APCO is reviewing the rules behind the recycling label on your packaging, and will pause label audits for two years

The Australian Packaging Covenant Organisation calls the work the ARL Uplift Program, and sets it out on a page titled Shaping the Future of the ARL. It describes the program as APCO’s program of work to review and strengthen the rules, evidence and supporting systems behind the Australasian Recycling Label (ARL). The page carries no publication date. The earliest copy in the Internet Archive is from 9 September 2026, and that copy has no section on audits. The version we read on 13 November does, and it says that while the work is underway, APCO will pause the annual audits.A

Exhibit A · from the source

What the review covers

The page names four strands. The first is the evidence behind the label’s rules, with a primary focus on the kerbside recycling system, including whether the label should later cover alternative destination or away‑from‑home pathways. The second is what the label needs to do for consumers. The third is how it fits packaging reform, which the page says extends to its future role in a system shaped by Extended Producer Responsibility (EPR) and eco-modulated fees. The fourth is folding ARL reporting into APCO’s other member reporting.

For anyone who lays out packs, the part that matters is what the page says the work may change. Its list starts with The rules that decide the ARL shown on pack. It goes on to the design or presentation of the icons, how disposal pathways are communicated, and a revised ARL methodology manual. On the icons, its answer is No decisions have been made at this stage.

May change, per APCO

• The rules that decide which ARL a component carries
• The design or presentation of the icons (no decision yet)
• How disposal pathways are shown, possibly beyond kerbside
• Whether some formats can show the ARL at all: Potentially, for some formats.
• A revised ARL methodology manual

Stays, per APCO

• The ARL remains the primary disposal tool in Australia and New Zealand
• No immediate action is required from members.
• Most existing settings are expected to remain unchanged.
• Changes come with notice, lead times and a transition period

On artwork, the key sentence is this one: Where evidence supports change, some businesses may need to update on-pack ARLs for specific packaging components over time. APCO promises a substantial transition period and says it will try to line changes up with brands’ normal packaging review cycles. It also says it will take into account other required packaging updates, such as labelling or regulatory changes already affecting packaging artwork. The page gives no date for any proposed change, and says further updates will come as key milestones are reached.

What a changed setting looks like

APCO has already shown how it handles a format the evidence is unsure about. In February 2026 it recognised milk bottles made from ‘light-blocking’ HDPE as recyclable under the label, in New Zealand only, for a fixed term. The position statement grants a 24-month timebound recognition, with an annual review, because the carbon black in those bottles presents recyclability risks. It ends with a reservation any brand owner should read twice:

APCO reserves the right to amend, further constrain, or withdraw this recognition under the ARL Program.

That is one New Zealand ruling, not a sign of what the Australian review will decide. It does show the shape a decision can take: tied to evidence, time-limited, and reversible, which for a printed pack means artwork that may have to change on a date set by someone else.

The audits pause; the campaign starts

The audit pause sits beside a second pause, of separate ARL reporting requirements until the Uplift Program is completed and future requirements are confirmed. APCO says this does not change members’ wider reporting obligations, and that it will continue targeted assurance and market surveillance activity where required to protect the integrity and credibility of the label.

On 26 October, APCO launched a national campaign, timed ahead of National Recycling Week (9 to 15 November), to get people to read the label before they bin something. Its release cites a 2026 study:

Almost 8 in 10Australians recognise the ARL

Fewer than halfcheck it before disposing of packaging

500,000+products carry it, Australia and New Zealand

The campaign, It’s not that hard, runs on TV, streaming, social media and some outdoor sites, with a festive follow-up in production. Its message is the one in its tagline: check it before you chuck it. The release quotes APCO’s then chief executive, Chris Foley: Businesses have invested millions of dollars in putting clear recycling information on their packaging. His successor, Sarah Cook, was due to start on 9 November, according to APCO’s 4 November announcement, so the review lands on a new chief executive’s desk.

Two other labelling clocks

The ARL is not the only thing that may move on pack. APCO’s own page acknowledges labelling or regulatory changes already affecting packaging artwork, and two are on the public record.

1. Undated: ARL UpliftAPCO reviewing the label’s rules, icons and pathways; changes, if any, with lead times; annual ARL audits paused for two years
2. Roadmap, “Next 6 months”Environment ministers’ Circular Economy Roadmap lists exploring adding labelling to the Covenant and NEPM co-regulatory scheme
3. 2028: NSWNSW Plastics Plan 2.0 timeline lists disposal labelling regulations for single-use plastic cups, food containers and plastic bags

The roadmap’s packaging row says ministers will explore adding to the co-regulatory scheme recyclable design, recovery and recycled content outcomes, liability thresholds and labelling, and will Explore applying the Commonwealth’s Design Framework as a national approach to recyclability. In NSW, the EPA’s timeline puts under 2028: Commence regulations for proper disposal labelling on single-use plastic cups, food containers, and plastic bags. We covered what NSW can now do by EPA order on 7 November. None of the three has said what its label will look like.

Our view, labelled as such

APCO’s advice that members need do nothing now is right for packs already on shelf, and the review itself is sensible: a label that tells people to recycle something the system cannot handle is worse than no label. But the page sets out a real prospect of on-pack changes with no dates, alongside two other labelling processes that also have no settled wording. For a brand or printer planning artwork now for runs over the next few years, the practical step is to treat the recycling label as a block that can be swapped without reworking the whole pack, and to keep a record of which ARL settings each component was assessed against. That is our advice, not anything APCO has said.

The audit pause is the part we would question. The same organisation is running a national campaign telling consumers to trust and follow the label, while pausing the annual check that the label on each pack is right, for two years. APCO says targeted assurance and market surveillance continue. The fair test is whether it publishes what that surveillance finds while the audits are off. We will report the proposed changes to ARL settings when APCO publishes them.

Sources

How we put this together. AI systems researched and wrote it under our standing editorial rules, taking its facts from the primary sources below. 25 quotes were matched by software, word for word, against saved copies of the sources. How The Print Register works.

1. Australian Packaging Covenant Organisation, Shaping the Future of the ARL (web page, undated, read 13 November 2026): the ARL Uplift Program, its four strands, the possible changes, the transition commitments, the audit and reporting pauses, and the frequently asked questions. The audit pause is shown in Exhibit A.
2. Internet Archive, capture of the same page, 9 September 2026 (read 13 November 2026): the earliest archived copy, with no audit and reporting section.
3. Australian Packaging Covenant Organisation, APCO launches national campaign to make checking the recycling label a consumer habit (media release PDF, published 26 October 2026, read 13 November 2026): the campaign, its channels, the study figures, the product count and the quoted remarks.
4. Australian Packaging Covenant Organisation, APCO Board announces appointment of Sarah Cook as Chief Executive Officer (media release PDF, 4 November 2026, read 13 November 2026): the start date and succession.
5. Australian Packaging Covenant Organisation, ‘Light-blocking’ HDPE Bottles (New Zealand only) (position statement PDF, published February 2026, read 13 November 2026): the time-bound recognition, the annual review and the quoted reservation.
6. Environment Ministers’ Meeting, Circular Economy Roadmap (PDF, agreed 18 September 2026, read 13 November 2026): the packaging action pathway on page 7.
7. NSW Environment Protection Authority, NSW Plastics Plan 2.0 (web page, updated 28 October 2026, read 7 November 2026): the 2028 disposal labelling item in the implementation timeline.

Put the ARL on packs you design or print, or been told how the review affects them? Tell us and we will check it against the sources and log the outcome here.