Key findings
\ Product stewardship (PS) and
extended producer responsibility
(EPR) measures can facilitate the
shared responsibility of manufacturers,
retailers and consumers for the impact
of products on the environment, public
safety and human health. They aim
to ensure that everyone involved in
the creation and use of a product
shares the burden of what happens
to it at the end of its useful life.
\ Consumers and producers are not
exposed to the full cost of the waste
they generate. This is a ‘negative
externality’ that can be addressed
through EPR or PS.
\ The most successful international
examples of PS are underpinned by
mandatory approaches.12 There are
currently no mandatory Australian
schemes.\ Multiple stakeholders raised the need
for mandatory PS for ‘difficult to
recycle materials’, such as packaging
made from multiple materials.
\ The Product Stewardship Act 2011
is administered by the Australian
Government to provide a framework
for reducing the environmental and
other impacts of products. It is
currently only applied to a limited
number of products. Of the several
voluntary schemes, participation
and effectiveness vary widely.
12   AlphaBeta (2019) Recycling and resource recovery infrastructure in Victoria: International and Australian comparisons,
report for Infrastructure Victoria
33
Infrastructure VictoriaRecommendation 09
33


There is confusion about the
responsibilities of different
government bodies involved
in the waste and resource recovery
sector. This is well documented
by the Victorian Auditor-General’s
Office and was raised with us
by stakeholders.
VAGO found that the lack of an overarching
waste policy and gaps in statewide
guidance resulted in ad hoc and reactive
responses from agencies instead of
strategic responses, and an inability to
plan for sufficient infrastructure.
In November 2019, the Victorian
Parliament’s Environment and Planning
Committee Inquiry into Recycling and
Waste Management also recommended
a review of governance arrangements
to ensure clear roles, responsibilities and
accountabilities for various organisations.
Infrastructure Victoria supports this
recommendation.
The Victorian Government has indicated
in the Recycling Victoria policy that it
will create a new body, which will provide
an opportunity to clarify roles and
responsibilities.Infrastructure Victoria recommends
that the Victorian Government:
\ Eliminate overlap in roles and
responsibilities of the Department of
Environment, Land, Water and Planning
(DELWP), Sustainability Victoria (SV)
and the Waste and Resource Recovery
Groups (WRRGs). For waste, key areas
to distinctly allocate are policy, strategy,
behaviour change, waste collection, waste
processing, infrastructure planning and
contingency planning.
\ Specify the waste management
services roles and responsibilities
of local governments in legislation.
\ The roles and responsibilities of local
government should include minimum
service standards, implemented through
subordinate instruments. Minimum service
standards could include bin lid colours
and the specific materials accepted.
\ Provide financial support for local
governments to transition to minimum
standards, where necessary.
\ Consider changes to the way waste
and material processing services are
procured to address market power
imbalances between local governments
and service providers. This could include
mandating participation in collective
procurement processes or having these
processes handled by a statewide
or regional authority.Provide greater clarity of roles
and responsibilities for Victorian
Government bodies involved in
recycling and resource recoveryRecommendation 10
Context Recommendation
34
Infrastructure Victoria Advice on recycling and resource recovery
34


Key findings
\ Clarity in roles and responsibilities is
critical for effective and coordinated
planning and implementation of
the state’s waste programs and
activities. Greater clarity can improve
transparency, making it easier
to monitor performance and
track progress.13
\ DELWP , SV and the metropolitan
WRRG are not clearly or publicly
reporting on the progress of
individual actions, overall objectives
and outcomes of their strategies
in a way that enables industry and
community to track their progress.
\ Differences in service provision
between local government areas
limits the ability to have consistent
statewide education14 and can create
confusion for households, leading to
contamination of material streams.\ Local governments play a crucial
role in the waste and resource
recovery sector, particularly in waste
collection. However, their collection
roles and responsibilities are not
enshrined in legislation.15 Defining
these roles and responsibilities in
legislation is an opportunity to set
minimum standards for waste
collection.
\ The market for MSW recovery
and reprocessing services in Victoria
is dominated by a few large players.
Victoria’s approach to procuring
collection and recovery services
has, in part, contributed to this
problem by creating consolidation
in the market as businesses bid
for larger and larger numbers of
council contracts to achieve
economies of scale.  \ Local governments, individually,
are at a disadvantage when
negotiating waste processing
services.
\ Improved governance arrangements,
such as mandatory collective
procurement or the creation
of a suitable authority, have the
potential to counterbalance growing
market power issues in Victoria’s
waste sector.
\ In the face of recent major
disruptions to the sector, responsible
agencies worked together to
minimise the amount of recyclable
materials that went to landfill.
Having a clear lead agency and
decision-making powers for this
work would have streamlined
processes.
13   Victorian Auditor General’s Office (2019) Recovering and
Reprocessing Resources from Waste14  ibid. 15   Infrastructure Victoria (2019) Legislative and
regulatory reviewLocal governments play a crucial role in
the waste and resource recovery sector,
particularly in waste collection.
35
Infrastructure Victoria Recommendation 10
35


