Our last best chance to transition our materials economy

Last week, APCO announced it wouldn’t proceed with its planned Extended Producer Responsibility (EPR) fee model for FY27. If you're not in packaging or retail, this news may have flown under your radar, but it has been making waves in the industry.

After hearing from hundreds of Australian businesses, the message was clear: industry needs more time.

But here’s the problem: the longer we delay, the harder it gets to take reform seriously. Time only helps if we have a framework to prepare for. And right now, we're treading water on packaging regulation reform.

Australia had a 2025 target of 70% of plastic packaging being recycled or composted. We achieved only 20%.

It’s clear that the National Packaging Targets and voluntary compliance haven’t worked.

Tanya Plibersek said two years ago:

“Until now, governments have ignored calls to step in and set mandatory targets... We’re changing that.”

She warned that "tough" new packaging legislation is due in late 2025. APCO's regulatory pause barely rated a blip on most people's radars, but with Murray Watt now the environment minister (approving 40-year extensions to gas projects and Labor dragging its heels on EPA reforms), these new packaging rules risk flying under everyone's radar if we don’t make some noise.

Voluntary compliance has failed, and the National Packaging Targets have missed the mark. And while “tough” new legislation is due in late 2025, there is a very real risk that it will be watered down or pushed back, especially with the same businesses that pushed back on APCO likely to lobby the government for more time... yet again.

During a discussion on LinkedIn about this topic, I was challenged by Sustainable Choice Group CEO, Kiarne Treacy to show her "what real regulation" looks like... so I've taken a run at doing just that below.

This is a complex and nuanced issue, and I’m the first to admit I’m not a policy expert. Some of what follows may be ambitious or naïve. But in the spirit of keeping this conversation going, I’m pinning this up on the board for further discussion.

Since we're not a powerful lobby group that makes generous political donations, we need to find other means to ensure our voices are heard. We’ll need to organise, pressure our Government, Murray Watt, industry and other key stakeholders and decision-makers to build a shared vision for what a more circular materials economy could look like.

Nationally legislated regulations and mandatory targets provide industry with the certainty that's been proven to drive systematic change across entire supply chains. But without a national regulatory framework, a circular materials economy will only ever be a pipedream for Australia.

So consider this a discussion starter. If you have thoughts feedback or advice, pull it to pieces and put it back together again. Whatever it is, we need this change to happen, so I’d love to hear from you.

You can reach me via email or LinkedIn.

The regulatory path to an Australian materials economy built on soils, not oils

THE PROBLEM

Australia’s current packaging system is environmentally and economically unsustainable.

• Plastic doesn’t break down. It breaks up into toxic microplastics and nano-plastics that are now found in our bodies, organs, ecosystems, and food chains.
• Recycled plastics often shed even more microplastics than virgin plastic, giving them a second and third chance at life to do more harm.
• Global plastic production is growing exponentially, with emissions expected to double by 2050. Only 9% is recycled globally, And 20% is recycled here in Australia.
• Voluntary Compliance hasn’t worked, and the National Packaging Targets (NPT’s) have not been achieved.
• Meanwhile, landfill capacity in major cities approaches crisis point.

We cannot recycle our way out of this plastic crisis.

Fortunately, alternative materials and systems are available, but they require nationally mandated regulatory frameworks to unlock innovation in the packaging and waste management sector.

THE OPPORTUNITY

We already have the blueprints for success:

• APCO/NEPM targets
• European Extended Producer Responsibility models
• Australia’s FOGO program (Food Organics, Garden Organics)

APCO/NEPM

• APCO already has a tried-and-tested framework for packaging sustainability. The APCO reporting system provides clear guidelines for how businesses can measure, manage, and reduce their packaging impacts.
• However, the system remains voluntary, with only around 3,000 businesses currently participating, leaving the majority of companies with substantial packaging footprints outside the reporting and accountability net.

By making packaging reporting mandatory and tying it to eco-modulated fees, we can create a powerful incentive for packaging that is designed for reuse, recycling, or composting, and disincentivise wasteful, high-impact materials.

European Extended Producer Responsibility models

• Across Europe, mandatory Extended Producer Responsibility (EPR) schemes have driven real change by reducing waste, increasing recycling rates, and shifting the financial burden of packaging impacts back onto producers.
• EU EPR schemes now generate €4–5B a year and have helped lift packaging recycling rates from 30% to over 70%. Proof of what’s possible with consistent regulation.

These models demonstrate the benefits of clear targets, strong regulatory enforcement, and transparent fee structures that reward low-impact materials and fund collection and processing infrastructure.

