model that is fit for purpose to achieve our packaging sustainability goals. 


Timeline (updated)

  • August 2024: APCO’s 2030 Strategic Plan released 
  • February 2025: Preparatory webinar series 
  • April–May 2025: Member and Signatory consultation 
  • July 2025 onwards: Consultation findings published and next steps for revised EPR approach released in coming months 
  • July 2027: Current fee structure maintained 

Resources


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Not an APCO Member or Signatory and want more information?

📧 Contact: apco@apco.org.au.