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Queensland Container Refund Scheme – CDS Compliance
CDS Old update
From the 1st of November, new requirements were introduced for selling wine into Queensland. Wineries are now required to register with Container Exchange through the Beverage Manufacturer Registration Portal, this involves establishing a Container Recovery Agreement with COEX and then registering your products. Find further information on the process and register at the COEX Website
Key dates: 1st November 2023 & 1 January 2027
To lawfully sell wine into Queensland from 1 November 2023, beverage manufacturers must have:
- A Container Recovery Agreement (“CRA”) in force
- Registered their eligible beverage products with COEX
- A barcode on their eligible beverage products
CDS Compliance
With glass wine and spirit bottles now being included in Queensland’s Container Recovery Scheme, the Queensland Government has provided further information in relation to barcode requirements.
The Queensland Government expects compliance with the scheme’s legislative framework including that relevant beverage manufacturers have taken immediate steps to commence registering products into the Scheme through the COEX portal and that manufacturers of beverage products have a Container Recovery Agreement in force and display a barcode on containers eligible for a refund under the Scheme to sell products in Queensland.
Container Recovery Agreements
Where beverage manufacturers have made best endeavours to enter the registration process in a timely way and prior to 1 November 2023, but a Container Recovery Agreement has not been fully executed through no fault of their own, then a beverage manufacturer making ongoing sales in Queensland will not be considered to be offending against Section 99P of the Waste Reduction and Recycling Act 2011 (the Act).
Display of barcode
Section 99P of the Act states that a barcode must be displayed on eligible beverage products sold in Queensland.
To allow sufficient time for beverage manufacturers who do not currently have barcodes on their products to transition to the new requirements, the department will provide an initial 12-month grace period for new wine and pure spirit manufacturers to comply with the requirement to display a barcode.
Wine and pure spirit manufacturers should note that a barcode is required to complete the product registration process; however, this barcode is not required to be displayed on the container immediately.
The Queensland Government has also acknowledged that products produced prior to the end of the grace period may be sold after the grace period ends. It is an overarching principle of the transition period that the department does not expect beverage manufacturers to relabel or over sticker existing stock.
Full details can be found on the Department of Environment and Science website.
More information about support for beverage manufacturers is available on the Container for Change website.
COEX can be contacted on 13 42 42 or qldbm@containerexchange.com.au.
The Queensland Container Refund Scheme (“CRS”) has been expanded to include wine bottles. Consumers in Queensland will be able to redeem their wine bottles for a 10-cent refund within Queensland, and ‘beverage manufacturers’ (defined by legislation as either the maker, importer or distributor of the packaged beverage) will need to pay the scheme price on their eligible containers from 1 November 2023. The scheme price for glass bottles in Queensland is currently 13.9 cents per container plus GST.
Advocacy
- AGW and Wine Victoria in conjunction with the state wine industry associations continue to lobby the Queensland government for a grace period on compliance and enforcement activities until manufacturers have been given the opportunity to be onboarded by COEX, noting the unreasonable timeframe provided to comply.
- The department has offered to provide written advice from the regulator acknowledging the transition, “best endeavours” by manufacturers to comply by the 1 November deadline, and that they will take an “education first” approach to compliance and enforcement. We expected to receive the written advice in the week commencing Monday 11th September 2023, however it has not yet been provided – we will continue to share updates as they arise.
Get Involved
AGW and state wine associations encourage all members who sell wine into Queensland to attend the online Q&A sessions to find out more about the new requirements and take the opportunity to let COEX know the impact of this scheme expansion and unrealistic timeframes may have on your business.
We have communicated the detrimental impacts of this expansion repeatedly and extensively, however we need to unite as an industry and share our concerns. COEX needs from the businesses directly who are affected by this changes.
Australian Grape & Wine, Wine Victoria, and all other state wine associations will continue to advocate on your behalf and fight for changes to this scheme.