Brand Owner Membership

From small local businesses through to multinational corporations, nearly two thousand Australian organisations are committed to working towards achieving the 2025 National Packaging Targets. 

Find out more about the benefits APCO Brand Owner Membership will bring to your organisation. 


Brand Owner Membership FAQ

What is a Brand Owner?

As defined in the NEPM, a Brand Owner is:

  • A person who is the owner or licensee in Australia of a trademark under which a product is sold or otherwise distributed in Australia, whether the trademark is registered or not; or
  • A person who is the franchisee in Australia of a business arrangement which allows an individual, partnership or company to operate under the name of an already established business; or
  • In the case of a product which has been imported, the first person to sell that product in Australia; or
  • In respect of in-store packaging, the supplier of the packaging to the retailer; or
  • In respect of plastic bags, the importer or manufacturer of the plastic bags or the retailer who provides the plastic bag to the consumer for the transportation of products purchased by the consumer at the point of sale.

Do I need to become a Brand Owner Member?

If you are a Brand Owner business in the Australian packaging supply chain with an annual turnover of $5 million (AUD) or more, you may be required to meet obligations under the National Environment Protection (Used Packaging Materials) Measure 2011 (NEPM).

To meet these regulatory obligations, your business may choose between two options:

  • Become a Signatory to the Australian Packaging Covenant (the Covenant ) and a Member of APCO; or
  • Meet compliance obligations under the NEPM.

If you become a Signatory to the Covenant, APCO will provide a supported and guided pathway to comply with the obligations of the NEPM.

If you instead choose to meet your compliance obligations by submitting to direct regulation under the NEPM, your business will be required to meet prescriptive requirements for all consumer packaging materials, as set out by regulations in the jurisdictions in which your packaging is sold or distributed. These obligations cover:

  • The recovery of used packaging materials; 
  • The re-use, recycling or energy recovery of packaging materials; 
  • Demonstrating that the recovered materials have been re-used or exported; 
  • Demonstrating that reasonable steps have been taken to advise consumers as to how the packaging is to be recovered; and
  • Recording and reporting on the above obligations.

Responsibility for enforcing the NEPM rests with the Commonwealth and State and Territory governments in relation to companies operating within their jurisdictions. A summary of the implementation frameworks, targets specified for non-Signatories to the Covenant, and enforcement provisions in each jurisdiction is provided in the table below. 


What are my obligations as a Member?  

Brand Owner Members must meet the requirements of the Covenant, with obligations being:

  • Within three months of becoming a Signatory, submit an action plan that sets out what the Signatory proposes to do to contribute to the Covenant’s aim and meets the obligations published by APCO
  • By 31 March each year, commencing in the financial year following the year in which a company becomes a Signatory, submit an annual report that outlines performance against all of the action plan commitments and meets the reporting obligations as published by APCO
  • Publish the action plan and annual reports on its website in a prominent and readily identifiable way.
  • Make annual financial contributions in the form of Membership fees payable to APCO