ASBG has considerable concerns with the Paper. While Option 1, ongoing use of APCO is preferred by ASBG it is incomplete, in that it requires considerable support by all Australian Governments to make a more effective circular economy. Also used packaging should be treated as a part of the whole circular economy process, where its recycling etc. represents only 10% of the waste stream.
The Paper is somewhat confusing as it seems to partly follow a Regulatory Impact Assessment, but provides no cost-benefit analysis. All three Options should go through this process, but it seems on the final regulation may be have an RIS.
The paper's preferred Option 3, the EPR scheme, lacks many details, and will be very expensive, where costs of over $1b p.a. or more, are likely as a starting amount. EPR taxes on packaging materials will result in perverse outcomes where good packaging materials will simply rise in price to just under their competitive poorer packaging material (now taxed) rate. This undermines the incentives to change packaging materials to a more recyclable type.
Also concerning is there is no identification of how the $1b will be spent.
Regardless of which Option is used, the following is required and recommended overall is a better planning and management, especially from a waste infrastructure perspective including:
- The commonwealth revamping its export ban on recyclable materials
- State and territory governments work with industry to a better, more consistent plan of strategic planning, siting of recycling infrastructure and downstream residual waste management including
covering EfW and landfill supplies. - All parties to improve education on waste management.
- Local Governments to remove obstructions and reluctance to teaming up to provide sufficient waste / recyclate flow rate to provide economies of scale for efficient and effective recycling facilities where appropriate.
 ASBG's Submission on the Reform of Packaging Regulation Consultation Paper 2024 | 1184 kB |
