Product Stewardship Amendment Bill WWF Submission

WWF-Australia is part of the WWF International Network, the world's largest independent conservation organisation. WWF’s global mission is to ‘stop the degradation of the planet's ​ natural environment and to build a future in which humans live in harmony with nature’. ​ WWF is active in more than 100 countries, and has approximately five million supporters worldwide.

Our organisation has a global priority to achieve no plastic in nature by 2030. To this end, WWF seeks to; 1. Reduce the amount of plastic in the system. 2. Increase the circulation of plastic in the system. 3. Eliminate the leakage of plastic out of the system.

WWF welcomes the opportunity to input into the Product Stewardship Amendment (Packaging and Plastics) Bill 2019. Producers and manufacturers play a crucial role in reducing marine plastic pollution, particularly through packaging design choices and mandatory product stewardship is essential in achieving this. To reduce the use of problematic plastics and to drive and recovery rates of valuable materials, WWF supports a stronger Product Stewardship Act.

While plastic has generated significant benefits for society, the way plastic has been managed and converted into a disposable and single-use convenience, has transformed this innovation into a planetary environmental crisis. Of the 3.4 million tonnes of plastic consumed in Australia in a year, only 9.4% is recycled.1 An inefficient management system, low recycling rates and high consumption of problematic plastics results in approximately 130,000 tonnes of plastic flowing into Australian waterways and oceans each year.2

The disposable nature of plastic packaging and low post-use value, makes it one of the largest sources of marine plastic pollution. Data from the CSIRO, Tangaroa Blue, Boomerang Alliance and Clean Up Australia all indicate that single-use plastic items and plastic packaging are the top marine items. Plastic litter or microplastics have been detected in all parts of the planet’s marine environment. The leakage of plastic caused by this broken system is having devastating effects on wildlife and ecosystems. More than 270 species have been documented as having been harmed by entanglement, while more than

1 Envisage Works and Sustainable Resource Use, 2018, 2017/18 Australian Plastics National ​ ​ Recycling Survey 2 Boomerang Alliance, 2016, Threat Abatement Plan: Marine Plastic Pollution

240 species have been found to have ingested plastics.3 Every year humans and animals continue to ingest plastics from food and drinking water, with the full effects still unknown.

As the largest share of Australia’s plastic consumption, plastic packaging use and design requires urgent attention. Simply; addressing plastic packaging requires greater accountability from upstream actors. The Product Stewardship Act can achieve this through bringing the responsibility for end-of-life product impacts into the market. As such, WWF supports a mandatory product stewardship scheme that eliminates problematic single-use plastics, improves design through mandatory packaging targets and creating a market for secondary plastics through a requirement for producers of plastic to use recycled content.

Eliminate problematic single-use plastics

Single-use plastic items are a major and destructive source of ocean plastic pollution due to their small size, low residual value and disposable nature. Items such as plastic bags, plastic utensils, balloons and cigarette butts are of urgent environmental concern as they present the highest entanglement and ingestion threat to seabirds, sea turtles and marine animals.4

As reflected in Australia’s National Waste Policy, the simplest way to manage waste is to create less of it in the first place. Phasing out single-use plastics has the potential to lower plastic demand by up to 40% and as such can directly address the amount of plastic entering our oceans.5 For this reason, many jurisdictions internationally such as the European Union (EU), Canada, Vanuatu and Rwanda are phasing out problematic single-use plastics.

To assess progress in Australia, WWF recently identified the top ten problematic single-use plastics and ranked each of the states and territories’ policies on these items via a plastic scorecard - attached in Appendix 1. The scorecard reveals that many states and territories are failing to take action on some of the most problematic single-use plastics. Only one state, South Australia, was awarded green on release of the scorecard.

Policies to phase-out single-use plastics can have dramatic effects on the amount of plastic polluting coastways and oceans. Queensland has noted a reduction in plastic bag litter by 70% since their ban on single-use plastic bags while their container refund scheme has reduced litter by about 35%.6 Data from other states and territories tells a similar story.

While there has been some positive movement on single-use plastics from many states and territories, the inconsistencies between the regulations and the lagging of some states calls

3 WWF, 2019, Solving Plastic Pollution Through Accountability 4 Wilcox et al, 2016, Using expert elicitation to estimate the impacts of plastic pollution on marine wildlife, Marine Policy ​ 5 WWF, 2019, Solving plastic pollution through accountability 6 Queensland Government, 2019, Tackling plastic waste: Queensland's Plastic Pollution Reduction Plan

for federal direction on the most problematic single-use plastics where alternatives exist. WWF believes the following items should be prohibited from being placed on the market.

- Single-use plastic bags - Microbeads - Coffee cups and lids - Plastic plates - Plastic straws and stirrers - Plastic cutlery - Plastic containers - Plastic packaging - Balloon sticks.

These items reflect those that have been proposed by the EU, represent the plastic items most found on Australian beaches and comprise the items most likely to present a threat to seabirds, turtles and marine animals.

WWF also supports a ban on polystyrene containers and oxo-degradable plastics. Polystyrene products are one of the most common plastics found in the environment because they are not biodegradable, are highly contaminated by food products and are difficult to recycle.

- Plastic bottles

Plastic bottles and lids are one of the top polluting items on Australia’s beaches. Boomerang Alliance estimates that beverage litter comprises 38% of marine plastic pollution.7

To address beverage litter and increase recovery rates of plastic bottles, container deposit schemes (CDSs) across Australia are an essential and proven tool. A CSIRO study found that CDSs can reduce the amount of beverage containers on the coasts by up to 40%.8 ​ While the majority of states and territories in Australia have implemented their own schemes, there is an opportunity to harmonise and enhance the effectiveness of these programs nation-wide. This is important to ensure universal coverage while optimising refund amounts and exploring expansion of all beverage containers.