The Victorian Government’s
planning and policy decisions
need to be informed by reliable
data on recycling and resource
recovery. Gaps in data create
issues for policy and strategy
implementation, particularly
in monitoring progress
towards targets (refer to
Recommendation 12).
The responsibility for data collection is
currently shared by SV, the EPA, local
governments and the WRRGs. SV has
responsibility for coordinating reporting
of this data. There is significant scope
to improve the quality and coverage
of data currently published by SV.
In Recycling Victoria: A new economy,
the Victorian Government has committed
to modernising Victoria’s waste data. Data
on the state of Victoria’s recycling sector
reports 69% of materials are currently
recovered for recycling. However, this
data does not include information on
whether the recovered material is recycled,
illegally dumped or has some other fate. The Victorian Government can implement
its commitment to modernising Victoria’s
waste data by:
\ Introducing new data reporting
requirements in regulatory and
contractual conditions for recycling
and resource recovery operators.
\ Providing clearer guidance to local
governments and recycling and resource
recovery operators on how to report
data in a standardised, consistent way.
\ Introducing new controls and quality
assurance to verify and validate data.
\ Implementing enhanced data analysis
to evaluate the data gathered through
the above recommendations. This
should include monitoring for perverse
outcomes, identifying risks to performance
(by sector and material) and identifying
opportunities to realise circular economy
outcomes (e.g. where waste from one
business can be used for production
in another business).
\ Regularly reporting performance data
to improve transparency in the sector.
\ Ensuring Victorian data quality
standards align with other Australian
jurisdictions.Improve the quality
and use of data to support
resource recoveryRecommendation 11
Context Recommendation
36
Advice on recycling and resource recovery Infrastructure Victoria36


Key findings
\ Introducing new data reporting
requirements and providing guidance
on how to report data would
improve the coverage and quality
of information on the fate of
recovered materials and help
overcome issues with data quality.
\ A 2011 report by VAGO on
MSW management found that
deficiencies in data quality had
reduced the reliability of performance
data, and that complete, timely,
accurate data is necessary to
effectively report on performance.16
\ Data is often collected through
voluntary surveys of local
governments and waste recovery
and reprocessing operators, so
is incomplete and not necessarily
accurate.
\ There is scope to impose
data requirements on operating
licenses within the waste and
resource recovery sector through
amendments to the Environment
Protection Act 1970. Licencing
conditions should require regular,
periodic reporting of material
flows data at all resource
recovery facilities.17 \ There is scope to improve data
provision and reporting in waste
processing contracts. This can
support improved outcomes for
materials as well as contingency
planning for sector disruption.
\ Data reporting and governance
requirements should be specified
where legislation is used to define
the scope of different government
entities, including local
governments.18
\ Timely data publishing can improve
transparency and accountability
around the performance of the sector
and inform education and behaviour
change campaigns. It can also assist
to predict disruption to or emerging
gaps in the system. Victoria’s
2017-18 data was published in
September 2019.
\ Data governance and system
improvements should meet
the following objectives:
– establish a framework for
monitoring progress towards
the circular economy, including
the identification of indicators
and metrics– introduce a new waste and
resource recovery data system to
enable better waste management
and circular economy monitoring
– expand waste and recycling
market intelligence reporting
– improve the usefulness and
accessibility of Victorian waste
data to local governments,
industry and the community.
\ Clear governance for a data
improvement program is required
for efficient delivery. Costs are
uncertain but may be in the
range of $20 million over three
to five years.
16   Victorian Auditor General’s Report, Municipal Solid
Waste Management17   AlphaBeta (2019) Recycling and resource recovery
infrastructure in Victoria: International and Australian
comparisons, report for Infrastructure Victoria 18   Refer to Recommendation 10 which recommends
their role should be defined in legislation
 37
Infrastructure Victoria Recommendation 11
37


