Australia is Transitioning from Voluntary to Regulated EPR

APCO has released its FY26–27 Business Plan and Statement of Intent in December 2025 and it outlines the shifting from voluntary improvement toward regulated Extended Producer Responsibility (EPR).

Australia’s packaging system is undergoing a period of accelerated reform and transition. With national expectations shifting toward regulated Extended Producer Responsibility (EPR), APCO has positioned itself as the industry body guiding members through this regulatory evolution. Over the next three years, APCO’s work focuses on building a stronger, more aligned and future-ready packaging ecosystem, equipping industry with the tools, standards and data needed to comply confidently with emerging obligations.

Central to this transition are five focus areas: strengthened packaging standards and design guidance; uplift of the Australasian Recycling Label (ARL); simplified and more accurate reporting; development of credible stewardship pathways including soft plastics; and enhanced government engagement to support national alignment. These priorities respond directly to member feedback and the need for clearer compliance settings, better data integrity and recognition for early leadership.

A stronger national data system underpins this work. In 2023–24, 6.84 million tonnes of packaging were placed on the market, with a 59% recovery rate and plastics continuing to be the lowest-performing material stream. APCO’s updated Consumption & Recovery reporting and material factsheets offer vital evidence for benchmarking, target-setting, and internal decision-making.

Soft plastics stewardship remains a national priority. APCO is partnering with Soft Plastic Stewardship Australia (SPSA) to develop industry-led EPR pathways and a Stewardship Assurance Framework to strengthen confidence, credibility and readiness. This supports scalable national solutions and gives members a pathway to engage meaningfully in soft plastics reform.

Alongside design and stewardship reforms, APCO is working to clarify reporting definitions, especially “placed on market”, and improve reporting tools to make compliance more intuitive and accurate. Members can expect pilot opportunities, access to new design guidelines, participation in technical committees and upcoming consultations across PFAS policy, compostability, ARL enhancements and EPR fee methodologies.

Government relations are also being strengthened through ministerial letters, delegation forums, regulatory consultation, and research partnerships such as the Advancing Plastics Recycling in Australia (APRA) work with ACOR. These initiatives aim to reflect industry needs in policy settings and protect early action by brand owners.

Over the next 36 months, industry leaders should expect tighter rules, clearer design standards, expanded ARL applications, enhanced national consumer education and increased accountability for reporting and stewardship participation. APCO has also established a Member Engagement Manager to coordinate member support, feedback loops and visibility across evolving requirements.

Key Dates & Milestones to Watch (FY26–FY28)

Immediate – Foundation Building

✔ Updated Sustainable Packaging Guidelines released and trialled with members

✔ PFAS discussion paper and guidance published

✔ National consumer awareness campaign for the ARL activated (festive season peak)

✔ Reporting definition clarifications piloted with members

✔ Soft plastics stewardship alignment begins between APCO and SPSA

✔ National bin audit insights released to inform ARL changes

What businesses must do now:

• Review guidelines, update internal design processes, participate in consultations, and strengthen internal reporting systems.

  
  

FY27 (2026–2027) – Capability Building & Alignment

✔ Packaging Guidelines embedded in tools and reporting

✔ ARL strengthening measures adopted—brand updates may be required

✔ Enhanced reporting portal and support systems deployed

✔ EPR fee methodology refined and communicated

✔ Pilot opportunities for stewardship programs (including polypropylene food pails)

✔ Council, retailer and government engagement intensifies

What businesses must do in FY27:

• Update internal procedures and supplier briefs, prepare budgets for EPR impacts, and ensure label consistency at portfolio level.

  
  

FY28 (2027–2028) – Regulatory Readiness & Transition to EPR

✔ Industry expected to be ready to operate under regulated EPR frameworks

✔ Verified and auditable packaging data in place

✔ ARL program operating with strengthened governance and national consumer visibility

✔ Clear stewardship participation pathways available for soft plastics and potentially other streams

What businesses must do for FY28:

• Budget for compliance costs, embed EPR reporting obligations, ensure labelling and design systems are audit-ready.

  
  

Milestones by Category

Design & Standards

• FY26 → Release and testing of re-framed Packaging Guidelines

• FY27 → Integration into procurement/design processes

• FY28 → Recognition of compliance through EPR pathways

ARL Program

• FY26 → Technical review, iconography insights, communication changes

• FY27 → Implementation of strengthened rules and wider destination claims

• FY28 → National consumer knowledge uplift embedded

Reporting

• FY26 → Definition refinement and reporting support programs

• FY27 → New reporting tools and methodologies deployed

• FY28 → EPR reporting readiness required

Soft Plastics Stewardship

• FY26 → Partnership alignment and data settings with SPSA

• FY27 → Pilot programs, opt-in pathways and fee models

• FY28 → Full participation alignment for EPR-based operation

What Organisations Should Be Doing Now

At AWEN Consulting, we support organisations to ensure they are prepared as Australia’s packaging landscape evolves. With regulatory expectations tightening and EPR costs emerging, early action will be essential to avoid operational disruption, unplanned expenditure and reputational risk. Our services include auditing packaging portfolios against updated design and ARL requirements, strengthening data systems to enable reliable placed-on-market reporting, and supporting clients to participate in consultation processes so they can understand and influence upcoming decisions. We also assist businesses to model potential EPR fee impacts and to prepare leadership, procurement and technical teams for the implementation shifts expected from FY27–FY28. By acting now, organisations can transition smoothly, protect their investments and position themselves as credible leaders in a changing compliance environment.

If you want to stay compliant, competitive and ahead of the policy curve — now is the time to act. AWEN Consulting gives you the global EPR experience and expertise, tools and foresight to turn upcoming regulation into strategic advantage. Contact us to learn more.