Australia EPR
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Packaging
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Packaging
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Battery
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Textile
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Textile
Packaging
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Textile
Packaging
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Textile
Australia EPR for Packaging
Australia does not have one single “EU-style” national packaging EPR registration system. Instead, packaging producer responsibility is implemented through a co-regulatory framework combining:- The Australian Packaging Covenant (APC) (industry + government agreement) run by APCO
- The National Environment Protection (Used Packaging Materials) Measure 2011 (NEPM), applied through state/territory regulator
- Federal product-stewardship settings that allow and support co-regulatory arrangements
- Join APCO (as a Brand Owner Member / Covenant signatory) or comply directly under NEPM requirements, and
- Report annually and maintain a packaging sustainability action plan, and
- Use national tools/standards (e.g., ARL/PREP) and work toward national packaging targets.
What is Australia EPR for packaging
Producer Responsibility / EPR (in practice) in Australia is primarily the Australian Packaging Covenant (APC) framework, delivered by the Australian Packaging Covenant Organisation (APCO) as a co-regulatory approach to reducing packaging impacts. The APC focuses on:- Sustainable packaging design
- Increasing recycling and recovery
- Reducing litter and leakage
- Transparent annual reporting and continuous improvement
Does this apply to e-commerce & online sales
Yes — if your business is a “brand owner” placing packaging on the Australian market, online channels don’t change the obligation. This commonly includes:- E-commerce brands shipping direct to Australian consumers (B2C)
- Importers selling packaged goods online in Australia
- Marketplace brands (if you own/control the brand on the pack and place goods on the AU market)
Who is the “producer” in Australia packaging EPR
Australia typically uses the term “brand owner” (not “producer”) for packaging obligations. A brand owner is usually the organisation that:- Owns the brand on the packaging, or
- Imports packaged goods under its own brand, or
- Controls the packaging specifications and places the packaged product on the Australian market
Who must register / comply for packaging EPR in Australia?
The common threshold (APC / APCO scope) The APC generally applies across the packaging supply chain, and APCO materials describe the Covenant applying to businesses in the supply chain with turnover greater than AUD $5 million. Compliance routes Businesses typically comply by either:- Joining APCO as a Brand Owner Member / Covenant signatory (the most common route), or
- Complying directly with NEPM requirements via relevant state/territory processes.
Australia EPR Packaging — Registration Threshold (2026)
Australia currently does not have a single, fully mandatory national Extended Producer Responsibility (EPR) law for packaging (as exists in many EU countries). Instead, packaging is regulated under a co-regulatory framework combining:
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National Environment Protection (Used Packaging Materials) Measure 2011 (NEPM) — national standards and state enforcement
-
Australian Packaging Covenant / Australian Packaging Covenant Organisation (APCO) — industry-led compliance mechanism
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Ongoing federal reforms that may introduce a stronger, more formal EPR scheme in future .
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Packaging covered (and excluded)
Covered (typical scope)
Australia’s co-regulatory packaging approach covers consumer packaging placed on the Australian market, across common material categories:- Plastic (rigid and flexible)
- Paper and cardboard
- Glass
- Metals (aluminium/steel
- Composite/multi-material packaging
- Retail
- Wholesale
- E-commerce shipping (secondary/transport packaging where relevant to the brand owner’s operations)
Exclusions (practical)
There is no single universal “exclusion list” identical across all Australian jurisdictions and programs. In practice, the scope you must address is defined by:- APCO’s reporting framework (Packaging Sustainability Framework + metrics), and/or
- State/territory NEPM interpretation and enforcement
Producer Responsibility Organization (PRO) in Australia
In Australia, APCO functions as the main industry body operating the Covenant system (similar to a PRO role in practice), including:- Annual reporting tools and frameworks
- Guidance and programs for sustainable packaging
- National targets progress tracking
- ARL/PREP programs (with partners)
EPR “registration” in Australia (what you actually do)
Step 1 — Determine if you’re a “Brand Owner” under the Covenant/NEPM If you place packaged products on the market and exceed the turnover threshold, assume you’re in scope unless advised otherwise. Step 2 — Join APCO (most common compliance route)- Become an APCO Brand Owner Member / Signatory
- Pay membership fees (commonly structured around turnover)
Authorized representative (Australia)
Australia generally does not operate like EU EPR countries where overseas sellers must appoint a formal authorised representative for packaging EPR. Instead, responsibility typically sits with:- The Australian brand owner, or
- The Australian importer/distributor placing goods on the market
What data must be reported
APCO annual reporting typically includes two major components:- Packaging Sustainability Framework (PSF)
- Packaging metrics (quantitative)
- Packaging material types used
- Volumes/weights placed on market (often by material)
- Recyclability outcomes and design change
- Use of recycled content (where relevant
- Progress against targets and internal commitments
ARL / PREP-related data (if you use the label)
If you adopt the Australasian Recycling Label (ARL), you typically need:- A PREP assessment for packaging component
- Evidence-based recyclability outcomes for correct on-pack disposal instructions
First reporting period (when do obligations start?)
