3 Packaging Compliance Changes That Took Effect in 2026 — And What They Mean for Procurement

If you procure or specify soft plastic packaging consumables—such as bin liners, pallet wrap, or clinical waste bags—three waste regulation and enforcement developments changed your compliance risks at the start of this year. These stricter requirements are not future considerations; they are in effect now, impacting every brand owner and retailer in the sector.

1. Mandatory Scope 3 Reporting Is Now Law for Large Australian Corporates

Australia’s mandatory climate-related financial disclosure regime now requires large corporates to disclose their full supply chain emissions. This sustainability reporting includes Scope 3, covering the environmental impact of all purchased goods and services.

What is Scope 3? Scope 3 covers emissions that occur across a company’s value chain but are not directly controlled by that company. This includes the environmental footprint of purchased goods and services — which means the packaging their suppliers provide.

Who is affected and when:

Group	Threshold	Reporting start
Group 1	Large listed entities and major financial institutions are already reporting.	1 January 2025
Group 2	Mid-to-large corporates enter the mandatory regime in four months.	1 July 2026
Group 3	Smaller reporting entities.	1 July 2027

Group 1 entities are already reporting. Group 2 entities — which include many mid-sized corporate buyers in cleaning, hospitality, and logistics — enter the mandatory regime in July 2026. That is four months away.

The practical consequence for packaging suppliers: Enterprise buyers cannot allow blind spots in their supply chain data. They are actively requiring their Tier 2 and Tier 3 suppliers to provide structured, repeatable, audit-ready environmental data. Suppliers who cannot provide it — meaning verified recycled content percentages, ISO-aligned carbon equivalents, and chain-of-custody documentation — are being removed from preferred supplier panels.

This is not a sustainability conversation. It is a legal compliance conversation. The data your customers need from you is now a regulated financial disclosure requirement on their end.

2. The ACCC Has Established a Clear Standard for Recycled Content Claims — and the Penalty for Getting It Wrong Is Significant

The ACCC has officially made greenwashing an apex priority for 2025–2026. Following a landmark $8.25 million penalty against Clorox Australia in 2025, the regulatory landscape has shifted. For any brand owner, retailer, or supplier, the standard for recycled content in products is no longer a matter of opinion. Packaging must be backed by rigorous, independent verification rather than a simple assertion.

Under Extended Producer Responsibility (EPR), the liability for packaging materials falls squarely on those who place packaged goods on the market. If you are a retailer or distributor selling items based on unverified marketing claims, you now assume significant compliance risks.

What constitutes a verifiable claim in 2026:

A defensible recycled content claim now requires independent third-party certification from an accredited body. This is essential for sustainability reporting and mitigating compliance risks. In the Australian market, the Australian Packaging Covenant Organisation (APCO) and government procurement frameworks recognize three primary pillars of verification:

• GECA (Good Environmental Choice Australia): The domestic standard for packaging materials. Their Claims Authentication scheme (ISO 14021) verifies recycled content in products, ensuring marketing claims are not merely a manufacturer’s assertion.

• GRS (Global Recycled Standard): Critical for the value chain, validating recycled material, environmental processing, and social responsibility across the entire supply chain.

• RecyClass: Provides science-based traceability for plastic packaging, aligning directly with the EU’s Packaging and Packaging Waste Regulation (PPWR).

Self-declared “recycled” labelling is no longer a defensible commercial position.

3. Oxo-Degradable Plastics Are Being Legislated Out of the Australian Market

The regulatory position on oxo-degradable plastics is now unambiguous across Australia. As compliance requirements tighten, Australian businesses and brand owners must recognize that these materials no longer align with national packaging targets or global sustainability standards.

The science is clear: oxo-degradable plastics contain pro-degradant chemical additives that cause the polymer to fragment under UV exposure or heat. They do not safely biodegrade; instead, they break into harmful microplastics. This is a scientific and regulatory consensus that has driven stricter bans across multiple jurisdictions to mitigate long-term environmental impact.

The current legislative position by state:

The waste regulation environment is becoming stricter, with each member state (and Australian territory) accelerating its own timeline for packaging materials:

• • New South Wales: Under the NSW Plastics Plan 2.0, packaging must meet new standards by late 2027. This includes a total ban on all plastic containing pro-degradant additives and a phase-out of plastic packaging bags with handles, regardless of micron thickness.