WWF notes the EU Directives sets a recycling target for beverage containers of 77% by 2025 and 90% by 2030 and believes that a similar target for beverage containers should be included to build on the success of the states and territories’ CDSs.

WWF also supports the attachment of container caps and lids to beverage containers by 2023. This will reduce the likelihood of these items being littered and entering the marine environment.

7 Boomerang Alliance, 2016, Threat Abatement Plan: Marine Plastic Pollution 8 CSIRO, 2018, ‘Deposit schemes reduce drink containers in the ocean by 40%’ https://blog.csiro.au/deposit-schemes-reduce-drink-containers-ocean-40/

- Balloon releases

Balloon pieces are the number one plastic debris likely to cause seabird mortality and one of the top three plastics posing an entanglement risk to marine life.9 10 R​ eleased helium balloons can travel hundreds of kilometres and burst at high altitudes, returning as litter into the ocean.

While litter is an offence when items are deposited on land or waters, releasing of balloons is not addressed by many states and territories, despite these balloons or fragments returning to land as litter. NSW, ACT and Queensland are the only states and territories to have some legislation regarding balloon releases.

This issue requires leadership by the Federal Government to ensure there are consistent and effective laws to prevent the release of balloons across Australia.

- Cigarette butts

Cigarette butts are one of the most littered single-use plastic items in Australia. WWF supports labelling requirements and financial contributions towards the cost of disposing of and cleaning up as per the EU Directive.

Address plastic product design through legislated extended producer responsibility.

Addressing product design to improve recyclability is critical to addressing the rate of plastics leaking into our oceans.

It has been argued that packaging design is the single largest barrier to increased recycling rates in Australia.11 Issues regarding recyclability, the price competitiveness and quality of secondary recycled plastics can largely be attributed to the fact that manufacturers and producers are largely unaccountable for the downstream impacts of their products.

Australia’s 2025 packaging targets could dramatically transform the market and ensure that plastic use is reduced and that the needs of recycling are considered when designing products. In the EU, it has been calculated that design improvements could halve the cost of recycling plastic and are key to increase recycling.12 However, voluntary frameworks have been in place in Australia for 20 years and continuing to rely on these will not drive the market quick enough to address issues of product recyclability.

9 CSIRO, 2019, Sources, distribution and fate of , https://www.csiro.au/en/Research/OandA/Areas/Marine-resources-and-industries/Marine-debris ​ 10 Wilcox et al, 2016, Using expert elicitation to estimate the impacts of plastic pollution on marine wildlife, Marine Policy, Vol 65 ​ ​ 11 ACOR, 2012, Submission to the Packaging Impacts Consultation Regulation Impact Statement 12 European Commission, 2019, A European strategy for plastics in the circular economy

Packaging targets as part of a mandatory product stewardship framework would set the incentives needed to ensure effective end-of-life collection, cut excessive or unnecessary packaging and achieve higher rates of reuse and recycling. It would ensure packaging targets are met and that industry players who are demonstrating best practice in regards to stewardship are not disadvantaged.

The Product Stewardship Act is the natural instrument to incorporate packaging targets. WWF supports the following targets to be made mandatory; - 100% of all packaging will be reusable, recyclable or compostable by 2025. - 70% of plastic packaging will be recycled or composed by 2025. - 70% of all packaging will be recycled or composted.

Stimulate demand for recycled plastics through mandatory targets.

Creating a market for secondary plastics is crucial; not only does it create an economic incentive to build collection and recovery infrastructure, but it creates a direct incentive to avoid leakage into our natural environment. Only 3.6% of total plastic waste in Australia was reprocessed for local use in 2017/18.13 A combination of high cost, low quality and minimal demand incentives has resulted in such low demand. While effort is needed to address quality issues - achieved through high-quality inputs, scale and standardisation, demand can be addressed through a mandatory recycled content target.

The packaging target for industry to include 30% recycled content in packaging by 2025 is too low to considerably drive demand for recycled materials, especially considering 35% of packaging currently uses post-consumer content.14 To bolster demand for secondary materials and drive confidence in an Australian market, this requirement should be increased and made mandatory. We also note that the figure for recycled plastic content in packaging is currently much lower than the average across all material streams. To build Australia’s capacity to generate high-value recycled plastic, it is necessary to have a specific target for plastic recycled content. Greater demand for recycled plastics will drive recycling technology and make recycled plastics more commercially viable.

The Product Stewardship Act is the natural instrument to incorporate packaging targets. WWF recommends that a higher recycled content target is included and made mandatory, with a specific target included for plastic.

In summary

The world’s oceans are at risk of being overrun by plastic. Each year, up to 130,000 tonnes of plastic enters Australian oceans and waterways, presenting a devastating threat to our natural world, marine life and human health.

13 Envisage Works and Sustainable Resource Use, 2018, 2017/18 Australian Plastics National ​ ​ Recycling Survey 14 Review, 2019, https://wastemanagementreview.com.au/apco-releases-packaging-progress-data/ While the trajectory for plastic growth shows the crisis is expanding, we can change this through effective accountability measures. Amending the Product Stewardship Act to eliminate single-use plastics and mandate plastic packaging targets could dramatically transform waste management in Australia and ensure the reduction, reuse and recycling of plastic waste.

WWF-Australia looks forward to working with the Environment and Communications Legislation Committee to achieve this. For further information, please feel free to contact our No Plastic in Nature Policy Manager, Katinka Day .

Appendix 1 - WWF Plastics Scorecard