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Briefs

Call for input into the Design for Kerbside Recyclability Grading Framework

Call for input into the Design for Kerbside Recyclability Grading Framework

13 March 2025

Background 

The Department of Climate Change, Energy, the Environment and Water (DCCEEW) has released the proposed Design for Kerbside Recyclability Grading Framework. Consultation closes on 18th April 2025.  

The proposed framework, developed by the independent National Packaging Design Standard Working Group, is intended to support a reformed regulatory scheme for packaging.  

DCCEEW is seeking feedback on this framework to ensure it is robust and practical and avoids unintended consequences for the industry.  DCCEEW have noted that the publication of the Framework does not presuppose a specific form of future reform, such as an EPR scheme or eco-modulated fees for packaging. 

The AFGC is seeking member input on how this framework applies to current packaging formats. Your case studies will help assess practical implications, challenges, and unintended consequences arising from this framework. 

Member Action 

Members are requested to provide case studies detailing the impact of the framework on their packaging formats. This information will support the AFGC in providing industry-wide feedback on feasibility, cost, timing, emissions, food waste, product safety, regulatory contradictions, and supply chain impacts. 

Examples of feedback we are seeking: 

Packaging Format Constraints 

  • Cases where a format cannot change due to functional or regulatory requirements (e.g., food safety, hazardous goods, medical packaging). 
  • Instances where alternative materials compromise performance or durability. 
  • Small size packs  

Unintended Consequences & Challenges 

  • Potential trade-offs in recyclability versus performance. 
  • Increased costs, operational disruptions, and supply chain issues. 
  • Overseas market implications, particularly for globally distributed products. 
  • Difficulty in accessing traceable recycled content. 
  • Increased lifecycle emissions from the packaging or reduced shelf life.

Change Feasibility & Decision Points 

  • Estimated cost and time required to implement design changes. 
  • Internal decision-making process: key factors influencing material selection and format retention. 
  • Examples where packaging changes have been successful despite challenges. 
  • Barriers to change, including regulatory inconsistencies across jurisdictions. 

We request that all feedback and input be provided to the Sustainability Team by 1 April 2025.  Please note that all member input will be de-identified to ensure confidentiality. 

Your contributions are essential in ensuring industry perspectives are considered when by DCCEEW in relation to the proposed new grading framework. We appreciate your input and look forward to your submissions. 

If you have any questions or would like to discuss the proposed new framework, please feel free to contact me at sarah.collier@afgc.org.au.

Sarah Collier
Acting Director – Sustainability