Packaging · Regulation

Ministers will examine strengthening the Covenant you already answer to, and explore adding recyclable design and labelling

The question this masthead has asked since July is which route packaging reform would take: the private senator’s bill, a new Commonwealth scheme, or an agreement between governments. On 18 September 2026 the Environment Ministers’ Meeting answered it. Ministers agreed a Circular Economy Roadmap and tasked officials with examining options with Industry, local government and other stakeholders, to strengthen packaging regulation through existing co-regulatory arrangements. That means the Australian Packaging Covenant and the Used Packaging Materials NEPM, the two instruments brand owners already answer to. The roadmap’s six-month list for packaging is mostly about design, and design is where a printer or converter comes in.

Published 5 October 2026 · The Print Register · 6 sources

What ministers asked for in March, and what they agreed in September

At their March meeting, ministers wrote that The Australian, state, territory and local governments are committed to the reform of national packaging regulation, and they tasked officials to return to the next EMM with a draft intergovernmental agreement to deliver options for nationally consistent product stewardship arrangements, with a focus on batteries and packaging. They also commissioned a circular economy roadmap by mid-2026.

Two ministers’ meetings were held in between, in June and July, and both were about H5 bird flu, as we reported in August. The department labels the 18 September communique as Meeting 9, the next general meeting after March. It does not mention an intergovernmental agreement on packaging; the word “intergovernmental” does not appear in it, on our reading of the published PDF on 5 October. What it records instead is that ministers agreed the Circular Economy Roadmap (Roadmap) and proposed actions, and tasked officials with the co-regulatory work quoted above and with developing a packaging reform plan for the future under the National Competition Policy. Both pieces of work are for discussion at the next Environment Ministers Meeting, which the communique does not date.

The urgency language is stronger than the mechanism. Ministers all agree that packaging reform remain an urgent and important environmental priority for Australia, with almost all single use plastics entering the Australian waste stream coming from packaging, and that packaging being both significantly reduced and designed to be recycled is a crucial part of packaging reform, as are design standards.

Why it went this way

Ten days before the meeting, on 8 September, the Australian Packaging Covenant Organisation said it was disappointed that a new Commonwealth scheme for packaging will not be introduced in this term of Government, as reported recently. That is APCO’s account, and it does not cite a ministerial statement; we have not found one to read, so we attribute it to APCO. It fits the government’s position in the Senate in August, when it declined to support the No Time to Waste bill. APCO’s same statement made the point every brand owner should keep: Obligations under the NEPM continue to apply, and the Covenant remains the pathway through which most Australian businesses meet them.

The six-month list, item by item

The roadmap’s action pathway splits the work into three columns: Respond, labelled Next 6 months; Reform, Next 2 years; and Embed, Through to 2035. For packaging, the Respond column says officials will Examine options, in consultation with industry, to harmonise and strengthen existing co-regulatory arrangement, naming the NEPM and the Covenant, Including exploring adding to co-regulatory scheme four things:

recyclable design
recovery and recycled content outcomes
liability thresholds, which decide who is caught
labelling

Alongside those it lists three more lines: Commit to strengthening NEPM monitoring and enforcement; Explore applying the Commonwealth’s Design Framework as a national harmonised approach to packaging recyclability and design; and Build evidence base with further cost benefit analysis and modelling. The roadmap’s key shades this block as Commonwealth-led.

A second packaging block, shaded as state-based, lists items to consider for the National Competition Policy process: bans of problematic plastic items, a national container deposit portal and list of accepted containers, and National kerbside recycling collection lists.

Read the verbs before planning around any of it. “Examine”, “exploring adding” and “explore applying” are not decisions. The only firm verb in the packaging block is the commitment to stronger NEPM monitoring and enforcement. The Reform column is explicitly conditional: Subject to future government decision making processes and parliamentary processes, amend the National Environment Protection Council Act 1994, and Commence any agreed updates to strengthen existing packaging arrangements.

The design framework is the part that touches a press

The roadmap does not name the “Commonwealth’s Design Framework”. The design framework the department has published for packaging is the Design for Kerbside Recyclability Grading Framework, the A to G scale that grades the things a printer controls: material, inks, adhesives and labels. That is our reading of which document is meant, not the roadmap’s words. On 5 October the department’s reform page, last updated 11 September, still said A decision has not yet been made regarding the Framework’s use and application.

