5 November 2026

Packaging reform should begin now, an open letter to the Hon Anthony Albanese

By: Mike Ritchie, MRA Consulting Group

Dear Prime Minister,

I am writing publicly in response to the Australian Government’s decision to defer the introduction of a new national packaging scheme until a future term of government and 2028 at the earliest.

I appreciate the Government being clear about its decision. But I strongly disagree with it.

The decision appears to assume that packaging reform is primarily a new cost to households and businesses at a time when the cost of living is already under pressure.

I believe that assumption is wrong.

In fact, properly designed packaging reform is likely to reduce costs across the economy, while improving recycling, reducing waste and pollution, and creating the certainty necessary for investment in Australia’s recycling industry.

There is an important precedent for this conclusion.

Productivity Commission 2006

Twenty years ago, the Productivity Commission conducted its Waste Generation and Resource Efficiency inquiry.

The Commission’s starting point was not that governments should regulate recycling because recycling is inherently good. Its starting point was economics: government intervention should address market failures and should be justified by the net benefits to the community.

The Commission devoted a substantial section of its report to Extended Producer Responsibility (EPR). It examined the Waste Oil scheme as a case study.

The Oil scheme worked because:

1. there was an identifiable market failure;
2. the environmental costs of inappropriate disposal were not reflected in the market price;
3. the producers and importers could be identified;
4. the waste stream could be separately collected;
5. recovery outcomes could be measured; and
6. financial incentives could be directed towards the recovery of the material.

In other words, responsibility could be placed upstream, with the businesses that make decisions about the product, while incentives could be directed towards achieving measurable recovery outcomes.

That is precisely the economic rationale for a well-designed packaging EPR scheme.

Packaging has the same fundamental market failure

Today, a company placing a packaged product on the Australian market makes all of the decisions about the packaging.

• It determines the material.
• It determines the format.
• It determines whether the packaging is readily recyclable.
• It determines whether different materials are bonded together.
• It determines the labelling.

But when that packaging reaches the end of its useful life, almost all of the costs are transferred to other parties.

• Councils collect it.
• Ratepayers fund the system.
• Recyclers sort and process it.
• Landfills dispose of packaging that cannot be economically recovered.
• Governments and communities pay for litter and clean-up.
• And ultimately taxpayers and consumers bear the environmental and economic consequences.

That is a textbook market failure.

The price paid for the packaged product does not fully reflect the costs created by the packaging decisions made upstream. It also explains why the voluntary packaging scheme, the Packaging Covenant has failed to hit all of its targets and will continue to fail to achieve its targets, according to the APCO CEO Chris Foley. As a case in point one of the APCO targets is 70% of plastic packaging being recycled by 2025. It is currently 19% and has been for 6 years.

Reform should be judged on net economic benefit

This is why I believe the Government needs to undertake, and publish, a proper Regulatory Impact Statement (RIS) before deciding that packaging reform somehow adds to cost-of-living.

The RIS should not simply calculate the additional cost of collecting and recycling packaging. It must calculate the net economic effect.

That means accounting for the savings that packaging reform can deliver throughout the economy.

There are at least ten substantial areas where those savings exist:

1. Lower contamination of kerbside recycling and the associated cost of sorting and processing contaminated material.
2. Lower landfill costs as more material is diverted from disposal.
3. Lower greenhouse gas emissions, particularly through reduced virgin material production and the energy savings associated with using recycled materials.
4. Greater efficiency at pulp mills, plastic recycling plants and glass processing facilities, because better-designed and better-sorted packaging produces cleaner feedstock.
5. Lower packaging labelling costs through a nationally consistent system rather than continuing to operate with fragmented arrangements.
6. Lower waste management costs for councils, ultimately reducing the pressure on rates.
7. Avoided business failures.
8. Lower pollution and clean-up costs.
9. Lower health costs linked to microplastics
10. Greater investment certainty for recycling infrastructure and packaging manufacturers.

