Incorporating circular economy not as easy as it seems

APCO is what is called a co-regulatory body, whose role it is to administer the Australian Packaging Covenant.

“The Australian Packaging Covenant is a regulatory framework that sits under the National Environmental Protection Measure for used packaging. It is very firmly a co-regulatory body,” said Donnelly at a speech she gave at AUSPACK 2019 in Melbourne. “If you think about product stewardship, there are a couple of ways in which you can do that. You can do it in a voluntary sense, which is the industry getting together and deciding to do something. You can do it in a co-regulatory sense, which is industry and government getting together to do something, or you can do it in a mandatory sense, which is the government telling the industry what to do. We’re in what I like to think is the nice place in the middle, where we’re working together and we’ve got a framework to work to.”

The covenant has been going for 20 years, and every five years a new strategic plan is put in place that is agreed between industry and government together. In 2016, both industry and government got together to begin looking at a new approach. The covenant had been around for quite some time and it was struggling to find a way to deliver effectively to industry and government on the packaging changes that needed to happen. Government and industry looked at what model could be applied – looking particularly at the circular economy.

“We had a mandate in the 2017 strategic plan to deliver the sustainable packaging pathways in Australia through a circular economy model, which is no small feat,” said Donnelly. “It’s wonderful to talk about circular economy conceptually, but it is quite difficult to deliver in an operational sense, because it does require a complete transformation of the entire packaging ecosystem. That requires a level of collaboration and is driven through a collective impact model, which is all about shared value. If one of us doesn’t get there, none of us get there – that means you’ve got to take everybody on that journey with you. When you have 1,500 organisations and eight different governments (including states, territories and federal), that’s quite the challenge. So a co-regulatory body has a big task in terms of bringing stakeholders along the journey and getting everybody to where they need to be to be effective in this space.”

They focussed on four key areas. One is helping with the Sustainable Packaging Guidelines (SPG), which APCO has reviewed, with the end result being a new version of the SPG due out at the end of 2019. They are also at the forefront of providing a prep tool, which is a packaging recyclability portal, that is available to all APCO members, giving them the ability to actually know that they are designing packaging that has the ability to be recycled.
The second area APCO focussed on helping businesses identify and develop operational systems required for this work. Some of the key resources in this area are about strategic partnerships – bringing together organisations that otherwise would have no alignment with each other, other than that they have a similar end of life material.

“For example, we have 1,500 organisations that represent 153 different ANSZIC codes,” she said. “And if you can end up with an airline, a homewares company, a retailer and a pharmaceutical who, in any other sense, would probably not be having conversations – but who all have a similar material that they may need to deal with at end of life – that gives you the ability, in terms of looking at programs and options going forward, of scaling up material volumes and models that previously may not have been economically or operationally viable. That is because the limited scope of the material available can actually be scaled up on that collective impact model.”

The third area is education. The Australasian Recycling Label is the flagship piece of work for APCO in terms of helping industry and governments to communicate with consumers/communities about packaging and how to deal with packaging at end of life.
Finally, the fourth area is about material circularity. There’s no point recycling a piece of packaging unless it has a home to go to that has a value, said Donnelly. Material circularity is about dealing with the end market and creating a sustainable ecosystem for post-consumer recyclables.

Donnelly also touched on China’s national sword policy that reduced the amount of impurities it would allow in recycled materials coming from countries like Australia. And this, said Donnelly, is where Australian food, beverage and other industries that rely on packaging need a change in mindset.

China’s new policy saw the value of recycled materials drop through the floor. What this did was highlight the economic impact of the decision within Australia and whether it was palatable to have that level of risk on the global market for a commodity item such as waste.

“After much conversation among industry and government, it became obvious that that level of risk was not palatable,” said Donnelly. “So what’s our alternative? Our alternative is that we must create a domestic market and domestic opportunities for those materials to be used. Here there is a big transformation that’s required. APCO did a report that is available on our website, and that was completed around the time the China national sword policy was announced. That was one of the key things that really drove the need to do something different to what we’ve been doing traditionally. That coupled with the sustainable development goals and consumers’ greater awareness coming from things like ‘The War on Waste’, really drove a need to take a very different approach.”

In April 2018, APCO met with the state and federal environment ministers to discuss how APCO could support the response to these issues. Initially, the organisation went through a series of ways it could do that and it also tried to look how it could reach a target that could enable it to have something for companies to work towards.

“It was at that point that the 100 per cent target with regard to packaging being reusable, recyclable or compostable by 2025 was endorsed by every government in Australia, including federal,” said Donnelly. “We then went away and, in coordination with industry and government, we sat down and spent about six months working through what other targets and what other areas needed to be addressed to support such an audacious target. There were a range of targets that were discussed, but the consensus and the agreement in the end was around three other sub-targets that support that 100 per cent target. We talked about 70 per cent of plastic packaging being recycled or composted.”

Another target was 30 per cent average recycled content across all packaging.

“This is very much about driving the pull,” she said. “We need a pull in the market to give a home to these materials, and there’s no home if the home doesn’t have a value. Looking at recycled content is about understanding how we can get recycled content into certain material. And this is not a ‘purist version’ of bottle to bottle, this is about finding a home for materials that can be recycled across a range of activities. This conversation is very open about what the solution can be.

“You’ll note that the target is an average recycled content, and that is because recycled content can’t go into all packaging. There are some things that it can’t go into and that is really challenging – things like pharmaceuticals, some food products – and if you’re looking at a 30 per cent recycled content target, really the focus area is about looking, initially, at your tertiary packaging and your secondary packaging. And primary packaging is something that we can look at, but not where we would be suggesting to start from a strategic viewpoint.”

The final target APCO mentioned was phasing out problematic and unnecessary single-use plastic packaging through re-design, innovation or alternative delivery methods.

“This is a big, contentious area,” said Donnelly. “This is the whole space where people are talking about plastic-free and all these kinds of things. What’s bubbling up from this is a need to recognise that there are some packaging materials where we just shouldn’t use single-use plastics. But here’s the thing – if you’re not going to do that, you need to have a plan on what your alternative is. There’s no point in banning straws or balloons, and that’s what we’ve seen recently. Some councils have come out and banned things like straws and then they’ve had an issue with the disability sector, where some people need straws to consume food. We need to be working through alternative models and planned pathway for transitioning away from these materials.

“It’s not that you shouldn’t transition away from things. There are going to be some materials that are just simply too hard to recover, or not recoverable, which we can use alternative materials for, but we need to do the work and planning for what those things will be, and for that transition pathway.

“You’ll see some news pieces around people and certain industry sectors pushing back and saying we should mandate recycled content. Well, we’ve got to agree on what recycled content is first. In this space right now, we are in a very big transition and it’s a transition that needs to be done in a considered way. It is about making sure that we have the best possible outputs and outcomes in a considered way so that we don’t drive perverse outcomes.”