So the position is this: the framework has no decided use, and ministers have now named applying a Commonwealth design framework as one of the things to explore in the next six months, inside an instrument brand owners are already bound by. On 30 September we reported that fibre grading is among the unfinished work. That matters more if the framework is applied.

What it means for a print or packaging business

Nothing changes today. The NEPM and the Covenant already apply, and none of the roadmap items has been decided.

The timeline is short, if it holds. Counted from the 18 September meeting, “next 6 months” runs to about March 2027. That is our arithmetic; the roadmap gives no start date for its columns.

Our view. A new national scheme would have needed new law and a new administrator. Strengthening the Covenant does not need either, so if design and labelling requirements arrive they are likely to arrive as Covenant obligations on your customers, the brand owners, and then as specification changes on your jobs: an ink system, an adhesive, a label construction, a recyclability claim on the pack. A converter who can document what a pack is made of is placed for that. The “liability thresholds” item is the one to watch if you also sell packaging under your own brand, because it decides who is covered.

APCO’s chief executive put the industry’s ask in one line in its response to the meeting: The priority now is to translate this direction into decisions businesses can plan around. The roadmap has not done that yet.

What we check next

The next Environment Ministers’ Meeting, where both pieces of packaging work are due for discussion, and the department’s reform page for any decision on the design framework. Neither has a published date as at 5 October.

Sources

Environment Ministers’ Meeting, Communique, 18 September 2026 (EMM9) (PDF, downloaded and read 5 October 2026; the version on the department’s communiques page, which records an amendment on 23 September to a paragraph on the National Restoration Framework, not to the packaging text): that ministers agreed the Circular Economy Roadmap and proposed actions; the tasking of officials to examine options to strengthen packaging regulation through existing co-regulatory arrangements and to develop a packaging reform plan under the National Competition Policy, for discussion at the next meeting; the statements on urgency, single use plastics and design; the initial harmonisation priorities of battery stewardship, solar panels and soft plastics. We searched the text for “intergovernmental” and found no occurrence.
Environment Ministers’ Meeting, Circular Economy Roadmap (PDF, 8 pages, downloaded and read in full 5 October 2026): the Respond, Reform and Embed columns and their time labels; every packaging line quoted or listed above, from the action pathway on page 7; and the page 7 key distinguishing collective, state-based and Commonwealth-led actions, which we read from the rendered page.
Environment Ministers’ Meeting, Communique, 27 March 2026 (EMM8) (PDF, read again 5 October 2026): the governments’ commitment to reform of national packaging regulation; the tasking of officials to return to the next meeting with a draft intergovernmental agreement focused on batteries and packaging; and the commissioning of a roadmap by mid-2026.
Australian Packaging Covenant Organisation, APCO responds to Ministerial announcement on Commonwealth packaging scheme (PDF statement, published 8 September 2026 on its face, read 5 October 2026): APCO’s statement that a new Commonwealth scheme will not be introduced in this term of Government, as reported recently, and that NEPM obligations continue to apply with the Covenant as the pathway most businesses use. The file name says July; the document says 8 September, and we use the document.
Australian Packaging Covenant Organisation, Ministers set out pathway to strengthen Australia’s packaging framework (read 5 October 2026; it links the 18 September 2026 communique): the quotation from APCO’s chief executive on translating direction into decisions businesses can plan around.
Department of Climate Change, Energy, the Environment and Water, Strengthening packaging regulation (read 5 October 2026, page last updated 11 September 2026): that a decision has not yet been made regarding the Design for Kerbside Recyclability Grading Framework’s use and application.

How this came about. Our August reporting found that the only dated deliverable on packaging reform was the draft intergovernmental agreement ministers asked for in March, and that it was waiting on a general Environment Ministers’ Meeting. We check the department’s communiques page for that meeting. It was held on 18 September; we found it on 5 October, through APCO’s news page, which is later than we should have. Every quotation above is from the documents themselves, not from APCO’s summary of them.

What this is not. Nothing here reports a decision to change any obligation, because the roadmap makes none for packaging beyond the commitment to stronger NEPM monitoring and enforcement. The statement that no new Commonwealth scheme will come this term is APCO’s, and we have not read the announcement it refers to. We have not sought comment from the department or APCO.

Spotted an error, or has the next ministers’ meeting been set? Request a correction and we will check it against the sources above and log the outcome here.