APCO 2025 Packaging: 4 Targets and Who Must Comply

What Are the APCO National Packaging Targets 2025?

Australia's National Packaging Targets 2025 were set by the Australian Packaging Covenant Organisation (APCO) as part of its 2018–2025 Packaging Roadmap — a co-regulatory framework formally recognised under the Product Stewardship Act 2011 and the National Environment Protection (Used Packaging Materials) Measure (NEPM). These are not vague aspirations. APCO signatories — brand owners, retailers, manufacturers, and importers of packaged goods — made binding commitments to achieve four measurable outcomes by the end of 2025.

The targets operate at a different layer of the packaging system to state plastic bans. They govern what packaging gets designed and manufactured in Australia, not just what individual businesses are permitted to use on the floor of a café or food truck. Understanding where APCO ends and state legislation begins is the first step to genuine, defensible compliance.

APCO reports publicly on signatory progress each year. As 2025 passed, the industry's collective scorecard showed meaningful advances on some targets and significant shortfalls on others — particularly the recycled-content and recycling-rate targets. This guide unpacks each target, identifies who is actually bound, maps state-level legal obligations alongside them, and gives food service operators a practical checklist to operate with confidence in 2026 and beyond.

The 4 Core APCO Targets — What Each One Actually Requires

Target 1: 100% Reusable, Recyclable, or Compostable Packaging

Every piece of packaging entering the Australian market should be capable of being reused, recycled through a kerbside or drop-off scheme, or composted via a recognised industrial or home composting pathway. The critical word is "capable" — a package passes this test if it is technically recyclable in Australia, even if actual collection and recycling rates remain low.

For food service operators, this target means prioritising packaging with a clear, documented end-of-life pathway. Compostable packaging certified to AS 4736-2006 (industrial composting) or AS 5810-2010 (home composting) satisfies this target, provided customers have access to appropriate disposal infrastructure — FOGO bins, industrial composting services, or home compost. Recyclable mono-material paper and cardboard packaging also qualifies. Multilayer laminates, oxo-degradable plastics, and expanded polystyrene do not.

Target 2: 70% of Australia's Plastic Packaging Recycled or Composted

This was widely acknowledged as the most ambitious of the four targets — and the furthest from achievement. At the close of 2025, kerbside and drop-off recycling rates for flexible plastics, multilayer packaging, and opaque rigid plastics remained well below 70%. The collapse of the REDcycle soft plastics collection scheme in late 2022 set back progress in the flexible plastics category significantly, exposing how dependent the national recycling rate was on a single private-sector program.

APCO's own progress tracking acknowledges that this target required systemic infrastructure investment — new sorting technology, expanded collection points, viable end markets for recovered plastic — that the market has not yet fully delivered. For buyers, this target is the clearest signal driving the long-term shift away from plastic film wrapping, polystyrene containers, and multi-layer packaging toward mono-material paper, board, and certified compostable alternatives with cleaner, documented end-of-life pathways.

Target 3: 30% Average Recycled Content in Packaging

By 2025, packaging should on average contain at least 30% post-consumer recycled (PCR) material. This target directly shapes the raw materials packaging manufacturers can use. In practice, you see it expressed in packaging labelled with percentages like "made with 30% recycled cardboard" or "contains 50% PCR content."

For food businesses, this target has less day-to-day operational impact than the others — it applies to your suppliers' manufacturing decisions, not your purchasing choice at point of order. However, asking your packaging supplier for recycled content documentation is increasingly standard practice in procurement audits, particularly for hospitality groups, councils, and food service companies operating formal sustainability reporting frameworks. If you can't get the data from your current supplier, that's a red flag worth acting on.

Target 4: Phase Out Problematic and Unnecessary Single-Use Plastics

APCO defined a specific list of problematic packaging formats targeted for elimination. These include expanded polystyrene (EPS) food service packaging, PVC packaging, oxo-degradable plastics, and problematic flexible plastic laminates. "Unnecessary" single-use plastics — items where a reusable or alternative-material option exists and is commercially viable — were also flagged for phase-out.