In the high-performing
international and Australian
jurisdictions we examined,
clear long-term vision and
ambitious quantitative targets
were common.
These included overall system performance
as well as waste reduction. In some
jurisdictions, targets were statutory with
non-compliance penalties. To be effective,
targets require rigorous data collection (see
Recommendation 11) as well as necessary
funding and detailed sector planning. We
support the targets that have been formally
adopted in the Victorian Government’s
circular economy policy – Recycling Victoria:
A new economy.To leverage the adopted targets,
Infrastructure Victoria recommends:
\ In the longer-term, investigate more
ambitious and complex targets (e.g.
based on carbon emission reduction)
and penalties for non-compliance.
\ Consider the use of existing legislative
and regulatory tools to improve
performance in specific areas such as:
– The application of planning and
building permit conditions to establish
performance standards for waste
reduction and resource recovery
during both construction and
ongoing operations.
– The application of food business
licence conditions to establish
performance standards for food
waste reduction and organics recovery.
– The application of EPA operating
licence conditions to establish
performance standards in the
industrial sector.Use targets to
drive performanceRecommendation 12
Context Recommendation
38
Advice on recycling and resource recovery Infrastructure Victoria38


Key findings
\ Our analysis of places around the
world with high-performing recycling
and resource recovery sectors shows
that they have taken a long-term
approach to targets, revisiting and
increasing these as performance
improves.19
\ In other countries, targets are also
progressing from simple weight
or volume-based targets to more
sophisticated carbon emission
reduction or material-specific targets.
These address perverse outcomes
and focus effort where the greatest
environmental outcomes can
be achieved.
\ Legislative and regulatory tools
outlined above could be used
to implement the Government’s
proposed new requirement for
business to sort commonly
recyclable materials and organic
wastes from unrecoverable wastes.\ Waste management services for
multi-unit developments are not fully
integrated with the MSW system.
In many cases, waste management
services are provided directly by
commercial operators on behalf of the
body corporate, rather than by local
governments. Sustainability Victoria has
developed the Guide to Better Practice
for Waste Management and Recycling
in Multi-unit Developments to improve
waste management practices
and increase recycling in multi-unit
developments. This guidance has
now been incorporated into the
Victorian Planning Provisions.
\ In the City of Melbourne, there are
high concentrations of high-rise
residential buildings, restaurants
and cafes. City of Melbourne residents
recycle only 25% of their waste,
which is low compared to the
Victorian average of 45%.20 This
reflects the higher barriers and
lower rates of recycling in multi-
unit developments generally.21 22
19   AlphaBeta (2019) Recycling and resource recovery infrastructure
in Victoria: International and Australian comparisons, report for
Infrastructure Victoria
20   City of Melbourne (2019) Waste and Resource
Recovery Strategy 203021   Quantum Market Research (2019) Kerbside Collection
Deep Dive, report for Infrastructure Victoria
22   Quantum Market Research (2019) Waste Advice Research,
report for Infrastructure Victoria
 39
Infrastructure Victoria Recommendation 12
39


The Victorian Recycling
Infrastructure Plan (VRIP),
formerly known as the Statewide
Waste and Resource Recovery
Infrastructure Plan (SWRRIP)
has provided a long-term vision
and roadmap to guide planning
for waste and resource recovery
infrastructure across the state.
However, the private sector primarily
provides waste management, resource
recovery and recycling infrastructure,
with limited matching of strategic
considerations (like waste generation
trends, land use planning or minimisation
of costs to households and businesses)
to the type and location of infrastructure.
The objectives of the Plan are therefore
difficult to realise. The Victorian Government should use existing planning mechanisms to improve
recycling and resource recovery performance by:
\ Strengthening the status of the
VRIP to ensure cohesion of waste
management and planning decisions
across multiple levels of government.
Further amendment of the Victorian
Planning Provisions could achieve this.
\ Proactively encouraging the appropriate
location of waste and resource recovery
operations.
\ Establishing and strengthening
standardised land use buffers around
waste management sites, considering
the implications of local government
area boundaries. This would provide
greater certainty to the market in
developing these sites.\ Developing and maintaining spatial
data on waste generation and flows,
as well as resource recovery and
reprocessing infrastructure capacity
and capability.
\ Facilitating the appropriate location
of waste and resource recovery through
the formal development of an inter-
agency working group of responsible
Victorian resource recovery agencies,
economic development agencies,
and local governments
\ Undertaking active and transparent
contingency planning to provide
greater network resilience.
\ Including provision for waste-to-energy
and landfill capacity in the VRIP , to
optimise the management of residual
waste in both business-as-usual (BAU)
conditions and disruption.Strengthen the status of, and
processes around, Victoria’s
Recycling Infrastructure PlanRecommendation 13:
Context Recommendation
40
Advice on recycling and resource recovery Infrastructure Victoria40


