Summary
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Details
- Australia
The Australian co-regulatory packaging framework (APCO/NEPM) applies to “brand owners” that place packaging or packaged products on the Australian market. Your organization must collect and submit packaging information annually if all the following apply:
- Business type: You are a brand owner (e.g., the product trademark/brand owner; if overseas, this may be the Australian importer, licensee or franchisee).
- Financial threshold: Your Australian annual turnover is AUD $5 million or more.
- Packaging activities: You make, import, distribute or sell packaged goods (including supplying in-store packaging), thereby placing consumer packaging on the market.
Deep dive
Introduction
Australia manages packaging through a co-regulatory framework that pairs an intergovernmental legal instrument with an industry-led covenant. The legal backbone is the National Environment Protection (Used Packaging Materials) Measure (UPM NEPM), originally established under the NEPC framework and re-made in 2011, which participating states and territories implement and enforce through their own laws. The industry arm is the Australian Packaging Covenant, administered day-to-day by the Australian Packaging Covenant Organization (APCO). This model traces back to the National Packaging Covenant announced in 1999 and supports national goals to reduce waste and transition to a circular economy for packaging.
What companies must do (reporting & fees)
Businesses that follow the APCO pathway pay membership fees based on annual turnover. For the 2026 financial year, these fees range from AUD $653 (for turnover up to $5 million) to AUD $340,010 (for turnover over $15 billion). As provided by the Australian Packaging Covenant, obligations also include the submission of both an APCO Annual Report (due 31 March) and an APCO Action Plan (due 31 May) each year through APCO’s online reporting platform. These are framed by APCO as mandatory obligations for Brand Owner members, i.e. entities directly responsible for packaging placed on the market. In the Annual Report, members report against the criteria set out in the Packaging Sustainability Framework, including detailed packaging metrics. Examples of completed reports are available on APCO’s public register, which lists more than 2,300 members and signatories as of September 2025. APCO does not impose weight- or material-specific producer fees, as is the case with, for example, the UK Extended Producer Responsibility (EPR) for packaging scheme. Membership fees are instead based solely on turnover. As an alternative to joining APCO, companies can choose to comply directly with state or territory regulators under the NEPM or participate in a product stewardship scheme that delivers the same outcomes as an APCO membership.
Consequences of Non-compliance
Failing to fulfill the obligations described above may initiate the Non-compliance Procedures laid out in Schedule 5 of the Australian Packaging Covenant. Noncompliance can ultimately lead to suspension of access to exclusive APCO member resources and tools as well as referral to government regulators. State and territory EPAs enforce NEPM obligations through local regulations. For example, in New South Wales, the Protection of the Environment Operations (Waste) Regulation 2014 sets requirements for brand owners and retailers that are not APCO signatories (or fail to comply), and provides powers for compliance action and penalties. NSW provisions also specify responsibility for packaging types and record-keeping duties; other jurisdictions (e.g., Victoria) publish parallel compliance guidance under the NEPM for liable businesses.
Current Status and Reforms
As of September 2025, Australia’s co-regulatory system remains in force while the federal government advances reforms to packaging regulation. The Department of Climate Change, Energy, the Environment and Water (DCCEEW) consulted in September–October 2024 on options to deliver a circular packaging economy. Ministers have signaled the need to strengthen and modernize the regime, and DCCEEW notes further policy development is underway. Until new legislation commences, businesses must continue meeting obligations either by joining APCO and submitting annual reports/action plans or by reporting directly to state and territory regulators under the NEPM. Companies should therefore maintain current compliance arrangements while monitoring the government’s reform process for potential shifts toward a more comprehensive EPR model and nationally consistent requirements. Further consultation will precede any final law and commencement dates.
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