Overview
On 18 June 2024, the Australian Packaging Covenant Organisation (APCO) launched a formal consultation with its members to update its PFAS Action Plan, with the stated objective of eliminating all intentionally added PFAS from food contact packaging by June 2028. The consultation will review current thresholds, claims guidance, reporting requirements, and programme settings across Australia’s packaging supply chain. This is not a minor revision to an existing framework. It represents a material escalation from a voluntary, threshold-based approach to a defined elimination target backed by an industry-wide timeline.
The trigger for the review is straightforward. Reporting data collected under the 2022 PFAS Action Plan for the 2023 and 2024 periods demonstrates that a complete phase-out has not been achieved, despite the voluntary framework and the existing threshold of 100 parts per million (ppm) total fluorine in packaging materials. The data confirmed ongoing residual PFAS use across fibre-based food contact packaging in Australia. Rather than accept this plateau, APCO has moved to strengthen the programme, targeting full elimination rather than a managed reduction.
For environmental professionals, this development matters because it directly addresses one of the most persistent diffuse PFAS source pathways into Australian waste and wastewater systems. Food contact packaging entering municipal waste streams is a known contributor to elevated PFAS concentrations in landfill leachate and wastewater treatment plant biosolids. Reducing PFAS at the point of manufacture is ultimately a more cost-effective intervention than attempting to manage contaminated leachate or biosolids at the back end of the waste system.
Key details of the APCO PFAS Action Plan consultation and June 2028 phase-out target
The 2022 APCO PFAS Action Plan introduced a voluntary threshold of 100 ppm total fluorine as a proxy measure for intentionally added PFAS in packaging materials. This threshold was established as a practical screening level for the fibre-based food contact packaging sector, acknowledging that analytical testing for individual PFAS compounds across large packaging volumes was not yet uniformly practical. The total fluorine threshold was intended as a conservative but achievable interim target. The 2023 and 2024 reporting cycles, however, confirmed that voluntary compliance alone has not delivered the intended outcome across the full industry.
The June 2028 phase-out target now applies to all intentionally added PFAS across food contact packaging formats. The consultation launched on 18 June 2024 is reviewing four key areas: current concentration thresholds, the guidance used by manufacturers to make PFAS-free claims, reporting obligations for APCO members, and broader programme settings that govern how compliance is measured and verified. This scope signals that the consultation is not simply tightening a number but is reconsidering the entire architecture of how PFAS use in packaging is monitored and disclosed.
The alignment with federal chemical regulation is direct. The Industrial Chemicals Environmental Management Standard (IChEMS) prohibits the import, manufacture, and export of perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA), and perfluorohexane sulfonic acid (PFHxS) in Australia, a prohibition that came into effect in July 2025. These are among the most hazardous long-chain PFAS compounds. The APCO consultation extends the logic of these specific bans into the broader category of intentionally added PFAS in packaging, targeting compounds not yet captured under IChEMS but recognised as problematic under the PFAS National Environmental Management Plan version 3.1 (PFAS NEMP 3.1).
The waste pathway consequences are technically significant. PFAS-treated fibre packaging, when composted or processed through organic waste facilities, can transfer PFAS compounds into compost products. When landfilled, PFAS leaches into the leachate management system. Research has demonstrated that PFAS compounds, particularly short-chain variants used as replacements for legacy PFOS and PFOA, are highly mobile in aquatic and leachate environments. Landfill leachate can contain PFAS concentrations in the range of hundreds to thousands of nanograms per litre (ng/L), concentrations that create significant challenges for leachate treatment and disposal under current state environmental protection frameworks.
Australian context: PFAS NEMP 3.1, IChEMS, and state waste regulation implications
The APCO consultation sits within an increasingly dense regulatory environment for PFAS in Australia. PFAS NEMP 3.1, the current national reference document for managing PFAS-contaminated sites and waste, provides revised guideline values and waste management pathways that practitioners must apply in site investigations, remediation planning, and waste classification. Critically, PFAS NEMP 3.1 recognises that PFAS-affected wastes, including materials derived from landfill leachate or biosolids containing PFAS, face restricted disposal options. Reducing the quantity of PFAS entering the waste stream in the first place is therefore a logical upstream intervention consistent with the NEMP’s objectives.
At the state level, the Protection of the Environment Operations (Waste) Regulation 2014 (NSW) governs the classification and disposal of waste materials, including those affected by PFAS. Where waste contains PFAS above certain concentrations, reuse and beneficial use pathways are restricted or closed off entirely, substantially increasing disposal costs. Similar frameworks exist under the Environment Protection Act 2017 (Vic) and associated waste regulations in Queensland and South Australia. For landfill operators and waste managers receiving food industry or mixed municipal waste, the APCO phase-out is a practical upstream measure that stands to reduce the volume of PFAS-affected material entering their facilities, with direct implications for leachate management obligations, biosolids disposal costs, and compliance with state waste classification requirements.
References and related sources
- Primary source: msacsolutions.com
- mountain-bio.com
- nsw.gov.au
- PFAS National Environmental Management Plan (NEMP)
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This is an iEnvi Machete news summary. Prepared by iEnvi to summarise the source article for contaminated land, groundwater, remediation, approvals and site risk professionals.
Published: 20 Jun 2026
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