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Consultation feedback helps shape next steps for EPR activation

Friday 6 June 2025


APCO will not introduce the proposed Extended Producer Responsibility (EPR) fee model in FY27, following consultation with members and stakeholders in early 2025. While there’s strong support for the intent of EPR, feedback highlighted the need for regulation certainty, transparency and governance. APCO will work with industry and government to refine the model and ensure it is fair, practical and well-designed for future implementation. 


Thank you to all our members and stakeholders who provided feedback on APCO’s proposed industry-led Extended Producer Responsibility (EPR) approach for packaging.  APCO heard from almost 220 member organisations, along with external stakeholders from across the packaging value chain. Overall, there was strong support for the intent behind an EPR approach to packaging and a recognition that additional investment in collection, sorting, and reprocessing is required. However, many members and stakeholders expressed the need for greater regulatory certainty and free rider management.


Additionally, members want more detail on how fees would be used, how fairness and transparency would be maintained, and how governance and oversight mechanisms would support accountability.


Recognising this, the EPR fee model will not be introduced in FY27. This means the new proposed model of ‘base fee’ plus ‘EPR fee’ will not be activated next year, and APCO fees for FY27 will continue to be charged using the current turnover-based method. APCO will continue to consider adjustments in line with CPI and other cost recovery needs.


Feedback highlighted the following priorities: 


  • Industry needs regulatory certainty and a pathway that avoids duplication and confusion. 
    • Industry told us that acting now, without clarity about packaging’s future regulatory framework, risks misalignment. There’s strong support for national consistency, but concerns remain about overlapping obligations and unclear roles. Until the government confirms its position, industry have asked APCO to focus on building the foundations for an industry-led response. 
  • Industry supports the intent of EPR but wants a model that’s practical, fair and delivers results. 
    • Industry told us that a strengthened EPR system must go beyond intent. While many support the principle of producers taking greater responsibility, there’s clear concern that ambition must be matched by clarity, capability and commitment across the entire system, not just from those already doing the right thing. 
  • Industry wants a fee model that’s proportionate and reflects real-world packaging realities. 
    • Industry told us that significant fee increases need to be backed by a clear value proposition. If industry is asked to invest more, there must be transparency on how funds are used in the system and confidence that costs are being shared equitably. Many businesses have invested in upgrading packaging despite working on thin margins and want to see this recognised in the fee design. 
  • Industry wants meaningful governance.  
    • Industry told us that transparency and clear integrity matters. If members are contributing significant new funding, they want confidence in how it’s spent. Clear governance, regular reporting, and a defined process for member input are essential to building trust and driving outcomes. 
  • Industry wants reporting that’s efficient, not onerous and support to build capability. 
    • Industry told us that packaging data requirements are already complex, and increasing the burden without adequate support could backfire. Assurance requirements, in particular, need to be fit-for-purpose and proportionate. 
  • Industry wants a model that reflects the realities of each sector. 
    • Industry told us that different sectors face different challenges. Whether it’s food safety, therapeutic goods, compostables, or existing stewardship schemes, a one-size-fits-all approach won’t work. Although applicable to a minority of situations, a few members want us to explore how exemptions, discounts, and special conditions can be applied in a way that’s fair, evidence-based, and aligned with national goals. 
  • Industry needs time to prepare and a transition that sets the system up for success. 
    • Industry told us that businesses need time to plan, budget, and adapt systems. Many are already making 2027 decisions today. A phased approach, longer lead times, and clearer milestones are needed to get the timing right. 

APCO would like to thank all members and stakeholders who took the time to share their views. The consultation has provided clear direction for APCO’s next phase of work, and we remain committed to transparency, fairness and refining a strong, collaborative approach to packaging stewardship in Australia.


In the next few months, we will share a full consultation summary and more information on next steps to refine a model that is fit for purpose to achieve our packaging sustainability goals. 

 

We’re committed to delivering a model informed by industry that works and lasts. That means not rushing the process, and ensuring you have clarity and confidence in the approach.


You can find out the latest on the consultation and next steps: here