Ai Group welcomes the opportunity to contribute to the Department of Climate Change, Energy, the Environment and Water’s (the Department) process to reform packaging regulations.

Packaging regulation reform is an important step towards a more circular economy but must be weighed against the real-world uses and needs of businesses and consumers who sell and buy packaged goods.
Key messages from our submission include:

• While there are supporters in industry of each of the options presented by the Department, the greatest number support option three – an Extended Producer Responsibility (EPR) scheme.

• Packaging’s foremost purpose is to protect the product it is applied to. Design for circularity is important as we attempt to decarbonise our economy, but it should be achieved while fulfilling that primary purpose.

A whole-of-life approach, that includes product protection and/or preservation and safety alongside end-of-life considerations, should be taken.

• We would not support the proposed regulations being applied uniformly between business-to-business packaging and business-to-consumer packaging.

• There has been broad support for the inclusion of a collection and recycling obligation, as long as all packaging value-chain actors have clearly defined roles and responsibilities and not just brand owners

• Significant transition time would be required to allow all regulated entities to be able to develop fully compliant packaging and systems, while not sending large stockpiles of existing packaging to landfill.

• Consumer education and behaviour change initiatives are key to ensuring any reform results in a functional system that minimises contamination of collection streams and delivers high-quality outputs.

• Packaging cannot be separated from other circular economy concerns. The Department should consider closely how policy in the wider circular economy – from all levels of government – will interact with this regulation, and vice versa.

• Packaging regulation reform also needs to consider how the other regulatory requirements – e.g. FSANZ food safety requirements, TGA safety and labelling requirements – will interact with the proposed regulation.