These are real economic costs.

They do not disappear simply because packaging reform is delayed.

The cost to consumers is tiny compared with the potential savings

Modelling undertaken by APCO and MRA indicates that a properly designed packaging scheme could cost consumers approximately 0.3 cents per packaging item, or around 20 cents for a typical weekly shop containing 60 packaged items.

Once the indirect savings listed above are taken into account, the net cost to the Australian economy is likely to be negative or zero depending on the Government’s policy objectives and the level of ambition for recycling, recycled content and litter reduction.

That is why I believe it is misleading to present packaging reform simply as an additional cost to consumers.

Packaging reform is popular

Furthermore, if the question put to voters is:

“Would you support improving Australia’s packaging sustainability and reducing plastic pollution for around 20 cents a week, while creating savings and employment elsewhere in the economy?”

The answer is overwhelmingly YES. In fact, in the September 2026 polling commissioned by the Boomerang Alliance, 87% of voters agreed that the Australian Government has a responsibility to introduce binding policies to regulate plastic packaging. 

Delay has already imposed costs

Companies have already invested tens of millions of dollars in recycling plants in anticipation of packaging reform. It was first promised by Minister Plibersek in 2023 and agreed by all State Environment Ministers.

Deferring these rules leaves those investments stranded:

• Many of those companies are now in financial distress. 
• One of the largest, Plastics Recycling Australia went into liquidation last week, placing 60 jobs at risk despite receiving millions in federal grant funding.
• Another is importing soft plastic from New Zealand because it cannot get enough soft plastic in Australia.
• The national roll out of soft plastic collection has stalled because some large retailers (understandably) are concerned it is not backed by regulation and like Redcycle before it, could fall over.
• Australia’s promised chemical recyclers for plastic have closed their doors or gone off-shore.
• The Australian Council of Recyclers is warning of imminent business failures.

Your government has provided capital grants (welcomed) to accelerate private sector investment but also repeatedly signalled a near-term regulatory framework to underpin that investment. Recyclers have taken the Government at its word. 

When the framework is subsequently deferred, the consequences are borne by those recyclers, their employees and their investors. 

The Government does not have to get every detail perfect before acting

There are legitimate questions about targets, recycled content, labelling, governance, accreditation, enforcement, transition periods and the treatment of existing packaging stocks, that need to be answered.

But these are arguments for completing the work, not for deferring it.

APCO has been trying to do this work under a voluntary arrangement but history shows us that such systems are subject to free-riders and a lack of engagement.

The Environment Ministers Meeting (EMM) has acknowledged this point in its repeated call for mandatory arrangements. 

Now is the time to act

Packaging reform has already been discussed for years. 

It requires national action coordinated via legislation by your government.

Industry, stakeholders and community have been consulted. There is a high level of frustration, made worse by the 18^thSept 2026, EMM meeting, at which Minister Watt argued for yet more consultation and taking federal action beyond 2028.

The issue is no longer whether Australia needs to understand the problem. We understand it. We understand the collapse of recyclers, the pollution of waterways, the mass confusion about recycling, the higher burden of costs being currently carried by the packaging companies and the emerging and frightening health risks of micro-plastics and PFAS.

The issue is whether your Government will grab this opportunity to reform packaging (and be widely praised for it by State governments, industry, consumers and most voters).

The economic logic established by the Productivity Commission in 2006 remains unchanged: “Government intervention should be directed at genuine market failures and be judged by its net community benefit.”

The appropriate response to concerns about the cost of living is therefore not to defer reform, but to undertake a transparent RIS and then implement a mandatory framework that reduces existing, hidden, system-wide costs.

I therefore urge you to reconsider your decision and move forward with packaging reform without delay..

Yours sincerely,

Mike Ritchie

Managing Director, MRA Consulting Group

---

If you would like further information, please contact us at info@mraconsulting.com.au

---

This article has been published by the following media outlets:

---

---