This target directly overlaps with state and territory legislation. In NSW, Victoria, Queensland, South Australia, Western Australia, ACT, and Tasmania, most of these problematic formats are now banned outright under local law — making APCO's co-regulatory approach largely redundant at the retail level for those items, but still relevant to manufacturers and brand owners designing packaging for national distribution.

Who Is Legally Required to Comply with APCO Targets?

This is one of the most misunderstood aspects of the 2025 framework. APCO targets apply directly to APCO signatories — organisations that have formally signed the Australian Packaging Covenant. APCO has approximately 700 active signatories, covering a significant portion of the branded packaged goods market but not every business in the food service supply chain.

Signatories are typically:

• Brand owners who place packaged products on the Australian market
• Supermarket chains and major retailers
• Food manufacturers and importers of packaged goods
• Packaging manufacturers supplying branded product lines

A café owner ordering a case of sugarcane takeaway containers is not a direct APCO signatory and is not bound by the covenant's annual reporting requirements. However, this distinction does not make packaging compliance optional for food businesses. State and territory legislation creates hard legal obligations that apply to every operator regardless of APCO signatory status — from a single food truck to a national restaurant chain.

The practical reality: because APCO signatories (your packaging suppliers and the brand manufacturers upstream) must comply with APCO targets, the market effect flows downstream. Packaging formats that fail APCO recyclability or compostability benchmarks become progressively harder to source as manufacturers phase them out to maintain signatory standing. Your available product range evolves whether you are a signatory or not.

APCO Targets vs. State Plastic Bans — Two Different Obligations

The most common point of confusion is conflating APCO's covenant-based targets with the legally enforceable single-use plastic bans operating in each state and territory. They are separate regulatory instruments with different scopes, enforcement mechanisms, and penalties. The table below maps both frameworks side by side.

Key takeaway: State bans are the legal floor — breach them and face fines. APCO targets are the aspirational ceiling, enforced through reporting accountability rather than prosecution. A food business that sources only APCO-compliant packaging and abides by all relevant state bans is operating at the highest level of packaging compliance currently available in Australia.

Certification Standards That Prove Compostability Claims

When evaluating whether a packaging product satisfies APCO's 100% reusable/recyclable/compostable target, certification against recognised Australian Standards is the most defensible evidence a buyer can hold. Two standards govern compostable packaging in Australia, and they are not interchangeable.

AS 4736-2006 — Industrial Composting

AS 4736-2006 is the Australian Standard for biodegradable plastics suitable for composting in a commercial or industrial facility. To achieve certification, packaging must satisfy all of the following:

• Disintegrate ≥90% within 12 weeks under industrial composting conditions (approximately 58°C)
• Biodegrade ≥60% of organic carbon to CO₂ within 180 days
• Pass ecotoxicity screening — plants grown in the resulting compost must show no measurable adverse effects compared to a blank control
• Meet regulated heavy metal concentration limits

AS 4736 certification is the standard required for most food service packaging — cups, takeaway containers, plates, bowls, and cutlery — to be accepted in council FOGO (Food Organics and Garden Organics) collection programs. However, not all councils that operate FOGO programs accept certified compostable packaging; some exclude it to prevent contamination risk. Always verify with your specific local authority before diverting compostable packaging to the FOGO bin.

AS 5810-2010 — Home Composting

AS 5810-2010 sets a higher bar because home composting operates at ambient temperatures (≥20°C), well below the conditions of industrial facilities. Packaging certified to AS 5810 must still disintegrate and biodegrade fully, but must do so without the benefit of elevated temperatures, active turning, or managed moisture — the slower, uncontrolled conditions of a backyard compost heap.

Home-compostable certification is rarer and generally more expensive to achieve than AS 4736, but provides consumers with a genuine disposal pathway regardless of whether they have access to council FOGO collection. Products certified to AS 5810 are generally also acceptable in industrial composting streams, but the reverse is not true — an AS 4736-only certified product cannot be claimed suitable for home composting.