For APCO signatories:- Reporting begins from the financial year following the year you become a signatory/member, using APCO’s reporting tools and deadlines.
- State/territory compliance expectations apply based on NEPM processes and regulator requirements.
EPR reporting deadlines (APCO)
APCO’s published Covenant obligations include:- Annual Report due: 31 March each year
- Action Plan due: 31 May each year (submitted after the Annual Report)
Labels & Marketing claims in Australia
Australasian Recycling Label (ARL)
Mandatory label for EPR products in Australia
If your product is placed on the Australian market, it must comply with the Australian Packaging Covenant (APCO) and national packaging sustainability obligations.
An example of what a label looks like on packaging for Australia
Australia requires clear consumer sorting information on packaging.
The ARL symbol is an mandatory label in Australia showing that the packaging must be sorted and recycled through the national EPR system.
📎Download the ARL Logo from Lappa:
- PNG – best for digital use.
EPR eco fees & eco-modulation
Australia’s system is not yet universally structured as “eco-fees per kg per material” nationwide like many EU systems. Today, the most common “fee” structure businesses experience is:- APCO membership fees (often turnover-based), plus
- Internal costs for packaging redesign, testing, PREP/ARL assessments, and reporting
- EPR strengthening
- Eco-modulation (fees that reward recyclable design and penalise problematic materials)
Risks, penalties & common mistakes
Main risks
- Being non-compliant with APC/NEPM expectations (including reporting)
- Audit risk under NEPM processes (brand owners can be audited)
- Reputational risk (especially for consumer brands and retailers)
- Supply chain pressure (retailer sustainability requirements)
- Incorrect recycling labels/claims → consumer trust and enforcement exposure
Common mistakes (especially for e-commerce brands)
- Assuming “online-only” businesses are out of scope
- Not tracking packaging weights/materials early (makes reporting painful)
- Treating ARL as a marketing badge without a PREP evidence base
- Missing APCO reporting dates (31 March / 31 May)
- Overclaiming recyclability or using incorrect disposal instructions
What e-commerce sellers should do now (Australia checklist)
- Confirm who the brand owner is for each product/SKU sold in Australia
- Check whether you exceed AUD $5m turnover threshold and fall into APC/NEPM scope
- Join APCO (or document your direct NEPM compliance approach)
- Build a packaging data model: SKU → packaging components → material + weight
- If using recycling labels, adopt ARL via PREP assessments
- Align packaging design with national targets and retailer expectations
- Set a compliance calendar:
- Annual Report: 31 March
- Action Plan: 31 May
- If you sell beverages, understand interactions with Container Deposit Schemes (CDS)
Easy to use EPR Software to calculate Eco-fee
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FAQ
Is Australia “EPR registration” like Germany/France?- Not exactly. Australia’s packaging responsibility is mainly co-regulatory (APCO/APC + NEPM), not a single national “register + PRO fee per kg” system.
- The APCO/Covenant threshold is commonly described as turnover > AUD $5m, but specific obligations can depend on your structure and state/territory interpretation under NEPM.
- Not mandatory for all packaging, but it’s the leading standard for clear disposal instructions and helps reduce consumer confusion. If you use it, it must be evidence-based via PREP.
- They are a related but separate policy instrument focused on beverage containers. Australia now has CDS programs across all states/territories, with Tasmania commencing 1 May 2025 (the final jurisdiction to implement one).
Battery EPR law in Australia: None enacted
Australia is not among the countries with enacted battery EPR legislation at the federal level.
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What is Australia EPR Textile
Australia does not yet have a fully mandatory nationwide textile EPR regime. Instead, textile stewardship is governed under the Product Stewardship Act 2011, administered by the Department of Climate Change, Energy, the Environment and Water (DCCEEW). Textiles (including clothing, footwear, and household textiles) are identified as a priority waste stream under the National Waste Policy Action Plan 2019. The current framework is primarily voluntary or co-regulatory, but the government is actively progressing toward stricter, potentially mandatory textile stewardship requirements.Does this apply to e-commerce & online sales
Yes. Textile stewardship obligations in Australia are expected to apply to all entities placing products on the market, including:- Domestic manufacturers
- Importers
- Distance sellers shipping directly to Australian consumers
- Online marketplaces facilitating sales
Who is the “producer” under Australia EPR?
