Voluntary Today or Mandatory Tomorrow?

24 hours ago
4 min read

What EPR Means for Coffee Cup Brands in Australia

Australia’s packaging system is under increasing pressure.

According to the Clean Up Australia Litter Report FY25, packaging accounts for 59.5% of all litter collected nationally. Takeaway coffee cups increased from 2.8% to 4.3% of total litter in just one year – a 54% relative increase.

This is not a marginal fluctuation. It signals structural pressure on how packaging is designed, used and managed at end of life.

It is within this context that Extended Producer Responsibility (EPR) is being actively reviewed.

Image: Littered takeaway coffee cup

The data is getting harder to ignore

Clean Up Australia’s FY25 data shows:

Packaging represents nearly 60% of all litter.
An estimated 130,000 tonnes of plastic leaks into the Australian marine environment each year.
Takeaway coffee cups are increasing as a visible litter item.

For brand owners, this is not simply an environmental narrative. It is policy pressure in motion.

Packaging waste is increasingly being framed not as a consumer behaviour issue – but as a producer responsibility issue.

The regulatory direction is clear

Australia has committed to doubling its circularity rate by 2035 under the Circular Economy Framework.

At the same time:

Mandatory disposal labelling is rolling out.
State-based single-use plastic bans continue to expand.
Packaging reform is under active review.
Extended Producer Responsibility (EPR) for packaging is being openly discussed.

Importantly, Clean Up Australia has publicly supported the implementation of mandatory EPR for packaging, noting that voluntary agreements have not sufficiently reduced plastic waste.

This is not fringe commentary. It reflects mainstream environmental policy discourse.

The direction of travel is toward legally defined brand responsibility for packaging outcomes.

Why "wait and see" is a risk strategy

Some brands assume that if EPR becomes mandatory around 2028, it is prudent to wait.

But that assumption deserves scrutiny.

1. Regulatory Risk

When schemes become mandatory, governments set the structure and cost mechanisms. Early participants help shape systems. Late adopters comply with them.

2. Commercial Risk

Voluntary participation allows gradual cost integration, supply chain alignment and reporting maturity. Mandatory schemes often arrive with higher levies and tighter compliance timelines.

3. Reputation Risk

Consumers increasingly expect brands to demonstrate responsibility for end-of-life outcomes — not just recyclability claims.

4. Material Value Risk

Packaging is a resource. When recovered correctly, it replaces virgin materials in infrastructure and manufacturing. When unmanaged, it becomes landfill or litter.

Waiting may reduce short-term expenditure. It may increase long-term exposure.

Coffee cups: A visible example of the challenge

Takeaway coffee cups are a small fraction of total packaging volumes – but highly visible.

Composite paperboard cups are difficult to recover through traditional recycling systems. Without dedicated stewardship models, these materials risk being mismanaged, misunderstood or excluded from recovery altogether.

If regulation is moving toward producer responsibility, the logical question becomes: what does proactive responsibility look like in practice?

Image: Takeaway paper cup with waterproof lining

What product stewardship looks like in practice

Simply Cups, Australia’s largest paper cup recovery program, was established to address this exact gap — providing national collection, verified reprocessing pathways and transparent reporting for composite coffee cups.

Brands that join Simply Cups as product stewards:

Fund national collection and reprocessing systems
Gain accredited use of the ARL Drop-Off mark
Receive verified environmental reporting
Participate in a federally endorsed product stewardship framework

Become a product steward.

A common question we hear is: “How do I know my cups are being collected?”

As founding product steward, 7-Eleven Australia embedded collection points in approximately 90% of stores nationwide — building infrastructure years before regulatory pressure intensified. (Learn more here.)

This is not symbolic action. It is system-building.

Image: Takeaway coffee cup recycled with Simply Cups at 7-Eleven Australia store

The commercial case for acting now

Voluntary action today delivers:

Leadership positioning ahead of regulation
Managed cost integration
Stronger ESG disclosure capability
Credible sustainability storytelling

Once EPR becomes mandatory, participation becomes a compliance requirement – without the differentiation benefit.

Brands that move early help shape infrastructure, standards and market expectations. Brands that wait inherit them.

Voluntary stewardship is not about absorbing cost early. It is about shaping cost structures, standards and infrastructure before they are imposed.

A strategic question for brand leaders

Packaging represents nearly 60% of litter collected nationally. Regulatory momentum is accelerating. Producer responsibility is moving from discussion to design.

The question is not whether accountability for packaging will increase.

It is whether your organisation will help shape the system — or operate within one shaped by others.

Simply Cups exists to make voluntary product stewardship practical, credible and scalable. The infrastructure is in place. The reporting mechanisms are established. The regulatory trajectory is clear.

Now is the time to determine your position.