For two decades, Australian packaging has been governed by a co-regulatory arrangement: brands join APCO, report annually, and work toward voluntary national targets. That era is drawing to a close. The federal government is part-way through a reform of packaging regulation, and while the final shape is not yet locked in, the direction is clear. Brands that design for it now will have a far easier time than those that wait for the legislation.
Why the rules are changing
The trigger was simple: the voluntary approach did not deliver. Australia's 2025 National Packaging Targets, which included 70 per cent of plastic packaging recycled or composted and 50 per cent average recycled content, were not fully met within their original timeframe. APCO chief executive Chris Foley described the headline data as disappointing, and the recovery rate for plastic packaging was reported at just 18 per cent in 2020-21, a long way from the 70 per cent goal.
In 2023, federal and state environment ministers agreed the system needed strengthening. The Department of Climate Change, Energy, the Environment and Water (DCCEEW) then consulted publicly in late 2024 on three reform options.
The three options on the table
- Option 1: strengthen the administration of the existing co-regulatory arrangement.
- Option 2: national mandatory requirements for packaging, enforced by a Commonwealth regulator. This would include design-for-recyclability rules, bans on problematic formats and chemicals of concern, minimum recycled content thresholds, mandatory recyclability labelling, and annual compliance reporting by businesses that place packaging on the Australian market.
- Option 3: a full extended producer responsibility (EPR) scheme, where the businesses that put packaging on the market fund its end-of-life recovery.
No final decision has been announced. Through 2026, DCCEEW has been consulting with industry on a proposed recyclability framework, often described as recyclable by design, which assesses how readily each material can actually be recycled and remade in Australia. Until new regulations begin, existing obligations under the co-regulatory arrangement still apply.
The part that is already happening: eco-modulated fees
While the legislation is still being settled, APCO is not standing still. Under its 2030 strategy, membership fees are moving from a turnover-based model to an eco-modulated one, calculated from the amount and type of packaging each member places on the market. APCO consulted with members through 2025 and has aimed to have the new fee model in place for the 2026-27 financial year.
The logic is straightforward: packaging that is easy to recycle attracts lower fees, and hard-to-recycle formats cost more. For the first time, a soft-plastic laminate pouch and a mono-material alternative will carry visibly different price tags on the compliance side, not just at the printer.
What this means for your next pack
Whichever option the government lands on, the same design decisions come out ahead. Brands and their designers can act now:
- Design for recyclability first. Mono-materials, kerbside-compatible formats and easily separable components are favoured under every reform option, and under the eco-modulated fee model that is already arriving.
- Audit problematic formats. Formats and additives flagged as problematic are the most likely candidates for early bans under a mandatory scheme. If your pack relies on one, start scoping the alternative now rather than in a forced reprint.
- Get your labelling right. Mandatory recyclability labelling is on the table, and the Australasian Recycling Label is the established system. Treat correct ARL use as a design requirement, not a nice-to-have.
- Ask about recycled content at quoting stage. Minimum recycled content thresholds are part of the proposed mandatory requirements, and supply takes time to arrange.
None of this requires waiting for the regulator. A pack designed for recyclability today is cheaper to run under eco-modulated fees, safer against future bans, and more credible on shelf. The brands that treat the reform as a design brief rather than a compliance headache will come out of it with better packaging.
For a practical walkthrough of the marks and labels an Australian pack already needs, see every mark that belongs on an Australian pack.
General information to help you plan, not legal or professional advice. The reform is still in progress and details may change. Always confirm current requirements with DCCEEW, APCO or your designer before you print.