Australia’s FOGO program

• FOGO is set to divert millions of tonnes of organic waste from landfill each year, cut methane emissions, and build healthy soils.
• However, compost quality is under threat from plastic contamination, particularly from items such as fruit stickers, bread tags, and uncertified "biodegradable" packaging.

Now is the moment to build on FOGO’s success and address its challenges by supporting a new class of compostable materials, turning our waste crisis into a soil-based solution.

THE POLICY SHIFT WE NEED

1) Mandate Extended Producer Responsibility (EPR) with Eco-Modulated Fees

The APCO model, which was recently paused at the request of its members, was an Extended Producer Responsibility (EPR) model with eco-modulated fees. But, the fees were so small as to be meaningless, and the targets were voluntary.

What's needed is:

• Mandatory standards and reporting: Legislate clear packaging design and recovery obligations that apply to all producers. This creates regulatory certainty, levels the playing field, and ensures that accountability doesn’t depend on who opts in.
• Eco-modulated fees based on impact: Introduce meaningful fees that reflect the true environmental cost of packaging—carbon, toxicity, landfill risk, and end-of-life outcomes. Fees must be nationally consistent to reduce duplication and confusion across states.
• Link fees to packaging impact: Ensure that the worse the material, the higher the cost, disincentivising wasteful packaging and rewarding low-impact alternatives.
• Direct 100% of fees to:
  • Certification of safe, bio-based, non-toxic compostable materials
  • Investment in kerbside compost collection and processing infrastructure
  • Fund R&D for novel compostible materials and subsidise certification pathways for early-stage startups

2) Create a Certified Compostable Materials Pathway

• Require all compostable packaging to be:
  • Bio-based
  • Toxin and contaminant-free
  • Proven to break down safely and bio-assimilate in both compost systems and nature
• Collaborate with composters to validate material compatibility at scale.

3) Ban Non-Compostable Contaminants

• Prohibit the sale of fruit stickers, caddy bags, and bread tags unless they are certified home compostable.
• Prevent PFAS, emerging contaminants, and microplastic contamination through rigorous certification and transparent labelling to protect compost quality and market confidence.

4) Unlock FOGO’s Next Big Win

• Roll out a staggered introduction of certified compostable materials into the FOGO stream to ensure systems aren't overwhelmed, and closely monitor contamination.
• Kerbside collection of compostable materials provides a clear end-of-life pathway to certified compostable materials, reducing the friction to uptake and increasing investor certainty.
• Scale infrastructure and implement national standards to avoid a two-tier compost market.

5) Support Whole-of-System Collaboration

• Federally harmonise single-use plastic bans, recycling and composting systems and certification to allow for standardised systems to reduce friction for business and industry.
• Encourage partnerships between government, composters, brands, and material innovators.

THE BIGGER PICTURE

This is a once-in-a-generation opportunity to transition Australia to a regenerative, biocircular materials economy built on soils, not oils.

The solutions we need are already here:

✅ A proven national framework for packaging accountability (APCO) that can be made mandatory

✅ EPR and European-style eco-modulated fees with clear targets and firm, fair rules—because when rules are firm and fair, industry adapts and innovation follows

✅ Safe, compostable materials made from renewable and sustainable feedstocks, including food and agricultural waste

✅ Proven models of behaviour change and public participation (like FOGO)

✅ Composting infrastructure that’s ready to scale

All that’s missing is the right policy settings.

With clear standards, smart regulation, and targeted investment, we can connect the dots, ensuring these solutions join up, scale up, and solve the compounding landfill capacity + plastic crises.

If we’re serious about a circular economy, we can’t keep circling the same excuses. We need to move from voluntary reporting to mandatory standards, with real consequences, meaningful fees being funnelled into the development of real infrastructure with real urgency. Because Australia’s packaging system isn’t just underperforming... it’s fundamentally unsustainable.

Ensuring we have a legislated EPR with mandatory targets is where the real fight is.

Sustainability professionals are a resilient bunch. We run on vapours of hope. But this time, we'll need to organise and put a truck-ton of pressure on Murray Watt and Labor to deliver packaging regulation reform with teeth.

We cannot kick the can of yet another environmental crisis down the road for the next generation to deal with.

Help Spread the Word

Much of what I’ve shared here draws from a talk I delivered at The Planting festival at Woodfordia, titled A Materials Economy Based on Soils, Not Oils.

With new packaging legislation due at the end of the year, we have a narrow window to raise awareness, build momentum, and push for the kind of regulation that can deliver genuine systems change.

If you're part of an organisation, event, or business that wants to be part of that push, I’d love to deliver this talk to your team or community. It’s designed to inform, inspire, and mobilise. Because we can’t afford another delay, and the more people who understand what’s at stake, the harder it will be for the government to ignore.

Get in touch via email or LinkedIn if you’d like to help spread the word.