The ABA Certification Logos

Certification against either standard is administered through accredited testing bodies, with the Australian Bioplastics Association (ABA) managing the certification trademark logos that appear on compliant products: the seedling logo for AS 4736 (industrial composting) and the home composting logo for AS 5810. When sourcing packaging, checking for these logos — or requesting the certificate number from your supplier and verifying it against the ABA register — is the fastest, most defensible verification step available.

PREP — APCO's Recyclability Evaluation Tool

For recyclable (rather than compostable) packaging, APCO operates the Packaging Recyclability Evaluation Portal (PREP). Brand owners and manufacturers use PREP to score their packaging's recyclability against Australia's actual kerbside collection infrastructure — not theoretical recyclability in ideal conditions, but what happens in real Australian sorting facilities. PREP assessments are the mechanism by which signatories document progress toward the 100% recyclable packaging target. As a buyer, asking your supplier for a PREP score is increasingly the standard of evidence the market expects for any recyclability claim.

Packaging Compliance Comparison: Compostable, Recyclable, and Conventional

How APCO's 2025 Deadline Reshaped the Australian Packaging Market

The practical legacy of the APCO 2025 targets is visible in what's stocked on the shelves of packaging distributors today. Between 2018 and 2025, APCO signatories progressively redesigned packaging lines to meet PREP recyclability benchmarks and phase out problematic formats. Major supermarket chains eliminated EPS, oxo-degradable plastics, and loose-fill polystyrene from private-label lines. Food manufacturers reformulated multilayer packaging toward mono-material alternatives wherever commercially viable. This market-level pressure is the real mechanism by which APCO targets affect food businesses: not through direct regulation, but through supply chain evolution that removes non-compliant options from the catalogue.

Three structural shifts resulted from the 2025 target period that packaging buyers should understand heading into 2026:

1. Expanded polystyrene effectively disappeared from reputable suppliers before legislation required it. APCO signatories moved ahead of state bans in many cases, meaning distributors stopped stocking EPS food service items because they could not sell them to major accounts. By the time state bans made EPS explicitly illegal for food businesses, it had already largely vanished from wholesale catalogues.
2. Certified compostable packaging moved from premium niche to mainstream. In 2018, AS 4736-certified sugarcane (bagasse) containers were significantly more expensive than plastic equivalents. By 2025, the wholesale price gap had narrowed considerably, driven by order volume, supply chain maturity, and increased competition among compliant suppliers. Materials like bagasse, PLA (polylactic acid), CPLA (crystallised PLA for heat-resistant lids), and kraft paper with water-based coatings are now standard stock at competitive price points.
3. Recyclability claims became subject to documented scrutiny. The PREP tool created a documented evidence trail for recyclability claims. Broad marketing language like "eco-friendly" or "recyclable" without PREP verification became harder to sustain, particularly as ACCC greenwashing enforcement actions signalled intent to pursue substantiation. Buyers who request PREP documentation are now driving better evidence standards across their supply chain.

For food businesses planning major venue upgrades or new kitchen fit-outs alongside packaging transitions, working with experienced commercial trades makes a difference. APX Trade Group, licensed electricians based in Sydney, have experience with commercial kitchen upgrades as hospitality venues update their operations to meet modern compliance and sustainability standards.

What Comes After 2025? Australia's Post-2025 Packaging Framework

The 2025 deadline was a milestone, not an endpoint. APCO and the federal government have been developing a post-2025 packaging framework that raises ambition levels and introduces stronger accountability mechanisms to address the shortfalls — particularly on plastic recycling rates and recycled content — that the 2025 targets exposed.

Key elements expected in the post-2025 framework include:

• Higher and category-specific recycled content targets. The 30% industry average is expected to rise, with category-level targets that prevent high-performing categories masking laggards in the overall average.
• Extended Producer Responsibility (EPR) for packaging. A national EPR scheme is in development under the federal government's National Waste Policy Action Plan. EPR shifts end-of-life costs back to producers and brand owners, creating direct financial incentives for recyclable and compostable packaging design that the covenant's accountability-only framework lacked.
• Expanded mandatory reporting thresholds. The current framework exempts smaller businesses from signatory obligations. Post-2025 structures may lower the threshold, capturing more of the mid-market food service supply chain within formal reporting obligations.
• Stronger greenwashing enforcement. ACCC has signalled sustained attention to misleading packaging claims. Updated APCO evidence standards, combined with ACCC enforcement actions, mean "biodegradable" claims without certified standards will face increasing legal risk for the businesses making them.

