The AEPLG welcomes the opportunity to comment on the potential options to reform Australia’s packaging regulation to minimise packaging waste and plastic pollution and to support the transition to a circular economy for packaging.1 The AEPLG continues to support a national approach to waste management in order to facilitate a coherent, efficient, and environmentally responsible approach to waste r. [...] Requiring manufacturers and importers to take responsibility for product packaging is consistent with: (a) the objects in section 4 of the Recycling and Waste Reduction Act 2020 (Cth) (RAWR Act), which aim to develop a circular economy through product stewardship by ‘encouraging and regulating manufacturers, importers, distributors, designers and other persons to take responsibility for products’;. [...] The rules may, for example: (a) prohibit, limit or restrict substances from being contained in the product; (b) require the product to be labelled or marked in accordance with the rules; (c) specify requirements in relation to product packaging and design; (d) specify requirements in relation to the durability, reparability and reusability of the product; (e) specify requirements in relation to co. [...] Clearer product labelling The AEPLG understands that the purpose of the reforms is to improve packaging design for recyclability, and for packaging to display mandatory recycling labelling. [...] The recycling labelling on plastics and cardboard could be improved by increasing the size of the recycling symbol, so that it is clear to consumers that the product is capable of recycling.
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Table of Contents
- 25 October 2024 1
- Mr David Fredericks PSM Secretary Department of Climate Change Energy the Environment and Water GPO Box 3090 Canberra ACT 2601 packagingreformdcceew.gov.au 1
- By email 1
- Dear Mr Fredericks 1
- Reform of packaging regulation Consultation paper 1
- This submission has been prepared by the Australian Environment and Planning Law Group of the Law Council of Australias Legal Practice Section. 1
- AEPLG 1
- EPR 1
- Senate Waste and Recycling Report Product Stewardship Act 2011 1
- Support for financial and market incentives 2
- Recycling and Waste Reduction Act 2020 2
- RAWR Act 2
- Environmental 2
- Protection and Biodiversity Conservation Act 1999 2
- Cth which relevantly provide that improved valuation pricing and incentive mechanisms should be promoted. 2
- Mandatory product stewardship requirements 2
- Part 5 of the RAWR Act provides for the requirements of mandatory product stewardship which may be prescribed by rules as set out in section 92 of the RAWR Act. The rules may for example 2
- We suggest that the eco-modulated EPR fees proposed by option 3 could be used to implement a system to measure industrys performance against minimum recyclability performance standards. 3
- Clearer product labelling 3
- Improved implementation and education strategies 3
- Conclusion 3
- The AEPLG would welcome the opportunity to discuss this submission with the Department. In the first instance please contact AEPLG Deputy Chair Ms Charmian Barton 4
- Yours sincerely 4
- Geoff Provis Section Chair 4
