By Brian Smedley and Mark Gishen, South Australian Wine Industry Association
The South Australian Wine Industry Association (SAWIA) recognises the importance of recycling in achieving sustainability goals and supports effective recycling measures. Over the past four years, states and territories in Australia have also considered this, but unfortunately this has been limited to a simplistic discussion of expanding their container deposit schemes (CDS).
Getting a 10-cent refund for returning an empty wine bottle sounds like a good idea to most people, right? But is it really going to deliver better recycling outcomes, and is it worth the cost? In this article, we consider these questions and examine the impacts in the light of the purported benefits. SAWIA does not support the expansion of CDS to include glass wine bottles for several reasons as outlined in formal submissions to the proposals put forward throughout Australia (SAWIA, 2021).
This article briefly explains and summarises the reasons underpinning SAWIA’s position, highlighting the potential limitations of the CDS approach and the importance of exploring alternative recycling solutions. Additionally, we examine some of the economic and environmental impacts of including glass wine bottles in the CDS, emphasising the potential risks to the Australian wine industry and the broader economy.
The wine industry needs effective recycling
SAWIA acknowledges the role of recycling in transitioning to a green economy future and therefore advocates for evidence-based policies that maximise recycling outcomes, whilst aligning with international trading partners’ expectations and minimising greenhouse gas emissions.
There is an urgent need to address Australia’s relatively low recycling rates of packaging materials, especially plastic that has a recycling rate of only around 13% (DCCEEW, 2022). Of direct relevance to the wine industry, Australian-made glass wine bottles have an average recycled content of around 40%, compared with more than 50% for European-made on average.
The focus needs to shift to identifying and addressing the true causes of this mediocre recycling record, rather than the current focus on the details of the operation of the various CDS.
CDS is not the pathway to best recycling
SAWIA undertook considerable research to understand the impacts of expanding the CDS to include glass wine bottles since it was first raised by the South Australian Environment Protection Authority (SA EPA) in late 2019.
SAWIA’s work revealed a plethora of extremely compelling global evidence indicating that whilst CDS can help up to a point, other programs and mechanisms can be far more effective and cost efficient in maximising recycling rates. Furthermore, there is also evidence that CDS are far from the most efficient means of improving recycling and, even worse, may exacerbate greenhouse gas emissions, when compared with other alternatives (NZ GPF, 2022).
Of direct relevance to the wine industry, Australian-made glass wine bottles have an average recycled content of around 40%, compared with more than 50% for European-made on average.
This is no surprise, because the CDS is fundamentally a litter prevention program that encourages collection of packaging containers, but not recycling back to new containers. Glass wine bottles have been excluded from CDS in the past as they contribute only a fraction of a percent of litter items.
Inherently, a CDS does not incentivise recycling back into new containers because it does not involve contributions and participation from across the entire supply chain, most critically the manufacturers of the containers. No doubt this same lack of focus on true recycling was a major factor in the failure of the REDCycle soft plastics program.
It is important to note that the SA EPA’s published information (SA EPA, 2021) indicated that their proposal to expand the CDS was projected to increase recovery of glass containers by only 1%. The recycling rate (bottle-to-bottle) can only increase by some unquantified amount that will be less than this.
A key limitation of CDS is that it focuses on collection to increase supply of recovered materials, but does not increase demand for those materials to be remanufactured into containers.
Such a marginal improvement may fall well short of the sustainability requirements and expectations that overseas wine markets are considering introducing in the next few years (European Commission, 2022). In short, expanding the CDS will not be in the long-term interests of the wine industry’s sustainability efforts nor its overseas trade prospects.
There are better alternatives to increase recycling
A key limitation of CDS is that it focuses on collection to increase supply of recovered materials, but does not increase demand for those materials to be remanufactured into containers. In addition, it is limited to beverage containers and ignores the significant contribution of the same types of containers holding other materials and products.
Other countries that achieve high recycling rates have sophisticated systems that are typically comprehensive product stewardship schemes that involve the full supply chain and are based on the type of container material and not the contents (MS2, 2011; New Zealand Glass Packaging Forum, 2022). These systems provide incentives for both collection and remanufacturing and it is not surprising that they generally deliver global-best performance in cradle-tocradle recycling. Some of these systems contain elements of CDS alongside elements from other extended producer responsibility programs.
It is disappointing that Australia has so far failed to seriously consider exploring the range of alternative options to develop a locally-suitable ‘hybrid’ model for recycling (MS2, 2011). However, there are some bright spots emerging, such as Victoria introducing a separate glass-only kerbside bin. There is strong evidence from New Zealand that this could be a more effective solution than CDS for improving recycling, whilst at the same time reducing contamination of other recovered materials, reducing landfill waste, and reducing greenhouse gas emissions.