Key findings
\ For resource recovery and
reprocessing to be cost-effective
and for recycled products to be
attractive to markets on a price
basis, the location of particular
industries is important. If they
are continually pushed further out
of the metropolitan area as land
value increases and sensitive uses
encroach upon them, performance
will decrease due to a lack of
suitable facilities. We found
multiple instances where waste
management and reprocessing
sites are at risk from the lack of
alignment between waste planning
and land use planning decisions.
For example, a major construction
and demolition (C&D) recycler in
the south eastern suburbs is likely
to lose their current site in the
medium term. With no other
suitable sites nearby, 100,000
tonnes of processing capacity
may be lost.
\ We have also heard from multiple
stakeholders that government
agencies often appeal land use planning decisions at VCAT based
on their presence in the SWRRIP .
Although these cases are generally
won for the cause of waste
management, going to the tribunal
is funded by taxpayers and causes
delay. The Metropolitan Waste
and Resource Recovery Group
(MWRRG) is working to identify
and protect waste management
hubs of state significance through
collaborative processes with local
government and other agencies.
However, the current approach and
resourcing limits the completion
of the protection plans to two sites
(or hubs) per year.
\ Currently there is limited
communication and collaboration
across government levels and
portfolios to facilitate strategic
investment in the Victorian waste
and resource recovery industry.
For the best outcomes, regulators
need to understand the compliance
status of industry operators and
non-regulatory agencies. They also
need to understand the business operations of the waste sector
industry operators to ensure waste
and resource recovery programs
are aligned with market conditions.
Improved coordination across
government could improve the
sector. The interagency working
group for the Combustible Waste
Recyclable Materials (CWRM)
taskforce has been effective in
bringing together responsible
regulating agencies, aligning efforts
and improving communication and
collaboration. This could serve
as a model for future efforts.
\ Waste-to-energy and landfills
will likely both play a role in
managing waste in the future.
The VRIP needs to reflect this point,
while ensuring that Victoria does
not over-invest in capacity.
\ The VRIP’s objectives need
to integrate with a range of
government planning policies
and plans, including land use
planning, economic development,
and resources strategies.
41
Infrastructure VictoriaRecommendation 13


Victoria’s recycling resource recovery
system is under pressure.
Since 2015, the Victorian Government
has invested more than $135 million
in supporting the recycling and resource
recovery sector in Victoria, to ensure
continuity of service to Victorians
and to minimise the likelihood of
otherwise recoverable material being
sent to landfill.23 06.
What
we found
42
Advice on recycling and resource recovery Infrastructure VictoriaInfrastructure Victoria Advice on recycling and resource recovery
42


Some recyclable material is still being
landfilled and some Victorians have
become sceptical about the fate of their
recycling. In developing our advice, we
polled community members and found
that a quarter of Victorians we surveyed
believe their recycling goes to landfill.24
In the past 18 months, Victoria has seen
recyclable material being sent to landfill
after a major materials recovery operator
closed. In Victoria, particularly metropolitan
Melbourne, the recovery and processing
sector is concentrated, so there is limited
competition. Market concentration also
means there is little incentive for operators
to improve and limited redundancy in the
sector. This leaves Victoria vulnerable to
commercial or global shifts.
Responding to these challenges requires
a combination of short and long-term
initiatives. Victoria’s recycling and resource
recovery sector needs to respond to the
immediate challenges facing the sector
and deal with upcoming changes in national
policy. At the same time, all Victorians need
to take a different approach to waste.
Long-term, waste reduction and avoidance
will assist to ensure the circumstances
of the past 18 months are not repeated.
23   Department of Environment, Land, Water and Planning
(2020) Recycling Victoria: A new economy24   Quantum Market Research (2019) Waste Advice
Research, report for Infrastructure VictoriaChina National Sword Policy
Like many countries around the world,
Victoria has relied on international
markets to accept some recovered
material. In 2016/17, a significant
amount of Victoria’s waste exports –
nearly all plastic exports and 75% of
paper and card – went to China. The
introduction of the China National
Sword policy placed strict limits on
the level of contamination China
would accept in recovered materials.
Before China National Sword, many
Material Recovery Facilities (MRFs)
were paying Victorian councils for
recyclables, which subsidised the
cost of collecting Municipal Solid
Waste (MSW). MRFs then sold these
materials to China. After China
National Sword, the global price for
materials, particularly paper, card and plastics, plummeted. Victorian
operators scrambled to find new
export destinations for these
materials. This was repeated
on a global scale, with developed
economies looking to redirect
collected recyclables to other
waste markets throughout Asia.
China National Sword shone a
spotlight on the fact that a number of
Victoria’s major MRF operators were
operating as recovery businesses,
not actual recyclers. Their practice
of collecting and storing materials
to take advantage of economies of
scale for recovery led to stockpiles of
combustible materials. These posed
significant fire risks to the Victorian
community as the market for
the materials dried up.Victoria’s recycling and
resource recovery sector
needs to respond to the
immediate challenges
facing the sector and
deal with upcoming
changes in national policy.
43
What we found Infrastructure Victoria


