Container refund scheme submission
Submission to provide feedback on the proposed expansion of the Container Refund Scheme in Queensland
To Whom It May Concern:
Granite Belt Sustainable Action Network was formed in May 2019.
We are a volunteer grassroots organisation.
We are independent, respectful and non-partisan.
We are focused on practical, constructive and positive changes towards a sustainable future for our community.
We are also a participant in the current Containers for Change scheme and are keen to promote the scheme to our members to emphasise improved environmental, economic and social outcomes within our community.
Although we could have submitted our feedback via the survey, we feel that we have some unique aspects of our region which would make an expansion of the scheme particularly pertinent to us. By sending an individual submission we hope that our particular circumstance can be used to highlight the potential benefits of expansion of the scheme.
General Comments on the Container Deposit Scheme
Looking at the container deposit scheme as it currently operates, there is scope for much improvement to the scheme to eliminate existing problems. These are general issues related to the scheme and not particular to the Granite Belt region. We have identified the following problems and potential solutions:
The Containers for Change CDS is currently administered by the state of Queensland. Each state within Australia has its own scheme. This presents inherent difficulties if beverages are purchased in one state and the bottles refunded in another. If the CDS were a federal program any problems associated with this issue would be eliminated. We envisage a federal scheme would be more efficient for participants in the scheme, requiring only one monthly submission of data to one agency. At present, beverage manufacturers selling products into various states must report to each state they have sold into, however this could be simplified to one report if a federal scheme were adopted. A federal scheme would bring all of the individual states up to speed with a CDS and standardise procedures for depots.
Essentially, the container deposit scheme applies to the containers the beverages are packaged in, not the beverage itself. Thus, the container, being either a bottle, can, plastic bottle or aseptic container, should have the levy applied to it at the point of sale to the beverage manufacturers. At present, the onus is on the beverage manufacturers to administer, collect and pass on the levy, however this is extremely time consuming and potentially very costly to small manufacturers. A far simpler and more equitable method would be for the levy to be applied to the cost of the container (for example, if a wine bottle costs $0.75 the cost would increase by $0.13 cents to $0.88 per unit -the increased cost per unit would simply be passed on to the consumer). This would be relatively simple to implement and would alleviate the burden of administering the scheme for small producers.
Beverage exporters who have paid a levy per container need to be considered in a CDS. A rebate for exporters should be applied so that any levy paid per container is refunded.
We see no reason to exclude cordial and concentrate, health tonic and syrup manufacturers from an expanded CDS. The exclusion is based on the loophole of them not being classed as a beverage, however this is simply a technicality. Including such bottles in a CDS is fair and reasonable.
Specific comments on the proposed expansion of the Container Deposit Scheme
The Granite Belt is home to around 35 commercial wineries, 2 breweries, 2 distilleries and several cideries. Collectively, the Granite Belt wineries process around 800 tonnes of winegrapes annually, which corresponds to 640,000 glass bottles.
Whilst the breweries have incorporated the 10c beer bottle refund via the current system, a better means of recycling glass wine bottles in the area has been sorely lacking for many years. Commingled recycling exists within the Southern Downs Regional Council, however reports commissioned by the council have shown that there is a contamination rate in landfill bins of around 20%, which represents a resource recovery loss as well as unnecessary material sent to landfill. We recognise that putting a price on recoverable resources will be an important step in preventing them going to landfill.
We support the proposed expansion of the container deposit scheme to include:
• wine in glass bottles
• pure spirits in glass bottles
• wine in aseptic packs between 1 litre and 3 litres
• water in aseptic packs between 1 litre and 3 litres
• flavoured milk containers between 1 litre and 3 litres
• pure juice containers between 1 litre and 3 litres.
We also recognise that there are certain unique difficulties for small wine producers within the Granite Belt region which will mean that compliance with an expanded container deposit scheme will add significantly to their administrative burden. We think that the scheme should still be expanded to encompass wineries but that it must be implemented in such a way as to make it simple for smaller producers to comply.
We have spoken to some small producers within the region and they have expressed reservations about the proposed expansion. These are:
How much time will be required for them to comply with the record keeping. Small wineries already have a fairly large obligation to comply with record keeping and a CDS will add to this burden.
Container deposit schemes are currently state-by-state, however, if wineries sell wine wholesale into several states, then they will need to keep records for the container deposit schemes for each state that they sell into, further adding to the administrative burden.
Some wineries we spoke to expressed scepticism about the CDS, referring to it as “green washing”. Whilst the evidence does not support this assertion, the collapse of the Redcycle program for soft plastics and the subsequent revelations that the plastics had been stockpiled have had quite a negative impact, with many citizens now believing that all recycling is being warehoused and not actually recycled. Thus, among some winery owners there is a perception that the expanded CDS will not be effective. Convincing those producers that glass bottles are indeed being recycled will be part of the challenge in getting widespread conformity in an expanded container deposit scheme.
Other wineries we spoke to are essentially in favour of an expanded CDS, however they expressed frustration that industry consultation has not occurred and will not happen until after the scheme expansion is approved.
If the expanded scheme is approved a phase-in period needs to apply to assist wineries to adjust their labels. We suggest that the scheme should not apply to any current labels and that a date be determined to allow wineries to convert their labels. Labels will require the addition of the “10c at collection depots/points in participating state or territory of purchase” wording and a barcode.
The discussion paper “Proposal to expand the scope of eligible containers in Queensland’s container refund scheme - Containers for Change” refers to making allowances for small producers to enter the scheme by extending the reporting dates from monthly to quarterly. We suggest that even quarterly may be too onerous for small producers and that a six monthly reporting period may be more appropriate.
We spoke to our local (Stanthorpe) container refund depot about whether they could handle the volume of an expanded CDS and they confirmed that they could and they had the space to be able to cope with the increase.
To summarise our support for an expanded container deposit scheme, we have used the feedback questions provided from the IntheLoop survey:
1. Do you support more containers being accepted for a refund as part of Queensland’s container refund scheme,
Containers for Change? YES
2. Do you support glass wine bottles between 150ml and 3 litres being eligible for a refund? YES
3. Do you support glass pure spirit bottles between 150ml and 3 litres being eligible for a refund?YES
4. The current size limit for flavoured milk, pure vegetable and fruit juice, and water and wine aseptic packs is 1
litre. Do you think the size limit of these containers should be increased to 3 litres? YES
We hope that this submission will be taken into consideration when the decision about expansion of the container deposit scheme is made.
We thank you for your time,
The Waste and Resource Recovery Group of
Granite Belt Sustainable Action Network.