Australian Packaging Covenant

Recently a number of our members have contacted us after receiving letters from the Australian Packaging Covenant Organisation (APCO) advising them that they have obligations under the National Environment Protection (Used Packaging Material) Measure 2011 (NEPM) and to meet these obligations they need to join the ACPO. Failure to do so  would result in them being reported to the State Environment Protection Agency, in the State that they operated in.

Our members have described these letters as threatening in tone and in our view, misleading – they did not properly present the obligations and options.

In response we have spoken to the CEO of the ACPO and registered our disappointment in their behaviour.

If you are a Brand Owner business in the packaging supply chain with an annual turnover of $AUD5 million or more, you must meet the National Environment Protection (Used Packaging Material) Measure 2011 (NEPM). The definition of a Brand Owner is a person who is the owner or licensee in Australia of a trade mark under which a product is sold or otherwise distributed in Australia, whether the trade mark is registered or not.

To meet these regulatory obligations, your business must choose between two options:

  • Become a Signatory to the Covenant and a Member of APCO; or
  • Meet compliance obligations under the NEPM

If you choose to meet compliance obligations directly under the NEPM, your business will be required to meet the recording and reporting requirements for all consumer packaging materials, as set out by obligations and regulations in the states and territories in which your packaging is sold. A Signatory to the Covenant and a Member of APCO also must meet recording and reporting obligations.

If you receive this letter and want further information, please contact us at

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