Summary
Details
- Australia
Reporting against the relevant APCO framework is mandatory for APCO Brand Owner Members subject to annual reporting requirements.
The Framework is not a general Australian law that applies automatically to every company.
Businesses may voluntarily use its principles even when they are outside APCO membership requirements.
Deep dive
- What’s Required
- 1. Governance and strategy
- 2. Design and procurement
- 3. Recycled content
- 4. Recoverability
- 5. Disposal labeling
- 6. On-site waste
- 7. Problematic materials
- 8. Annual APCO reporting
- Important Deadlines
- Current Status
- Penalties for Non-Compliance
- Examples of Known Violations / Failure Modes
- Resources
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What’s Required
1. Governance and strategy
Companies are expected to integrate packaging sustainability into business strategy.
This can include:
Formal packaging policies.
Objectives and targets.
Executive oversight.
Procurement procedures.
Product development processes.
Internal communications.
Stakeholder engagement.
2. Design and procurement
Companies should apply sustainable packaging principles to both existing and new packaging.
APCO expects businesses to use the Sustainable Packaging Guidelines, or equivalent principles, when reviewing packaging design and procurement.
3. Recycled content
Members assess actions taken to increase or optimize recycled material in packaging while considering safety and product-quality constraints.
4. Recoverability
Companies assess whether packaging can be recovered through collection systems accessible to most Australian customers.
This includes:
Kerbside recycling.
Drop-off systems.
Reuse.
Recycling infrastructure.
End-of-life design.
5. Disposal labeling
The Framework evaluates whether consumers receive clear information about what to do with packaging at end of life.
Relevant systems include the Australasian Recycling Label.
6. On-site waste
Companies assess the proportion of operational solid waste diverted from landfill through reuse, recycling, composting or other recovery routes.
7. Problematic materials
The Framework evaluates progress in eliminating problematic and unnecessary single-use plastic packaging and other problematic materials.
8. Annual APCO reporting
APCO Brand Owner Members must submit an Annual Report.
Different reporting formats apply depending on company size and sector, including:
SME Report.
Full Framework.
Packaging Manufacturer/Supplier Framework.
APCO’s current guidance states that Brand Owner Members with annual turnover above A$50 million generally use the Full Framework or the specific manufacturer/supplier version, while smaller members may use the SME reporting route.
Important Deadlines
31 March each year: APCO Annual Reports are due.
From the financial year following membership: Brand Owner Members are required to complete annual reporting based on the Framework.
Ongoing: Action plans and progress are updated through successive reporting cycles.
Current Status
The Packaging Sustainability Framework remains active in 2026 and continues to underpin APCO Annual Reports and Action Plans. Current 2026 member reports continue to use Framework criteria for governance, design, recycled content, recoverability and related commitments.
Penalties for Non-Compliance
Possible consequences include:
APCO non-compliance procedures.
Brand Owner audit scrutiny.
Requirement to correct or complete reporting.
Regulatory attention where Covenant obligations are not met.
Reputational consequences.
Loss of credibility for sustainability claims.
Examples of Known Violations / Failure Modes
Typical failure modes include:
Missing the annual reporting deadline.
Incomplete packaging metrics.
Weak documentation supporting recycled-content claims.
Reporting packaging as recyclable where no accessible recovery system exists.
Failing to review packaging using the Sustainable Packaging Guidelines.
Not implementing Action Plan commitments.
Inconsistent data between suppliers and internal systems.
Using disposal labels that do not reflect actual recovery routes.
Treating Framework performance as certification.
Failing to address problematic materials despite identified risks.
Resources
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