Under the Product Stewardship Act 2011, the “producer” generally includes:- Australian manufacturers
- Importers placing textiles on the Australian market
- Brand owners and private label companies
- Distance sellers without a local importer
Who must register for EPR textiles in Australia
There is currently no single mandatory national register for textiles. However, companies may be required to participate in approved or emerging stewardship schemes. Obligations typically include:- Registration with a relevant product stewardship scheme
- Submission of product and volume data
- Payment of applicable contributions
Australia EPR Textile Registration Threshold
At present, no harmonized national thresholds apply to textile EPR in Australia. However, existing and upcoming schemes may introduce:- Turnover-based thresholds
- Volume thresholds (e.g. kilograms of textiles placed on the market)
- Exemptions for small businesses
Detailed EPR Guidance for each Jurisdiction
We support 36 jurisdictions
Textiles Covered (and Excluded)
The scope of textile stewardship initiatives typically includes:- Clothing and apparel
- Footwear
- Household textiles (e.g. bedding, towels, curtains)
- Industrial textiles
- Personal protective equipment (PPE)
- Certain second-hand or reused products, depending on scheme rules
Producer Responsibility Organization (PRO)
Australia does not yet operate a single centralized textile PRO. Instead, stewardship is driven by industry-led initiatives and government-supported programs. Key organizations include:- Australian Fashion Council (AFC)
- Sustainability Victoria
EPR Registration in Australia
Where participation is required, the registration process generally includes:- Identifying the applicable stewardship scheme
- Submitting company and product information
- Entering into a participation agreement
- Paying required fees
- Receiving confirmation of registration or membership
Authorized Representative
Foreign companies without an Australian legal entity may need to:- Appoint a local authorized representative, or
- Work through an importer or distributor
What Data Must Be Reported
Typical reporting requirements include:- Total weight of textiles placed on the market
- Product categories (apparel, footwear, household textiles)
- Material composition (e.g. cotton, polyester, blends)
- Number of units (if required by the scheme)
First Reporting Period & EPR Reporting Deadlines
As textile EPR is not yet fully standardized in Australia, reporting timelines depend on individual schemes. Generally:- Reporting begins upon joining a scheme
- Reporting is conducted annually
- Deadlines are defined by the relevant organization
Labels & Marketing Claims
Textile products in Australia must comply with:- Australian Consumer Law (ACL)
- Mandatory fiber composition labeling requirements
EPR Eco Fees & Eco-Modulation
Where applicable, eco fees are typically calculated based on:- Weight of textiles placed on the market
- Material type
- Product design characteristics
- Recyclability of materials
- Use of sustainable fibers
- Product durability
Risks, Penalties & Common Mistakes
Common compliance risks include:- Failure to register with applicable stewardship schemes
- Failure to report data or inaccurate reporting
- Ignoring e-commerce and cross-border obligations
- Making misleading environmental or marketing claims
- Financial sanctions under the Product Stewardship Act 2011
- Enforcement actions by the ACCC
- Reputational and commercial risks
What E-Commerce Sellers Should Do Now
- Determine whether you qualify as a “producer” in Australia
- Identify relevant textile stewardship schemes
- Implement systems to track product data (weight, materials, volumes)
- Review labeling and environmental claims for compliance
- Monitor upcoming regulatory changes and prepare for mandatory EPR
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FAQ
Is textile EPR mandatory in Australia?- Currently, textile EPR in Australia is not fully mandatory at a national level. It operates mainly through voluntary and co-regulatory schemes under the Product Stewardship Act 2011, but stricter regulatory measures are under development.
- Yes. Foreign sellers may be considered the “producer” if they place textiles directly on the Australian market without a local importer. In such cases, they are expected to meet stewardship obligations or work through a local representative.
- There is no unified national threshold yet. However, individual schemes may introduce turnover or volume-based thresholds, and exemptions for small businesses may apply depending on the framework.
- Textiles must comply with Australian Consumer Law (ACL), including accurate fiber composition labeling. Environmental claims must follow guidance from the Australian Competition and Consumer Commission (ACCC) and must not be misleading.
- Potentially, yes. While current obligations focus on producers and importers, regulators are increasingly examining the role of marketplaces, especially where they facilitate cross-border sales into Australia.