Request for Member Feedback – Proposed Kerbside Recyclability Grading Framework

21 February 2025

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.

Member Action

The AFGC is seeking input from members for our submission; key areas for consideration when providing input are as follows:

Technical Classification: Commentary on material placement across grades and any identified inaccuracies.
Gaps or Omissions: Identification of materials or considerations missing from the framework.
Alignment with EPR and Eco-Modulated Fees: How the framework could work alongside financial incentives and insights from international schemes.
Alternative Pathways Grade: The role of existing or proposed product stewardship initiatives.
Business and Market Impact: How might the framework affect member supply chains, operational practices, and packaging strategies?
Implementation Challenges: Expected lead times, transition considerations and industry readiness.
Cost/Inflationary Pressures: Potential cost impacts, including changes to packaging formats, investments in production lines, and broader economic implications.

Please note all feedback provided by members will be de-identified to ensure confidentiality.

Thank you for your engagement on this important issue; AFGC requests that all member feedback be provided by Tuesday, 1 April 2025, to Sarah Collier, A/Director Sustainability, AFGC (sarah.collier@afgc.org.au).