Recycling needs a national approach
The current state of recycling in Australia is variable, fragmented and complex. There are differences and inconsistencies across jurisdictions in terms of systems, rules, regulations, and data capture methods. The variations in rules and systems for CDS alone create confusion and duplication in compliance systems making interstate trade burdensome and costly for producers. It is clear to SAWIA that harmonisation is sorely needed. At the very least, CDS in all jurisdictions should have consistent rules on container eligibility and a single point entry system that provides recognition of label registrations and payments in all jurisdictions.
It is increasingly apparent that a nationally harmonised approach to recycling is required and this needs to include consistent timelines of implementation. Failure in this regard is clearly illustrated by Queensland having recently announced an expansion of their CDS, whilst at the same time Victoria and Tasmania have not even commenced their systems.
Glass wine bottles should remain exempt from the CDS
As already noted, the improvement in recycling from expanding the CDS to include glass wine bottles would be marginal. Expanding CDS by selectively adding glass wine bottles, but not other glass containers, would still fail to address contamination issues in co-mingled kerbside bins. It would not mitigate the loss of valuable recyclable materials or effectively tackle the root causes of contamination.
Whilst the benefits are minimal to say the least, the costs to the wine industry would be significant. SAWIA’s modelling, which has been independently verified, shows that expanding the South Australian CDS alone would cost South Australian wine producers nearly 40-cents per bottle on average totalling some $8.3 million every year. Expanding the CDS in all jurisdictions would increase the total to some $60 million annually averaging 30-cents per bottle. The cost to all wine producers across Australia would exceed $100 million annually (AGW, 2023).
So why force the wine industry to pay between 30- and 40-cents per bottle for a marginal increase in recycling? It just doesn’t make sense. Even in the unlikely event that this cost could be passed on to consumers, they only get back 10-cents for a marginal improvement in recycling, and that certainly doesn’t make sense either.
Whilst it appears that expanding the CDS to include glass wine bottles is popular with the community, it is questionable if this popularity is based on sufficient awareness about whether the benefits are worth the cost. It is worth noting that, even with their higher performing recycling systems, the European Union exempts glass wine bottles from its CDS.
Expanding the CDS is bad for the economy
Expanding the CDS to include glass wine bottles would increase costs for wine businesses, with a particularly severe impact on small businesses. The vast majority of the more than 1,200 South Australian wine producers are small businesses – often family-based – and the CDS has a disproportionate impact on them. A case study example of a small family winery producing around 800 dozen per year revealed that the cost to them would be around $1.16 per bottle in the first year and then 55-cents per bottle annually for just the South Australian CDS.
This increased cost to producers would have a negative financial impact on the wine sector and the broader economy. The direct impact on wine producers would necessitate cost cutting that would likely flow through the supply chain including manufacturers of packaging materials, suppliers of winemaking and viticulture inputs and professional services. Ultimately, it will detrimentally impact jobs in the wine and related sectors.
SAWIA’s concern about including glass wine bottles in container deposit schemes stems from its limited effectiveness in improving recycling, failure to address contamination issues, the likely negative economic impact, and the existence of more effective alternatives.
A comprehensive national approach, considering alternatives beyond the CDS, is necessary to achieve better recycling goals and maintain the industry’s global competitiveness. SAWIA believes that such an approach must include global best-practice, such as full product stewardship schemes or a separate glass only kerbside bin.
For more information, contact Mark Gishen at the South Australian Wine Industry Association on (08) 8222 9278 or [email protected]
AGW. (2023). Submission in response to the Queensland proposal to expand the scope of CRS, February 2023. Adelaide SA: Australian Grape and Wine.
DCCEEW. (2022). National Waste Report, December 2022. Canberra ACT: Department of Climate Change, Energy, the Environment and Water.
European Commission. (2022). Proposal for regulation on packaging waste, November 2022. Brussels: European Commission.
MS2. (2011). Best practice international packaging approaches, November 2011. Turramurra NSW: Martin Stewardship and Management Strategies Pty Ltd.
New Zealand Glass Packaging Forum. (2022). Product stewardship scheme design for glass, August 2022. Auckland NZ: New Zealand Glass Packaging Forum.
SA EPA. (2021). A discussion paper to review SA’s container deposit scheme, September 2021. Adelaide SA: South Australian Environment Protection Authority.
SAWIA. (2021). Submission in response to the SA EPA Discussion Paper on the CDS Review, November 2021. Adelaide SA: South Australian Wine Industry Association.
Mark Gishen is well known in the wine industry, having spent 12 years with the Australian Wine Research Institute prior to establishing his own specialist technical consultancy in 2006. He has a Master’s degree in Chemical Engineering (biotechnology) and more than 20 years of wine industry experience in a wide range of areas spanning winery production to applied research. Mark joined SAWIA in the role of Environmental Project Officer in April 2009.
Brian Smedley is a well known name in the wine sector, having worked for SAWIA since 1996, driving industrial relations and WHS initiatives for members. He has been the Chief Executive of SAWIA since January 2008. From working directly with wine business owners and managers, to driving policy, negotiating with government officials and promoting the sector, Brian is a tireless advocate for the wine industry.