With all the talk about the pending updated 2035 emissions reduction targets, I can’t help but wonder if one way of getting our national policy mojo back is greater emphasis on the link that waste and resource recovery (WARR) has to carbon. The reality is that Australia’s 43 per cent emissions-reduction target by 2030 and net zero by 2050 are achievable if we mobilise every lever, including the WARR industry. Continuing to reduce “waste” to an end-of-pipe problem squanders enormous potential for abatement.
By keeping materials circulating longer, designing out waste, and diverting organics from landfill, we cut emissions across whole value chains while building sovereign capability. Direct “waste sector” emissions (mostly landfill methane) are a small slice of the inventory, but the avoided emissions from material efficiency are larger: every tonne of aluminium, glass, paper, steel or plastic we reuse or recycle avoids energy-intensive virgin material extraction and production.
Organics is the fast win: stop food and garden waste entering landfill and you curb methane. The European Union (EU) recognised this by requiring separate collection – clarity that drives infrastructure roll-out and end-market investment. To date we only have one state that has mandated. Those jurisdictions that have opted to introduce separate collections remain focused on household waste, with very little attention being given to the C&I sector despite business offering a huge opportunity for diversion. s
What’s not working
Much of the accredited abatement is tied up in landfill Australian Carbon Credit Units (ACCUs), without driving circular demand. ACCUs remain a compliance currency and the landfill gas method is being reformed and extended, reflecting how much methane abatement has relied on this route. It is anticipated that the soon-to-be-public, revised landfill gas method will materially expand ACCU supply in coming years. Yet an ACCU created at a flare or engine doesn’t, by itself, create a market signal to use recycled content, design for repair, or avoid waste in the first place. That leaves a demand-side gap that procurement and product policy must fill.
Safeguard rules cover landfills, but also restrict co-located ACCU abatement. Non-government large landfills fall under the Safeguard Mechanism. By design, if abatement would reduce covered emissions at a Safeguard facility, that project is not eligible to earn ACCUs. This is an anti-double-counting rule that, in practice, blocks co-locating new ACCU crediting projects at big, covered landfills, and undermines industry’s ability to co-locate facilities at existing WARR precincts, capitalising on the existing planning and transport infrastructure. Instead, those projects can only be developed to reduce the landfill’s liability and create Safeguard Mechanism Credits (SMC), which has not yet been not enough of an incentive. The reality is that landfills often share a resource recovery precinct with other facilities. In some interpretations of the Safeguard rules, even facilities that do not have any connections to a Safeguard landfill could be barred from creating ACCUs: clearly an anti-competitive and perverse outcome. Decarbonisation options on sites that most need them can be financially harder to stand up unless the Safeguard baseline and/or on-site investments do the heavy lifting.
Fragmented state settings create cross-signals. States set levies, service standards and licensing. The result: different landfill levies, different organics service timelines, and varying methane management expectations. NSW is now funding a Landfill Emissions Abatement Program given a large number of smaller and/or council landfills lack comprehensive methane controls, while other states take different approaches. We are also increasingly seeing different emissions reporting and compliance levels on state-based policies when compared with national and other state policies. These divergences raise cost and uncertainty for national WARR operators and investors, and they blunt the climate signal. Crucially, they do not offer a direct incentive to commercially maximise reduced emissions.
There is no dedicated waste sector decarbonisation plan, yet. The Commonwealth sectoral net-zero industrial plan, which explicitly lists WARR as a sub-sector, remains outstanding. However, a standalone, published pathway for WARR is not even on the agenda, meaning policy instruments like described above land piecemeal. A clear sector plan would lock in priorities, timelines and investment sequencing. I also despair about the effectiveness of proponent-led methodologies given there would also appear to be no prioritising process, meaning I am unclear how we could drive incentivisation through this pathway in the foreseeable future. Leaving each proponent to figure out their own waste and resource recovery plans without input from our industry is doomed to fail.
One economy, one set of rules
Fragmentation is solvable. The Commonwealth and states need to make circularity the default, with consistent rules:
• Finish packaging reform and mandate design and local Australian recycled content. Move from voluntary targets to enforceable product-level rules. That is how you turn the ACCU abatement focus into materials abatement and sovereign manufacturing demand.
• Scale demand through procurement. The Federal Environmentally Sustainable Procurement Policy must be expanded with clear recycled-content minimums for priority goods. Government and private industry are the market-makers; pull signals convert remanufacturing capacity using recycled materials into emissions cuts.
• Harmonise organics policy and timelines. Set a national date for universal FOGO and continue to utilise the Recycling Modernisation Fund to co-fund composting/AD capacity with consistent quality specifications. Methane abatement is immediate and bankable.
• Nationalise methane performance expectations and incentives. Create minimum methane capture/management requirements for all medium-to-large landfills, harmonised across states, with robust monitoring and public data. That removes the incentive for “leakage” to weaker jurisdictions.
• Let’s copy what works in Europe: use less, for longer.
A practical agenda for Australia
1. Set a national materials-intensity goal for priority sectors and align procurement, standards and investment to hit it. This shifts focus from end-of-pipe credits to material efficiency and will assist with Australia’s target to double material circularity.
2. Make packaging reform a genuine market-maker: tie design for recyclability to mandatory local Australian recycled content thresholds, in order that processors see bankable offtake and invest.
3. Go hard on organics: universal FOGO by a national date, standardised service design, and national compost quality specs (that address safe levels of PFAS) embedded in soil and procurement programs.
4. Complete the net zero industry plan and align national carbon policy to reduce reporting burden on industry, while creating a thoughtful regulatory environment that decarbonises the economy, not simply creates a compliance burden.
5. Improve the proponent-led ACCU pathway to enable method development that supports keeping materials circulating longer, which supports capital investment in remanufacturing in Australia and reduces reliance on virgin materials.
6. Count what counts: evolve emissions reporting and procurement guidance in order that avoided emissions from reuse/repair/high-value recycling show up in decision-making and finance. Clearly link to the forthcoming net-zero sector plans so WARR’s role is explicit rather than incidental.
The payoff if we do
Clear, consistent rules turn today’s patchwork into an investable national program: methane falls fast via organics and better landfill performance; upstream emissions shrink as design, repair and recycled content become non-negotiable; and Australia builds a competitive circular economy.
Europe shows that when policy signals align, industry delivers. If we align Commonwealth and state levers, finish packaging reform, sharpen the Safeguard/ACCU interface, complete the Net Zero Industry plan, and make procurement pull recycled content through supply chains, WARR becomes a frontline climate solution, not just a service industry, but a decarbonisation engine for a net-zero Australia.
Gayle Sloan is the CEO of WMRR