A review of the Queensland Container Refund Scheme (CRS), now in its second year, has examined critical aspects of the performance of the CRS and its governance. CRS has a target return rate of 85 per cent by the year 2021/22.
The review was conducted by the Total Environment Centre (TEC) which has undertaken over 100 national and state environment protection programs.
CRS is coordinated by a single body, Containers for Change (CoEX), which has been strongly criticised for its lack of transparency and accountability, in particular by the Qld Productivity Commission. Environment groups have also voiced concerns about the absence of any formal and public consultation about the capacity of the collection network and forward strategies.
According to the review, the integrity of data about recycling and sales is central to the scheme’s credibility and it claims that the use of average weight-based verification is inherently inaccurate. The reviews’ authors states that NSW CRS has a far more rigorous and transparent approach.
“It appears to us there is excessive capacity for CoEX to massage data for public relations purposes and the incidence of fraud by collectors can exaggerate return rates,” it states.
“The Qld CRS adopts the same definition of eligible containers as other Australian states (except South Australia). There is a case for joint action to expand the definition, in particular to include wine.”
TEC also recently issued a report that found serious inadequacies in the network of SEQld refund points such as non-existent sites and an unacceptably high per person ratio to refund points, compared to NSW.
Notably, it said that the CoEx Board is dominated by the beverage industry and CoEX nominees.
Influence by smaller beverage interests
The review also stated that “…it is also of great concern that a smaller group of beverage interests took highly significant decisions about the network, prior to the full Board being established.
“A primary focus on costs to the sector can adversely influence the type and spread of refund points, negatively affecting convenience,” it said.
Further, evidence from the NSW and Qld CRS Annual Reports show that the NSW scheme is cheaper per container returned. The review said that, while drink prices are influenced by a range of factors, the Qld CRS has been found to cause higher price impacts on alcoholic drinks than in NSW; and marginally lower prices for non-alcoholic.
The review pointed to successful schemes in overseas jurisdictions that have a retail obligation to provide collection infrastructure.
“This limits the potential to site inconvenient refund points. The current rate of container return to the new network is about 40 per cent (plus 14 per cent from kerbside), well below the amount required to meet the 85 per cent target,” it said.
In summary, the review says that the CRS faces significant challenges and has made eight recommendations:
- The Queensland Government requires CoEX to change its culture and procedures to meet public expectations on transparency and accountability. The government should insist upon greater transparency regarding the progress and performance of the CRS; and ensure release of key reports and data.
- CoEX needs to achieve the same quality of data and reporting as in NSW and subject it to independent audit.
- The State Government should be considering an expansion to the scope of the CRS to include other beverage containers that could be collected by the CRS in the future. This should be done in collaboration with other jurisdictions and with input from industry and community stakeholders. The issue of recycled content could also be explored.
- With two CRS governance models emerging in Australia, other jurisdictions considering the design of their CRS need to seriously investigate the benefits and costs of separating the roles of Coordinator and Network Operator; and the single PRO model.
- Environment groups have consistently called for more engagement by the retail sector in locating refund points and TEC recommends government devise ways this can occur.
- The State Government must require CoEX to publish its budget, strategies and plans for the coming year, and each subsequent year. CoEX as a not-for-profit business, should provide public reports and analysis about its strategies, procedures and performance. In addition, an annual strategy should be published explaining its investment strategies for the coming year to develop and implement its collection network in Queensland. Formal CRP operator consultations and with other stakeholders/public consultation should accompany this.
- The government immediately review CoEX operations (including the performance of existing refund points) and future strategies and revise, where required, investment strategies that will ensure container return targets will be met. CoEX should publish identified milestone targets and updates on progress towards meeting its 85% + container return target by 2021/22.
- The State Government should instruct CoEX to establish formal links and regular consultations with established community environment and social groups about the expansion and maintenance of an effective refund and donation point network.