Submission in response to the Scoping Paper to review SA’s container deposit scheme: Improving South Australia’s Recycling Makes Cents

Monday, Feb 25, 2019

The South Australian Wine Industry Association Incorporated (SAWIA) appreciates the opportunity to respond with our views on the Scoping Paper to review SA’s container deposit scheme: “Improving South Australia’s Recycling Makes Cents” (the ‘Scoping Paper’).

SAWIA supports maintaining the status quo of South Australia’s Container Deposit Scheme (CDS) and is not convinced that there is objective evidence to warrant the types of changes proposed by the Scoping Paper. SAWIA recognises that the CDS has been successful in achieving its designed intention of reducing litter, and that this should remain its primary focus.

SAWIA questions whether the CDS is the best or most appropriate mechanism to address objectives other than litter reduction, such as improved recycling of packaging materials. More information on the costs and benefits of all available options is required.

SAWIA also contends that changing the CDS now would exacerbate confusion between the various State CDSs and that a better leadership approach would be for South Australia to advocate for national consistency, but review all the State operating systems for efficiency and cost reduction opportunities.

SAWIA believes that changing the CDS to include wine bottles would have a significant negative impact on the South Australian wine industry, which would go against the government’s stated positions of targeting effort to the greatest benefit and not negatively impacting businesses that support South Australian jobs.

There are some other specific aspects raised in the Scoping Paper that are of concern to us and these include:

  • a failure to articulate any problems with the existing CDS that might warrant the types of changes proposed;
  • there has been no identification of improvement goals for the review of the CDS, nor the performance indicators of success;
  • there has been no attempt to explain the causes of the decline over recent years in return rates of CDS-eligible beverage containers;
  • there is a significant information gap in objective data about material and financial flows through the waste recovery process that would enable identification of problem points;
  • no consideration has been given to the potentially significant impact that a public education program could have on improving recycling outcomes in a far more efficient manner than changing the CDS; and
  • there is no consideration of containers other than those containing beverages.