| 2016-09-27 18:53:00





Container Deposit Implementation Team

Waste and Recovery Branch

NSW EPA

PO Box A290

Sydney South, NSW 123221 September 2016

Further to, and in response of your calls for submissions in regard to the proposed NSW Container Deposit Scheme (CDS), we submit the following on behalf of the Packaging Council of Australia PCA.

We would like to point out that whilst this type of legislation has been highly unpopular with most of industry for some years and we as an industry association have advocated on our members’ behalf against CDS, as it is seen to threaten profit and can differentiate between containers that are redeemable and those that are not therefore has the potential to create unfair market advantage.

After stating the above our industry understands the principle and direction given by the NSW government and given the decision has been made, wants to work with the government and community to create the best outcome for all stakeholders. Therefore, our submission is not based on negativity of the process and or implementation but on enabling a best cost most effective outcome for all stakeholders.

Packaging Council of Australia submits that more time to understand and resolve issues is required, we believe that this would be of great benefit to the design of the scheme not only in NSW but across state borders to other states we have listed examples of our concerns (below) for your consideration.

  • Other States announcements;Since the NSW government announcement that it will implement a “CDS” other states have indicated that they wish to do the same. This has introduced questions and issues around alignment and timing that are currently not fully understood nor answered and that could severely impact the efficient implementation / operation and subsequent impact on cost to the public.
  • Design time underestimated;Working groups have met and discussed the detail and potential opportunities that could lead to a more effective CDS. Some issues have not been fully explored and resolved. We believe this is exposing the CDS design to expedient solutions rather than sound and effective plans.
  • Label marking requirements and stockpiling of containers pre July 2017;Lead time for deposit labelling and stockpiling of redeemable containers are issues that need serious consideration and to date are not fully understood nor syndicated widely and therefore not resolved. These are very important issues for our members and something which if not addressed correctly and resolved effectively will introduce costs and inefficiencies into the scheme.
  • Undue pressure from groups that will profit from a CDS;Vested groups (not industry) are agitating and lobbying via media to rush into a system that they stand to profit from. Whilst this can be managed to best cost and most effective it will take time to understand all stakeholder issues and design to provide the best and not the fastest scheme with little regard to minimising cost to the community.
  • Contractual relationships;We understand that NSW proposes a different relationship with collectors than SA but do not believe the proposed multi relationship contracts have resolved the contractual drivers and kerbside issues that have been recognised as needing resolution. We could be introducing a complex system of driving costs up rather than incentivising high returns at lowest or best cost.

Our members thank the NSW government and the Container Deposit Implementation Team from Waste and Recovery Branch of the NSW EPA for this opportunity and hope the government appreciates industry is trying to work with a difficult legislation that aspires to create great outcomes to which our members also want but with the best cost and most effective methodology.

Sincerely

David Carter

CEO Packaging Council of Australia