Published name
1. Do you currently participate in traceability?
2. Do you support the framework adopting a technology-agnostic approach?
2a) Please explain
Technology-agnostic allows for innovation and does not exclude smaller players
3. Do you support the framework adopting an outcomes-focused approach?
3a) Please explain
Outcomes are the whole point, not data for data's sake
4. Should the framework include requirements to share data with government to support reporting, for example progress reporting against national recycling targets?
4a) Please explain
Transparency and accountability are crucial, and critical for informing policy development and adjustment
5. What requirements could be included in the framework to help industry and governments report against targets? For example, what type of traceability information could support reporting?
Location of origin (city and country), business names of all handlers in the supply chain
7. Would you adopt a voluntary framework?
8. What timeframe would be required for you to implement traceability in your own business?
9. Do you support recycled content traceability being initially voluntary?
9a) Please explain
Early adopters can help test and refine the system before full mandatory participation
10. Should recycled content traceability become mandatory for everyone over time?
10a) Please explain
Only mandatory systems are effective and provide consumers with assurance. Mandatory systems also eliminate any disadvantage to early adopters due to bearing costs of compliance.
11. Should recycled content traceability be mandatory only in specific circumstances or sectors?
11b) Please explain
A fully circular economy needs to encompass all materials.
12. Do you support governments requiring consistency or alignment with the framework as a requirement for future initiatives, for example grant funding?
13. Is the proposed objective appropriate for a voluntary approach?
14. If the proposed framework were mandatory or to become mandatory, would the proposed framework objective still be appropriate?
15. Is the proposed framework sufficient to support collection and sharing of accurate and harmonised recycled content information?
16. Do you use traceability systems for other parts of your business? For example to trace food or agricultural products.
17. Is it appropriate for traceability to begin at the material recovery step in the supply chain?
18. Does the defined scope of recycled material and recycled content cover all types of recycled materials that should be traced?
19. Are the supply chain steps shown in Figure 2 and described in Table 1 of the discussion paper sufficient to capture all types of recycled content supply chains (for example, glass, paper, plastics, metals and construction materials)?
20. Should imported recycled materials be within scope of the framework once they enter Australia?
20a) Should the framework requirements apply in the same way to imported materials? Please explain
As far as possible, yes.
21. Is the GS1 Global Traceability Standard an appropriate basis for guiding interoperability in recycled content supply chains?
23. Would you require further guidance from Australian governments to ensure interoperability of recycled content traceability systems is achieved?
24. Could your business currently achieve one-up, one-down traceability?
25. Is it appropriate to start with ‘one-up-one-down’ traceability?
26. Would 4 years be enough time for industry to adapt to full traceability?
27. Would 4 years be sufficient if the framework were mandatory?
28. Would the key data elements provide enough information and assurance about recycled content to encourage its use over virgin materials?
28a) What other data should be collected and shared in the supply chain to increase confidence in recycled content?
Confidence is helpful, but traceability alone is not enough to overcome price differences between recovered and virgin materials. The only way to correct for this market failure is to regulate mandatory recycled content inclusion.
29. Is the ISO definition for recycled content (ISO 14021:2016) appropriate to define the data point that is captured once recycled material is used to create a new product?
31. Should the key data elements described in table 4 of the discussion paper also be required for imported recycled materials?
31a) Please explain
Different standards could create disadvantages for local materials and businesses.
32. If you use a traceability system for a reason other than tracing recycled content (such as modern slavery reporting), could it be expanded to include the data elements in Table 4 of the discussion paper?
33. Is the guidance on key data elements sufficient to support accurate and harmonised recycled content information?
34. Do you use recycled content in your business?
35. Are you an end-user of recycled-content goods?
36. Are you an Australian business that uses recycled materials?
37. Are the four proposed chain of custody approaches appropriate to determine the recycled content in goods?
39. Should the framework define the mass balance accounting period, allocation of attributes, credit units and other mass balance requirements?
40. Could the framework help to harmonise existing chain of custody certification schemes?
41. Is it sufficient to trace the origin of domestic recycled content to the jurisdiction of origin?
41a) Please tell us why it is not practical and what level of origin should be traced?
State/Territory of origin might be enough to identify a specific business in the smaller states, but not larger states where there may be multiple operators. Level of origin should be narrowed, more localised.
42. Is it sufficient to trace imported recycled content back to the country of origin?
43. What challenges might be involved in tracing imported recycled content further than the country of origin? (for example, city of origin)
Cooperation of foreign businesses and governments, particularly in countries with no current traceability standards.
45. Are you an Australian business involved in processing or using recycled materials?
46. Does the proposed definition of ‘chemicals of concern’ include or exclude substances it shouldn’t?
47. Does the proposed guidance contradict or duplicate existing practices, such as industry guidance, state, territory or international requirements?
48. Are the standards identified in Table 8 of the discussion paper sufficient to guide implementation of recycled content traceability?
49. Which of these standards do you use in your business?
51. Should any other international traceability requirements or standards be considered under the proposed framework?
52. Do you currently verify domestic recycled content information you receive through the supply chain?
53. Do you currently verify imported recycled content information you receive through the supply chain?
54. Is it sufficient for verifiers to meet the ISO standard relating to verification bodies (ISO/IEC 17029:2019)?
57. What opportunities are available or could be considered to encourage stakeholders along the recycled content supply chain to use the proposed framework?
Legislation. Education. Circular economy policy and targets.
58. Would any additional stakeholders have a role in implementing the framework?
59. Would the proposed guiding principles provide sufficient guidance to support implementation of the proposed framework?
60. Do you think the benefits of traceability outweigh the costs of implementation for your business?
62. Are the proposed indicators of performance sufficient to measure the success of the framework?
64. Would 3 years of implementing the framework provide sufficient information to support the first review?
