Covenant Obligations

APCO Brand Owner Members, also known as Signatories to the Australian Packaging Covenant (the Covenant), have a series of obligations they must meet. As we work towards a circular economy for packaging, these obligations provide an opportunity to demonstrate each Members’ commitment and tangible action towards sustainable packaging.


Key annual obligations

Detail on three of the key obligations as an APCO Brand Owner Member are provided below:


  • APCO Annual Report

All APCO Brand Owner Members must submit an APCO Annual Report by 31 March each year via the APCO Reporting Tool.

Upon submission of an APCO Annual Report, Members receive a Performance Summary document. Performance is divided into 5 levels – ‘getting started’, ‘good progress’, ‘advanced’, ‘leading’ and ‘beyond best practice’. Further detail on reporting can be found here.

  •  APCO Action Plan

Following submission of the APCO Annual Report, Members must then complete an APCO Action Plan in order to ensure ongoing commitments towards more sustainable packaging. APCO Action Plans are due on 31 May each year via the APCO Reporting Tool. 

APCO Action Plans are a Member’s commitment to packaging sustainability actions for the following year.

Submission of an APCO Action Plan results in the development of the APCO Annual Report and Action Plan document. This is the public facing document which APCO posts on its website, and Members must post on their own website in order to meet the Covenant obligation of “publish the action plan and annual reports on its website in a prominent and readily identifiable way”.

  • APCO Membership Fees

Membership fees are determined by total annual turnover. APCO Membership fees which must be paid annually and run by financial year. For new Members, their first year Membership fee is pro-rated from the month they join to the end of the Membership year - 30th June.


APCO is a not-for-profit organisation, and all Membership fees directly support the administration of the Covenant, the provision of services to Signatories and projects. Click here for a copy of the APCO Membership Fee Schedule.

Covenant Obligations 

The obligations listed above are part of APCO Brand Owner Members requirement, as Signatories to the Covenant. The full scope of these obligations is listed below, as outlined in Section 10 Part C of the Covenant document:


  • within three months of becoming a Signatory, submit an action plan that sets out what the Signatory proposes to do to contribute to the Covenant’s aim and meets the obligations published by APCO, 
  • by 31 March each year, commencing in the financial year following the year in which a company becomes a Signatory, submit an annual report that outlines performance against all of the action plan commitments and meets the reporting obligations as published by APCO, 
  • publish the action plan and annual reports on its website in a prominent and readily identifiable way,  
  • make annual financial contributions in the form of membership fees payable to APCO, 
  • implement policies or procedures to buy products made from recycled materials,  
  • establish collection and recycling programs for used packaging materials generated on-site, 
  • take action, where appropriate, to reduce litter, 
  • allow independent audits of annual reports and the implementation of action plans, including allowing access to relevant supporting documentation demonstrating application of the Sustainable Packaging Guidelines, or an alternative to the Guidelines, and
  • assist APCO to respond to complaints from the public about the design and use of packaging materials.