ARL Compliance in 2026
by Sustainability Tracker 25/08/2026
Guide, News
by Sustainability Tracker 25/08/2026
Guide, News
This article was contributed by Sustainability Tracker.
If your packaging has carried an Australasian Recycling Label (ARL) for several years, it warrants a fresh review before the next print run. The label system itself has not changed since its last major update in 2023. What has changed is the environment around it: the 2025 National Packaging Targets have officially been missed, South Australia has introduced its own labelling mandate, and the Australian Competition and Consumer Commission (ACCC) has sharply increased the penalties for misleading environmental claims. An ARL label applied once and left unreviewed is a genuine compliance gap in 2026.
This guide sets out a practical self-check for brands: what to review on existing packaging, how the assessment process behind the ARL works, and where the regulatory environment is heading next.
The ARL system assesses each packaging component separately and assigns one of three outcomes, based on the proportion of the Australian population with access to the relevant collection service. A solid recycling symbol (“Recyclable”) applies where more than 80% of the population has kerbside access. An outlined symbol with an instruction, most commonly “Check Locally,” applies where access sits between approximately 60% and 80%. Below that threshold, the component is labelled “Not Recyclable” and belongs in general waste.
This threshold logic is set out by Little Aussie Communities and mirrors the assessment criteria APCO applies through the ARL program itself.
The Check Locally logo is not a recent addition. APCO introduced it in July 2023, in response to the collapse of the REDcycle soft plastics program the previous year, to cover materials with meaningful but not yet universal collection access, particularly soft plastics What is current in 2026 is that APCO has been actively reminding ARL Program Users to replace older soft plastics labels that predate this update with either the Check Locally logo or the Not Recyclable (bin) logo, on the basis that packaging still carrying the earlier labelling no longer reflects the program’s current assessment criteria.
Soft plastics packaging that has not been reviewed since before mid-2023 should be treated as a priority for audit.
Review any packaging with a soft plastics component against current ARL guidance. Labelling that predates the Check Locally update and has not been reassessed is likely inconsistent with what APCO now specifies as correct for that material.
The ARL is issued only through the Packaging Recyclability Evaluation Portal (PREP), and both PREP and the ARL program are exclusive to APCO members. A correctly applied ARL label therefore reflects a specific assessment of that packaging component, rather than a general assumption based on material type. Brands should confirm internally that each labelled component has been run through PREP, rather than labelled by analogy to a similar product.
State governments are legislating ahead of national reform. From 1 March 2026, South Australia requires every individual AS-certified compostable food container and beverage cup, not only the outer packaging, to be clearly labelled as home compostable, industrially compostable, or both. NSW’s Plastics Plan 2.0 introduces further requirements, including the phase-out of hard-to-recycle plastics, tethered caps on beverage containers by 2030, and mandatory labelling for away-from-home packaging.
Brands distributing nationally may need to satisfy more than one jurisdiction’s requirements concurrently, as the ARL does not itself cover these state-specific obligations.
The ACCC’s guidance on environmental and sustainability claims specifies that a claim must be truthful, specific, and no broader than the available evidence supports, and that visual elements such as symbols and logos can independently create a misleading impression where they overstate a product’s environmental performance. This carries greater weight in 2026: maximum penalties under the Australian Consumer Law for corporations increased to $100 million for conduct occurring on or after 28 March 2026. Any on-pack environmental claim, ARL-related or otherwise, should be backed by evidence the business could produce on request.
A PREP assessment is a point-in-time evaluation of a specific packaging component against current recycling infrastructure and collection data, rather than a certificate valid indefinitely. The correct label for a given material can therefore change over time independent of any change the business makes, simply because kerbside access data is updated or a collection pathway closes.
Reassessment is generally triggered by a change in packaging materials, formats, or suppliers; by distribution expanding into a state with its own labelling requirements; or by a program-wide update from APCO, as occurred with the Check Locally logo in 2023. Because PREP and ARL access sit within APCO membership, ownership of this process typically rests with whoever manages the packaging supply chain relationship or sustainability reporting, with marketing informed of any label changes ahead of print runs.
The direction of regulatory travel supports treating this as an ongoing process rather than a single fix. APCO’s own data release, published in December 2025, confirmed the 2025 National Packaging Targets were missed across all measured areas: packaging classified as reusable, recyclable or compostable reached 86% against a 100% target; plastic packaging recycling reached 20% against a 70% target; and average recycled content held at 44% against a 50% target. APCO has confirmed the Targets will continue beyond 2025 as the ongoing accountability benchmark while reform addresses the underlying structural gaps.
Two structural changes underpin this shift. First, Covenant membership: the Australian Packaging Covenant already applies to any business in the packaging supply chain with an annual turnover of $5 million or more that meets the Brand Owner definition under the National Environment Protection (Used Packaging Materials) Measure 2011, regardless of whether the business has formally signed up.
Businesses uncertain of their status can confirm it using APCO’s liability assessment tool.