The practical implication for food businesses planning procurement in 2026 and beyond: choose packaging that already meets or exceeds current standards — certified compostable to AS 4736 or AS 5810, recyclable with PREP documentation, or reusable where operationally feasible. Buying ahead of the regulatory curve is always cheaper than a forced transition under deadline pressure. If you need to update your business's online presence to reflect sustainability commitments, weauto builds professional websites for Australian businesses from $99 — a practical step for food operators wanting to communicate their compliance credentials to customers and B2B buyers.

Practical Compliance Steps for Australian Food Businesses

Here is what a café owner, hospitality manager, or sustainability officer should actually do to align with APCO targets and state legal requirements right now:

1. Audit your current packaging stock. List every packaging item used in your operation. For each, identify the material (ask your supplier if unsure), whether it carries a recognised certification (AS 4736, AS 5810, or PREP-assessed recyclable), and whether it contains any format currently banned in your state or territory.
2. Cross-reference your state's current ban list. NSW, Victoria, Queensland, SA, WA, ACT, and Tasmania all publish updated lists of prohibited items. Any non-compliant product in your current stock needs a compliant replacement sourced and ordered before your enforcement deadline.
3. Verify your disposal infrastructure before making claims. Compostable packaging is only as useful as the composting pathway available in your area. Check whether your council offers FOGO collection and whether it accepts certified compostable packaging. If not, work with a commercial composting service or route compostables to general waste rather than contaminating kerbside recycling streams.
4. Request certification documentation from every packaging supplier. Ask for the AS 4736 or AS 5810 certificate number for any product labelled "compostable" and verify it against the ABA register. Ask for a PREP score or assessment for products claimed recyclable. Keep these documents on file for supplier audits, council sustainability reporting, or any ACCC substantiation request.
5. Review packaging disposal labelling. Ensure your packaging carries clear, accurate disposal instructions visible to customers. Correct labelling reduces contamination in composting and recycling streams, and demonstrates due diligence in any regulatory review.
6. Consolidate to a single compliant wholesale supplier. Sourcing from a dedicated eco-packaging wholesaler gives you access to the full range of 700+ eco products — cups, containers, plates, cutlery, bags, and more — with documented certifications and consistent supply. Consolidation also simplifies your audit documentation and typically delivers better unit pricing at volume.

The total cost picture extends beyond unit price. Businesses that successfully route food waste and certified compostable packaging to FOGO or commercial composting services can reduce general waste volumes. In some cases this translates to lower commercial bin hire charges or collection frequency savings with private waste contractors — a real bottom-line benefit that partially offsets the higher per-unit cost of certified compostable packaging versus conventional plastic.

Frequently Asked Questions

Does my café need to comply with APCO National Packaging Targets 2025?

Not directly. APCO targets apply to formal signatories — typically brand owners, manufacturers, and large retailers who have signed the Australian Packaging Covenant. As a food service operator, you are not a signatory and are not required to file APCO progress reports. However, state and territory single-use plastic bans are legally enforceable and apply to every business in Australia. These bans cover most of the packaging formats that APCO's targets also addressed, meaning the practical compliance requirements for food operators are very similar to APCO's framework — even though the legal basis is different.

What is the difference between AS 4736 and AS 5810?

AS 4736-2006 certifies packaging for industrial composting — the high-temperature, managed process used in commercial composting facilities and some council FOGO programs (approximately 58°C). AS 5810-2010 certifies packaging for home composting — a lower-temperature, ambient-condition process (≥20°C) accessible to any household. AS 5810 is the stricter standard because conditions are less controlled, and packaging meeting AS 5810 is generally suitable for industrial composting too, but not the reverse: an AS 4736-only product cannot legitimately be called home-compostable.