  • South Australia: This sector leader completed further prohibitions in September 2025. This targeted plastic soy sauce containers, attached straws, and all remaining expanded polystyrene packaging.

  • Western Australia: Expanded bans in October 2025 included disposable plastic produce bags. Further extensions to plastic barrier bags for meat and dairy are confirmed for late 2026.

  • Victoria, Queensland, ACT, & NT: Compliance requirements for single-use plastics continue to expand. To remain compliant, businesses must monitor these jurisdictions as they align with national Extended Producer Responsibility (EPR) frameworks.

The primary inventory risk for a supplier or retailer lies in the fragmented timeline. A product placed on the market in Queensland today may face non-compliance in NSW within 18 months. National supply chain managers cannot handle packaging formats on a state-by-state basis without incurring massive compliance risks.

To maintain consumer trust and avoid non-compliance, Australian businesses must audit your packaging portfolio now. The move toward circular economy principles means that packaging must transition to recycled content and high recyclability to remain viable.

What a Compliant Packaging Position Looks Like in 2026

Procurement and waste management teams in 2026 need a supplier who provides:

1. Verified Recycled Content: Not self-declared; must have a GECA or GRS license.

2. ISO-Aligned Data: Documented environmental impact for sustainability reporting.

3. Traceability: Clear supply chain documentation for all materials used.

4. No Pro-degradant Additives: Fully compliant with stricter state bans.

How thinkpac’s ReCree8® PCR Range Addresses Each Requirement

thinkpac’s ReCree8® platform uses 100% post-consumer recycled resin, independently verified under GECA Licence THP-2024. Whether you need reusable packaging solutions or high-performance recyclable films, our range ensures your supply chain remains compliant.

Two Practical Steps Before Your Next Tender or ESG Report

Use the ReCree8® Impact Calculator to evaluate your entire packaging footprint. By entering your estimated annual soft plastic volume and material type, the tool generates data for your Environmental Management Plans. This output is essential for the circular economy and ensures your sustainability claims are backed by ISO-aligned methodology, helping you avoid compliance risks associated with PFAS or non-compliant materials.

→ Calculate your impact

Request the ReCree8® Technical Proof Pack. The full documentation dossier for procurement officers, sustainability leads, and ESG managers. Includes GECA certification details, GRS and ISO 14001 certificate references, chain-of-custody documentation, resin performance specifications, and segment-specific compliance mapping for cleaning, hospitality, and logistics. Ready to attach to your next tender submission.

→ Send an email to info@thinkpac.com.au for the proof pack

Frequently Asked Questions

Is mandatory Scope 3 reporting already in effect in Australia?
Yes. Group 1 entities (large listed companies and major financial institutions) began mandatory reporting on 1 January 2025. Group 2 entities (mid-to-large corporates) enter the regime on 1 July 2026.

What is the ACCC’s current position on recycled content claims?
The ACCC has made it clear that a mere self-declaration is non-compliant. To build consumer trust and avoid greenwashing penalties, brand owners and retailers must have third-party verification for all marketing claims. Using recycled material in packaging requires clear traceability to prove the environmental impact is genuinely reduced. Non-compliant packaging claims can lead to significant compliance risks.

Are oxo-degradable bin liners still legal in Australia?
Currently yes in most states, but with confirmed phase-out timelines. NSW has legislated a ban for late 2027, while WA and SA bans are expanding. National distributors and packaging manufacturers should audit your packaging portfolio against state-specific packaging requirements now. Transitioning to reusable or genuinely recyclable formats is essential for producer responsibility.

What is GECA Claims Authentication?
GECA (Good Environmental Choice Australia) is an independent body providing transparency requirements for sustainable packaging. It is a Type II environmental labelling program (ISO 14021) that verifies specific product data—such as recycled content in products. It is recognized by procurement frameworks and the Australian Packaging Covenant Organisation (APCO).

What is PCR plastic?
PCR stands for Post-Consumer Recycled plastic. Unlike industrial scrap, PCR plastic is made from plastic packaging waste collected after consumer use. Increasing the recycled content in your current packaging is a core part of the circular economy.