Second, a new eco-modulated fee structure is expected to take effect from FY26-27, under which member fees will be calculated according to each business’s packaging profile, with harder-to-recycle materials priced higher. These sit alongside a broader push toward national packaging reform, including extended producer responsibility (EPR), which APCO has described as the mechanism for closing the gap between recycling capability and market demand and establishing consistent national rules. For brands operating across multiple states, this narrows the margin for outdated or approximate labelling.
Meeting these requirements depends on maintaining accessible evidence: current PREP assessments, correct label versions, and substantiation for on-pack claims, held somewhere it can be found rather than sitting solely within the packaging team’s internal files.
Sustainability Tracker exists to make that evidence visible rather than left to be taken on trust. The platform houses brand and product sustainability information, initiatives, certifications and evidence in one place, so consumers and supply chain partners can find what they need without having to ask for it. For brands working through packaging claims specifically, the Compass greenwashing tool checks environmental claims against the ACCC’s own guidance on greenwashing, and the platform’s proprietary FACTS framework (Facts, Appearance, Context, Transparency, Substantiation) gives brands a structured way to test a claim before it goes on pack. Brands completing this audit have a natural opportunity to document the outcomes on their profile, including PREP assessments and label versions, somewhere supply chain partners and customers can reference it directly.
Alongside the requirements above, APCO is currently running a formal review program called the ARL Uplift, examining the evidence base, rules and governance behind the label. The review covers four areas: the evidence underpinning current ARL rules, with a primary focus on kerbside recycling; whether the label’s icons and disposal guidance remain clear for consumers; how the ARL should function within broader national packaging reform, including a future Extended Producer Responsibility framework; and how ARL-related reporting can be better aligned with APCO’s other member obligations to reduce duplication.
APCO has stated explicitly that no immediate action is required from members, and that most existing ARL settings are expected to remain unchanged. Where changes are introduced, APCO has committed to a substantial transition window, typically 18 to 24 months, aligned where possible with brands’ normal packaging review cycles. Brands should treat this as a development to monitor rather than an immediate compliance requirement: some packaging components could eventually need updated labelling if the evidence supporting their current disposal instruction changes, though no such changes have been announced.
Two elements of the review are worth noting specifically. APCO is exploring whether future ARL settings should extend beyond kerbside pathways to cover alternate destination or away-from-home disposal options, though no decisions have been made. The ARL Uplift is also being designed to align with the national packaging design and grading framework currently being developed by the Department of Climate Change, Energy, the Environment and Water (DCCEEW), which points to the ARL becoming more tightly integrated with national reform rather than sitting alongside it.
Brands still completing their current ARL reporting cycle, which APCO notes commenced in December, should continue to respond to any requests from the ARL Compliance Team, as this remains a standing requirement independent of the uplift review.
According to APCO, the ARL Uplift review could, over time, affect the rules that determine which label appears on a given packaging component, the design or presentation of the icons themselves, how disposal pathways are communicated, and how ARL-related evidence and reporting align with other member obligations.
None of these changes are confirmed, and APCO has stated most current settings are expected to hold. For brands, the practical implication is that packaging designed and labelled to a genuinely evidence-based standard today, rather than to the minimum required to pass, is less likely to need reworking as these settings evolve.
The clearest way to build that margin is to use APCO’s Sustainable Packaging Guidelines (SPGs), a publicly available framework built around ten principles covering the full packaging lifecycle, from material selection through to end-of-life recovery. Reviewing packaging against the SPGs is already a Covenant obligation for APCO Brand Owner Members under the Packaging Sustainability Framework, so brands already doing this systematically are, in effect, already positioned for where the ARL Uplift is heading.
APCO also publishes material-specific quickstart guides under Principle 1, Design for Recovery, covering PET, glass, HDPE, PP, fibre-based and consumer soft plastic packaging, which are a practical starting point for brands auditing specific components.
Brands wanting to move beyond minimum compliance should treat three things as priorities:
For brands wanting to go deeper than this guide, APCO and its partners maintain several free resources.
What is the Australasian Recycling Label?
The ARL is an on-pack labelling system that tells consumers how to dispose of each component of a product’s packaging, based on an assessment of how much of the Australian population has access to the relevant collection service. It is administered by APCO and powered by the Packaging Recyclability Evaluation Portal (PREP).
Do I need to be an APCO member to use the ARL?
Yes. Both the ARL program and PREP are exclusive to APCO members, as confirmed on APCO’s own FAQ page. Businesses with an annual turnover of $5 million or more that meet the Brand Owner definition under the NEPM are already within scope of the Covenant, whether or not they have formally joined.
Is the “Check Locally” logo new in 2026?
No. APCO introduced Check Locally in July 2023, in response to the collapse of the REDcycle soft plastics program. What is current in 2026 is APCO’s active reminder to brands to update any labelling that predates this change.
What is the ARL Uplift?
The ARL Uplift is APCO’s ongoing review of the evidence, rules and governance behind the ARL, covering the label’s icons, its evidence base, and its role within broader packaging reform. No immediate action is required from members, and any confirmed changes will come with a substantial transition window, typically 18 to 24 months.
Where can small businesses get started with the ARL?
The ARL Marketplace is designed specifically for SMEs, offering free training and a directory of suppliers with packaging ready to label. Access requires APCO membership.