Australia’s Packaging Regulation Framework Is Accelerating: What Brands Need to Know Now

Australia’s packaging regulation landscape is moving faster than many brands realise. While the country does not yet have a mandatory Extended Producer Responsibility scheme in place, the architecture being built right now by APCO, state governments, and the Federal Government makes clear that formal, fee-based obligations are coming. The question for brands is no longer whether to prepare. It’s how quickly.

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APCO Has Confirmed a Three-Year EPR Transition Pathway

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At its 2025 Annual General Meeting in December, APCO confirmed the FY26 Business Plan and a structured three-year pathway toward a regulated, industry-led EPR scheme for packaging in Australia. Three priorities came through clearly from the consultation: preparing for an industry-led EPR scheme, strengthening and simplifying packaging design and compliance, and building capabilities needed for a more regulated packaging environment.

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The Three-Year Roadmap

FY26 - Strengthen foundations: clearer design guidance, stronger data governance, better reporting tools, groundwork for soft plastic stewardship and future EPR requirements

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FY27 - Transition and activation: implementing priority interventions, setting clearer design and data expectations, beginning planning for an industry-led EPR model

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FY28 - Scale system impact: measurable improvements in recovery performance, downstream processing capacity, and public confidence, underpinned by stronger national alignment

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This is not a distant horizon. FY26 is live now.

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The Numbers That Define the Challenge

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APCO’s Australian Packaging Consumption and Recovery Data for 2023–24: 6.84 million tonnes of packaging placed on market in Australia. Overall recovery rate: 59%. 86% classified as having good recycling potential.

The gap is plastics. Recovery rates for plastic packaging (particularly flexible plastics) remain significantly behind paper, glass, and metals. This is precisely what the incoming EPR framework and APCO-SPSA partnership are designed to address.

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APCO and SPSA: A Coordinated Pathway for Soft Plastics

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One of the most significant developments in the current plan is APCO’s formal partnership with Soft Plastics Stewardship Australia (SPSA). APCO has signed a Letter of Intent with SPSA to support an industry-led EPR approach for soft plastics, with work underway to align data systems, billing, and participation settings so that brands can choose to participate via APCO.

SPSA is the industry-led body authorised by the ACCC to develop a coordinated national soft plastics recovery pathway. Its ACCC authorisation was a significant milestone, enabling collective industry action that was previously difficult to pursue.

The APCO-SPSA partnership matters for brands using flexible packaging because soft plastics have historically lacked a credible, scalable recovery pathway, leaving them exposed as the highest-risk category under any future EPR fee structure. A coordinated industry-led scheme creates the infrastructure that can support more favourable classification and fee treatment as formal EPR develops.

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State Governments Are Not Waiting

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While national EPR is still in development, state governments are accelerating their own packaging regulation:

• New South Wales: Plastics Plan 2.0: phases out hard-to-recycle plastics, requires tethered caps on beverage containers by 2030, mandates labelling for away-from-home packaging
• Western Australia: expanded bans to include moulded expanded plastic packaging
• South Australia: world-first ban on small pre-filled containers, including fish-shaped soy sauce bottles

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The practical problem for brands is consistency. Each state moving independently creates a more complex and costly compliance environment for national operations. APCO is prioritising government relations in its FY26 plan, working directly with states and territories to promote national harmonisation.

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The Federal Government Is Now Free to Focus on Packaging Reform

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The passage of the Environment Protection Reform Act 2025 modernises the platform for environmental regulation in Australia and in APCO CEO Chris Foley’s words: frees the Australian Government to focus fully on packaging regulation reform in 2026.

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Federal signals include proposed recyclability grading for packaging, mandatory design requirements, and clearer rules for sustainability claims and labelling. Greenwashing scrutiny is also increasing, meaning “recyclable” claims need to be defensible under tightening standards, not just well-intentioned.

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What This Means for Brands Right Now

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The consistent message across APCO’s consultation, its FY26 Business Plan, and regulatory signals from state and federal governments is that the window for low-cost preparation is narrowing.

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Brands that invest now in packaging design improvement, data quality, and stewardship engagement will be in a materially stronger position when formal EPR obligations and fee structures arrive. Those that wait will face the same decisions under worse conditions: less time, less flexibility, and higher cost.

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The specific actions that matter most right now:

• Build accurate, component-level packaging data
• Understand which formats in your portfolio are already carrying regulatory risk
• Engage with stewardship pathways like the APCO-SPSA soft plastics scheme before participation becomes a compliance requirement rather than a commercial choice

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Our View

Regulatory uncertainty in Australia is not a reason to delay. It is the opportunity for industry leadership. The brands that take it seriously now will be the ones that shape what the system looks like, rather than simply paying for it.

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Frequently Asked Questions

Does Australia have EPR for packaging yet?

Not in a mandatory, fee-based form. Australia currently operates a co-regulatory model through APCO. However, APCO has confirmed a three-year pathway toward a regulated, industry-led EPR scheme, and both state and federal governments are actively developing stronger packaging obligations.

What is the APCO-SPSA partnership?

APCO has signed a Letter of Intent with Soft Plastics Stewardship Australia to support an industry-led EPR approach specifically for soft plastics. The partnership aligns data, billing, and participation settings so brands can engage in soft plastic stewardship via APCO. SPSA was authorised by the ACCC in 2025 to develop a coordinated national soft plastics recovery pathway.

What are Australia’s National Packaging Targets?

Australia’s 2025 National Packaging Targets set goals for recyclability, recycled content, and the phase-out of problematic and unnecessary packaging. By all available data, Australia missed all of them at the 2025 deadline — with plastic recycling at approximately 20% against a 70% target. This miss is directly driving the shift toward mandatory regulation.

Which Australian states are introducing new packaging regulations?

New South Wales, Western Australia, and South Australia have all introduced or expanded packaging-related regulations in 2025. NSW’s Plastics Plan 2.0 is the most comprehensive, covering phase-outs, tethered caps, and away-from-home labelling. The Federal Government is working toward national harmonisation to reduce the compliance complexity created by diverging state approaches.

What should Australian brands do to prepare for EPR?

Build accurate SKU-level packaging data, audit your portfolio for formats likely to attract higher fees under an eco-modulated EPR system, engage with APCO membership and stewardship schemes, and treat packaging design decisions as financial decisions. The earlier these steps are taken, the more options a brand has when formal obligations arrive.

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