Summary
Details
- Australia
The wider regulatory framework is mandatory for businesses that meet the applicable Brand Owner requirements.
Eligible businesses must generally choose between:
Becoming a Covenant signatory and meeting Covenant requirements.
Complying with alternative state or territory arrangements under the NEPM framework
Some companies below the regulatory threshold may participate voluntarily.
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What’s Required
1. Determine whether the business is a Brand Owner
The Covenant applies to businesses in the packaging supply chain that meet the NEPM definition of a Brand Owner and have total annual turnover of A$5 million or more.
Covered businesses must determine whether they will:
Become a signatory to the Australian Packaging Covenant.
Join APCO as a Brand Owner Member.
Meet the alternative compliance requirements implemented by relevant states and territories.
2. Meet Covenant commitments
APCO members and signatories agree to work toward improved packaging sustainability and resource recovery.
Key areas include:
Packaging design.
Material efficiency.
Recyclability.
Recycled content.
Product stewardship.
Consumer disposal information.
Waste reduction.
Problematic packaging elimination.
3. Complete annual reporting
APCO Brand Owner Members are required to complete annual reporting against the Packaging Sustainability Framework. APCO states that Annual Reports are due by 31 March each year.
4. Develop action plans
Reporting is connected to forward-looking actions and commitments on packaging sustainability.
Companies may need to document:
Packaging sustainability targets.
Management responsibility.
Packaging reviews.
Supplier engagement.
Recycled content.
Recoverability.
Disposal labeling.
Waste diversion.
5. Support national packaging outcomes
The Covenant supports Australia’s broader National Packaging Targets and circular economy objectives. APCO works with governments and businesses to improve packaging design, resource recovery and recycling performance.
Important Deadlines
1999: The Covenant originated as Australia’s principal national packaging instrument.
2011: The current co-regulatory system was underpinned by the National Environment Protection (Used Packaging Materials) Measure 2011.
31 March annually: APCO Brand Owner Members submit their APCO Annual Report.
Ongoing: Businesses that meet the regulatory threshold must continue to comply with the co-regulatory arrangement. The Australian Government confirmed in September 2026 that the existing system remains in place while packaging reforms are considered.
Current Status
The Australian Packaging Covenant remains active in 2026.
The Australian Government states that the existing co-regulatory arrangement remains in place and that businesses must continue meeting their obligations while packaging regulation reform is considered. Businesses that are not fulfilling their obligations may be contacted by state or territory governments or APCO through the annual Brand Owner Audit process.
Penalties for Non-Compliance
The Covenant itself sits inside a broader co-regulatory structure, so consequences may arise through state and territory enforcement rather than solely through APCO.
Possible consequences include:
Brand Owner compliance audits.
Contact or enforcement from state and territory authorities.
Requirement to meet alternative NEPM obligations.
Membership non-compliance processes.
Reputational consequences.
Increased regulatory scrutiny.
Examples of Known Violations / Failure Modes
Typical failure modes include:
Failing to determine whether a company qualifies as a Brand Owner.
Failing to join APCO or comply through the alternative regulatory route.
Missing annual reporting.
Reporting incomplete packaging data.
Failing to implement stated action plan commitments.
Using recyclability claims that are inconsistent with Australian collection systems.
Failing to assess packaging under sustainability guidelines.
Treating APCO membership as proof that all packaging is sustainable.
Making recycled-content claims without documentation.
Ignoring state or territory implementation requirements.
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