Seamless has advocated for government intervention as part of its response to the Federal Government review of the Recycling and Waste Reduction Act 2020 (RAWR Act) to increase the Act’s effectiveness in advancing Australia’s circular economy.
The RAWR Act encourages the development of a circular economy through a range of mechanisms and programs including product stewardship. It is also the framework for managing Australia’s recycling and waste reduction objectives. Participating in the review is an important opportunity to shape Australia’s trajectory towards a more circular, resilient and resource efficient future.
Below is a summary of the feedback we have shared with the Federal Government as part of the RAWR Act review.
Read the full Seamless response to the Recycling and Waste Reduction Act review.
End-of-life product steward schemes
Seamless has advocated to shift the scope of stewardship to take a whole-of-life approach. For schemes to better align and deliver on circular economy principles, parties need to be held accountable for their products throughout every stage – from the design, manufacturing and use phases, through to recycling at end-of-life.
We also encourage the adoption of a more holistic approach to circularity to deliver positive environmental and human health as well as social impacts, while also recognising economic benefits.
Regulating product design standards is the most effective way to minimise the ecological footprint of products, as over 70% of their overall environmental impact, including emissions, is determined during the design phase.
Effectiveness of government accreditation
We’ve advocated for the introduction of a structured, tiered approach to require mandatory participation in industry-led, accredited product stewardship schemes where problematic products have been listed on the Minister’s Priority List for a minimum period of two years, and the scheme has been operational for no less than 12 months.
Minister’s Priority List
We’ve encouraged the creation of a formalised, structured path and process towards government regulation, with clear timelines. The structure should include rules around sector-appropriate thresholds for industry uptake that consider market size, market share, value chain capacity and capability, as well as the nature of the product risks and scheme benefits.
Deter non-compliance
We’ve advocated to extend the definition of liable parties to apply from the moment a product category is listed on the Minister’s Priority List as a problematic product.
Regular reporting for regulated entities
We support the same level of transparency, frequency of performance reporting and auditing for all industry-led mandatory schemes. Stewardship arrangements may also recommend notable exceptions where the Minister could request further reporting from specific parties.
Actions to stimulate circular economy
We encourage the implementation of government procurement policy that prioritises circular design and includes agreements for products such as uniforms and textiles. We also support the expansion of the Environmentally Sustainable Procurement Policy (ESPP) to apply beyond Federal Government, cascading to all tiers of government. Additionally, incentives and co-investment strategies should be introduced for sorting, decommissioning and recycling infrastructure, ensuring investments are proportionate to economically viable end-markets.
Other issues
We’ve advocated for the adoption of “resource” terminology rather than “waste”terminology in legislation and policy to drive sustainable resource management.
We support alignment with international circular economy legislative trends to strengthen Australia’s global competitiveness and ensure best practice across the entire product lifecycle.
We encourage coordinated efforts across all tiers of government to align policies and state-level activities to provide industry with the certainty required to improve resource recovery.
Additionally, we should ensure that the everyday Australian user experience is front of mind so communications about how to manage household resources are clear, simple and consistent.
Finally, we should ensure that stewardship schemes are well supported in their transition or establishment phases to maximise their potential for success.
Read the full Seamless response to the Recycling and Waste Reduction Act review.