Can I put certified compostable packaging in my council FOGO bin?

It depends entirely on your specific council. Many Australian councils with FOGO programs accept packaging certified to AS 4736, but a significant number explicitly exclude packaging to prevent contamination of compost batches. Never assume — always check directly with your local council's waste team before diverting compostable packaging to the FOGO bin. Contaminated FOGO loads can be rejected by composting facilities, undermining the entire program.

What is the PREP tool and do food businesses need to use it?

PREP (Packaging Recyclability Evaluation Portal) is APCO's tool for scoring packaging recyclability against Australia's actual kerbside infrastructure. It is used by APCO signatories — brand owners and manufacturers — to document progress toward the 100% recyclable packaging target. As a food service buyer, you don't use PREP directly. However, you can and should ask your packaging suppliers to provide a PREP score or assessment for any product they claim is recyclable — this is becoming the market standard for substantiating recyclability claims and will protect you from inadvertently relying on greenwash.

Which single-use plastic items are now banned across all Australian states?

While each state has its own legislation, the following formats are banned or actively being phased out across most Australian jurisdictions: expanded polystyrene (EPS) food containers, single-use plastic cutlery, plastic straws and stirrers, lightweight plastic carry bags, and oxo-degradable plastics. South Australia, New South Wales, Victoria, Queensland, Western Australia, ACT, and Tasmania have all enacted bans with varying effective dates. If you operate across multiple states, apply the strictest standard currently in effect across all your locations to ensure national compliance.

Are biodegradable and compostable the same thing for APCO compliance?

No — these are legally and technically distinct terms. "Biodegradable" has no regulated definition in Australia and can be applied to materials that break down slowly over decades, leave microplastic residues, or require conditions never specified. "Compostable," when certified to AS 4736 or AS 5810, has a precise, tested, and third-party verified meaning with time limits and safety requirements. APCO's packaging design standards and state-level legislation recognise certified compostable packaging as meeting the compostable pathway; vague biodegradable claims are not accepted as evidence of compostability. Always look for the certification logo or number, not just the marketing language on the packaging.

What happens to APCO signatories who didn't meet the 2025 targets?

APCO's covenant framework uses public reporting and reputational accountability — rather than financial penalties — as its primary enforcement mechanism. Signatories who fall short are identified in APCO's annual progress reports, creating reputational consequences and investor scrutiny for listed companies. The post-2025 framework under development is expected to introduce stronger mechanisms, potentially including an Extended Producer Responsibility (EPR) scheme where financial contributions are tied to recycling performance outcomes. Businesses buying packaging from compliant suppliers are largely insulated from this upstream corporate accountability risk.

How do I verify a compostable packaging certification is genuine?

Request the specific certificate number from your supplier and verify it directly with the Australian Bioplastics Association (ABA) or the certifying testing body named on the certificate. Products displaying the ABA seedling logo (AS 4736) or home composting logo (AS 5810) have been third-party tested and are listed on the ABA's register. Be cautious of products that use the words "compostable" or "certified compostable" without displaying a recognised logo or providing a verifiable certificate number — this is one of the most common forms of greenwashing in the food service packaging market, and it exposes buyers who rely on such claims to reputational and regulatory risk.

The Right Packaging Partner Makes Compliance Straightforward

Navigating APCO targets, state bans, and compostability certifications is significantly easier when your packaging supplier can document compliance at the product level rather than leaving verification to you. ZenPacks Australia supplies wholesale certified compostable and eco-friendly packaging to food businesses, cafés, hospitality groups, and councils across Australia, with competitive pricing on bulk orders and fast delivery from Sydney. Our team can advise on which products carry AS 4736 or AS 5810 certification, which formats are approved for FOGO programs in your council area, and how to build a packaging range that satisfies both current state bans and the direction of the post-2025 regulatory framework. Contact us to discuss your requirements or browse our full range of 700+ eco products — from certified compostable cups and containers to kraft paper bags, bamboo cutlery, and sugarcane plates.