What actually appeared

The new page is headed Improving packaging design: 2025 Stakeholder feedback, and it is the department’s summary of what it heard, not the submissions themselves. Its account of the timeline is short: the draft framework was released in December 2024, and During early 2025, stakeholders shared their feedback on it.

The headline it gives itself is There is broad support for the Framework, and on the evidence of what follows that is fair. Stakeholders backed the design-for-recyclability approach, the grading charts and most of the material gradings. Then comes the sentence that matters to anyone planning a press run against this thing: More work is required before the proposed Framework is finalised. This will include the structure and technical detail of the Framework. It will also include implementation timeframes.

Implementation timeframes are not settled. That is the answer to the question this masthead has been asking the page for six months.

ALT is the grade worth understanding, and it is the one left open

In the feedback summary it is a single line: The ‘ALT’ category was supported, but stakeholders want to know what obligations come with it. That reads like a technicality until you go back to the framework and see what ALT is.

The A to G scale grades packaging that kerbside recycling can handle. ALT sits off the end of it. The framework describes the packaging that lands there as NOT acceptable in kerbside recycling systems, and container deposit schemes and can be a litter issue or a contaminant at the majority of MRFs or reclaimers, and it gives the brand owner three options in its own words:

  • Re-design to move to a higher recyclability grading level
  • Consider moving to the "ALT" Grade - Alternative Pathway - for recovery and reprocessing
  • Eliminate product from market

The third option is the one to read twice. A grading framework that can put Eliminate product from market in front of a brand owner is not a labelling scheme, and the route that avoids it, the alternative pathway, is only open IF the min volumes/tonnage are viable. For a converter or printer, that is the difference between a redesign brief and a discontinued line.

So the position published on 11 September is this: the sector supports the existence of ALT, and does not know what being in it will require. The department has recorded that and not resolved it.

Fibre is named among the unfinished work

The framework grades five material families separately, fibre among them, and it does not rank materials against each other. Which makes one line in the feedback summary this masthead’s line: More work is needed on grading fibre, flexible plastic, and compostable packaging.

Fibre is paper and board. It is the material most of this masthead’s readers put through a press. The department has published that its grading is not finished, without saying what about it is wrong, and that is worth knowing before anyone treats a draft grade as settled.

The food grade rule was contested, and stayed

The most counter-intuitive rule in the framework is that only food products packaged in food-grade polymers can reach Grade A, on the reasoning that food-grade recovered plastic carries the highest end-market value. Non-food-contact plastic cannot get an A however well it is designed.

The sector noticed. The summary records mixed comments about food grade packaging being rated higher than non-food packaging, with some arguing it is important so there is enough recycled material for food packaging. The department reports the disagreement and does not settle it, which is consistent with the rest of the page.

Two other things the sector asked for

A wider scope. Some stakeholders want the framework to cover more than kerbside: They want it to include packaging used between businesses and look at other environmental impacts. Business-to-business packaging is a large share of what the print and packaging trade produces and it is currently outside the instrument.

Exemptions. The summary records that Some stakeholders said there should be exemptions for packaging that is essential, like medical and pharmaceutical packaging. That is the kind of carve-out that, once granted, tends to define the edges of a scheme.

What has not changed

No commencement date. No decision on whether the framework becomes part of regulation. The parent page is explicit that While governments explore options, the existing co-regulatory arrangement remains in place. Businesses must continue to meet their obligations. Brand owner audits continue, and the National Packaging Targets still stand.

For a printer or converter the practical position is the same as it was in July, with one addition. The framework is still a draft, it still grades the things a press controls, and now there is a published record that the sector broadly wants it, wants fibre grading finished, and wants to know what happens to anything that falls off the end of the scale.

What we check next

The same date, on the same page. It moved once in six months and what it produced was a summary rather than a decision. The next thing worth reporting from it is either an implementation timeframe or a finalised framework, and the department has now told us in writing that neither exists yet.