The Australian Beverages Council Limited and its members consider sustainability a top priority for our industry.

The transition towards a more circular economy is an opportunity to improve both environmental outcomes and deliver economic prosperity.

As stewards of Australia’s most successful and only fully mandated Extended Producer Responsibility (EPR) scheme for packaging, the non-alcoholic beverages industry has demonstrated the capacity for industry investment through engagement with container deposit schemes. While initially considered a litter reduction scheme, CDS has evolved to provide a clean, source-separated recycling stream that supports the recovery and reuse of our material. Most importantly, through CDS our material remains in the economy by supporting bottle-to-bottle circularity.

While CDS has proven an effective EPR model, there are opportunities for improvement and policy solutions that would address leakage of valuable recyclable material into landfill and the environment. These polices would address gaps in collection of material, improve the sorting and separation of recyclable containers at material recovery facilities, reduce contamination that impedes the economic viability of material and prioritise the sale of that material for use in new beverage products.

These measures include:

1. Increased access and convenience to collection infrastructure (view our CDS page for more information).
2. Improved quality of kerbside waste collection to reduce contamination of eligible materials.
3. Require improvements to MRF infrastructure, critical to the sorting and decontamination of recyclable material.
4. Harmonise sorting, baling and processing specifications across jurisdictions to improve consistency of recovery outcomes and market development opportunities.
5. Maintain high-quality washing and processing of recyclable material to enable food-grade reuse and minimise yield loss during reprocessing.
6. Prioritising the sale of recyclate for use in food-grade packaging.

Packaging Reform and Extended Producer Responsibility

Currently, Australia’s packaging regulations are administered through a combination of the National Environment Protection Measures (NEPM), a legally binding agreement between Commonwealth, State and Territory governments and state-specific regulations. Administration of the NEPM has not kept pace with policy and regulatory developments resulting in state and territory governments opting to advance their own independent regulatory frameworks. In recent years, this is evident in announcements relating to the phasing out of single-use plastic products, and similar, which has introduced new legislation and regulations relating to the management of packaging.

With the non-alcoholic beverage industry’s experience of state and territory governments establishing container deposit schemes (CDS), the ABCL has strongly advocated for the need to approach this a national level and avoid creating further complexity in Australia’s regulatory environment. A national framework for Extended Producer Responsibility (EPR) would create a blueprint to achieve uniformity across areas of design standards, labelling and recycled content requirements and avoid differences across state borders.

The ABCL advocates for:

1. A national approach to EPR

The ABCL supports a nationally consistent EPR framework for the management of non-CDS packaging. Any new framework should recognise the existing and well-established CDS network and avoid duplicative fees and reporting requirements for beverage manufacturers. National reform should build on existing infrastructure, improve consistency across jurisdictions and ensure regulatory obligations are proportionate and efficient.

2. Harmonised regulation of packaging design, waste collection and recycling

The creation of nationally consistent regulations for packaging design, waste collection and recycling would better support investment in material recyclability, reduce the complexity of state-based approaches and support improvements to Australia’s systems of recycling including kerbside collection.

3. Measured implementation of recycled content mandates

The non-alcoholic beverages industry is not opposed to recycled content mandates. However, limited access to high-quality domestic recycled material remains a significant challenge. Food and beverage packaging requires food-grade recycled material, much of which is recovered through container deposit schemes. Beverage manufacturers must compete on the open market for access to this material, including against export and non-food packaging uses, despite contributing to its collection costs. Contamination in non-CDS collection further reduces the available food-grade supply and limits investment in higher recycled content.

4. Material traceability

To demonstrate compliance with recycled content requirements, a robust traceability system is essential from the point of material collection through recycling, remanufacture and incorporation into new packaging. As recycled content levels in plastic packaging cannot be determined through testing of the finished product, compliance depends on accurate chain-of-custody data. This requires cooperation across the waste, recycling and packaging manufacturing sectors to ensure beverage manufacturers can verify and report the recycled content used in their packaging.

5. Material recyclability

The non-alcoholic beverages industry has already made significant progress in transitioning packaging towards formats that are recyclable through Australian domestic systems and supports similar progress across other product categories. In relation to chemicals of concern, industry continues to monitor emerging scientific evidence and engage with regulators to support proportionate, evidence-based policy responses. Industry also participates in relevant research to identify emerging risks and priorities, helping ensure beverage packaging remains safe for consumers while supporting ongoing improvements in packaging design and circularity.