How to explain packaging compliance to teams and decision-makers

Packaging compliance often stalls because current obligations, potential consequences and next decisions are understood differently across the wider business.

As at October 2026, Australian businesses that make or sell packaging and earn $5 million or more generally need to join the Australian Packaging Covenant Organisation (APCO), report through relevant state or territory arrangements under the National Environment Protection Measure (NEPM), or participate in another approved equivalent program. The right pathway depends on the business and where it operates.

The regulatory direction is less settled. More than 80% of the 426 responses counted in the Australian Government’s 2024 consultation preferred Commonwealth regulation. In early September 2026, industry reporting said a new Commonwealth packaging scheme would not be introduced during the current term. On 18 September, environment ministers agreed to keep strengthening packaging regulation through work with industry under National Competition Policy. A separate private senator’s packaging EPR bill remains before the Senate, although the committee that examined it recommended that it not be passed.

That leaves the person responsible with a difficult task: explain what is known, what remains uncertain and what the business needs to decide now. The most reliable starting point is the packaging information that remains useful across changing rules: components, materials, weights, packaging levels, recyclability and supporting evidence.

Current packaging obligations still need owners

Regulatory language rarely arrives as a clean task list for product, procurement or sustainability teams. Someone inside the business has to turn each obligation into a deadline, a set of data fields and a clear decision.

For APCO Brand Owner Members, the Annual Report is due by 31 March, followed by an Action Plan due by 31 May. APCO’s non-compliance process can ultimately lead to a business being withdrawn as a Signatory and state and territory governments being notified.

For example, a national homewares retailer shows how many hands can sit behind one report:

1. Product coordinators raise purchase orders and manage suppliers
2. A sustainability coordinator reviews packaging records and consolidates the response
3. Risk leadership relies on the final report
4. If responsibilities remain unclear until March, the sustainability team inherits every missing field and unresolved supplier question

Waiting creates rework across the business

Products, packaging and suppliers keep changing while policy develops. Each delayed decision allows more records to become incomplete, more evidence to remain in inboxes and more new products to enter the range without usable packaging data.

The result can be repeated supplier chasing, rushed reporting, packaging changes made without a reliable baseline and difficulty answering market-access questions.

Suppliers feel the duplication too. A packaging supplier may receive requests from several brand customers, each asking for similar information in a different format.

The European Union’s Packaging and Packaging Waste Regulation (PPWR) reinforces the value of a reusable record. The PPWR began applying on a phased basis on 12 August 2026. Under Regulation (EU) 2025/40, manufacturers must prepare technical documentation and, where relevant, an EU declaration of conformity for each packaging type. Some major measures apply later, so businesses still need to confirm which provisions affect their packaging and timing.

Four ways to explain packaging compliance clearly

Clarity comes from converting requirements into ordinary business processes.

1. Map each obligation to a decision

Record the jurisdiction, reporting period, responsible entity, deadline, required fields and evidence. Label current obligations separately from proposed reforms and consultation outcomes.

2. Build records at component level

Capture each packaging component’s material, weight, format, packaging level and relevant recovery or recyclability information. Keep the specification, certificate or supplier confirmation attached to the value it supports.

3. Separate requesting, reviewing and reporting

Procurement or product teams may hold the supplier relationship, while packaging or sustainability teams assess the response and risk or finance leaders approve the result. Give every gap a named owner.

4. Collect data when the product is bought

A purchase order or supplier-onboarding step creates a timely trigger. The supplier and specification are current, and the business can resolve gaps before the reporting deadline.

Phantm supports this approach by structuring product, component and supplier evidence in one record, showing what has been confirmed and directing missing-data requests to the right supplier. That same foundation can support different reporting and decision workflows. Each framework still needs its own interpretation, checks and submission process.

Please note: This article provides general information, not legal advice. Confirm your obligations with APCO, the relevant regulator or a legal adviser.

Find the gaps before the deadline

Not sure which obligations apply to you, or whether your data could answer them? Book a walkthrough and we will show you what your packaging data already covers and where the gaps are.