Waste is a growing by-product of
modern life. A growing population
and increasing consumption mean
the amount of waste is growing in
line with our demand for products
and services. Unless Victorians change
their approach to waste, the need
for recycling and resource recovery
infrastructure will also continue to
grow to deal with ever-increasing
quantities of material.
Recycling, re-use and recovery all lead
to positive outcomes and are better
than simply disposing of waste to landfill.
The waste hierarchy shows the best ways
to deal with waste, avoidance being the
most preferable. Managing waste in line
with the waste hierarchy is legislated
in Victoria through the Environment
Protection Act 1970 (the EP Act).
Avoidance is at the top of the waste
hierarchy. Re-using, recycling, recovering
energy and disposing of waste all incur
economic and environmental costs. As
the scale of these tasks grows, so will
the costs. The most cost-effective way
to manage waste is to create less in
the first place.
A policy approach that prioritises
transitioning to a circular economy can
support a long-term focus on avoidance,
re-use and recycling. A circular economy
aims to reduce the environmental impacts
of production and consumption, along with
more productive use of natural resources.25 Improved waste avoidance, recycling and
resource recovery are key in a circular economy
In February 2020 the Victorian
Government released Recycling
Victoria: A new economy, which outlines
its vision for how materials are used
and managed, and provides long-term
direction for the sector. While investment in resource recovery
infrastructure is essential for the immediate
and medium-term stability of the sector,
a circular economy could reduce the
significant, growing pressure on the
sector by reducing the material it needs
to manage. Figure 2: Preferred waste outcomes
DisposalContainmentTreatmentRecovery of energyRecyclingReuseAvoidanceMost preferable
Least preferable
44
Advice on recycling and resource recovery Infrastructure VictoriaInfrastructure Victoria What we found


25  Department of Environment, Land, Water and Planning
(2019) A circular economy for Victoria – Creating more
value and less waste
26   Blue Environment (2019) Victorian waste flows
projections, report for Infrastructure Victoria Victoria’s recycling and resource
recovery sector manages increasingly
large amounts of waste from
three sectors:
\ Municipal Solid Waste (MSW). MSW is
waste managed by local governments.
Most MSW comes from kerbside bin
collection services (predominantly from
households, along with some small
businesses). MSW tends to be separated
into three streams: garbage, commingled
recycling and food and garden organics.
In 2018, about 3 million tonnes of MSW
was generated in Victoria, which is
around 21% of the total waste stream.26
\ Commercial and Industrial waste (C&I).
C&I is waste generated by business
and industry. About 4.8 million tonnes
of C&I waste was estimated to be
generated in Victoria in 2018, which is
around 33% of the total waste stream.
\ Construction and Demolition Waste
(C&D). C&D waste comes from
construction and demolition and can be
collected as mixed or segregated
streams. C&D is the largest part of the
waste stream, making up an estimated
46% of total waste generated in Victoria
in 2018 – about 6.6 million tonnes.
Across all three sectors, a total
of 14.4 million tonnes of material is
estimated to have entered the waste
pathway in 2018. This poses a significant task for
the Victorian recycling and resource
recovery system. Without changes to
the way products are designed, consumed
and disposed of, this task is only going
to get bigger as our population and
economy grows.
Unless Victorians change how they think
about waste, the resource recovery sector
will need to significantly expand its capacity
to deal with different materials, especially if
Victoria is to improve its recovery rate and
reduce the amount of material going to
landfill. In 2018, an estimated 10 million
tonnes of material was recovered and 4.4
million tonnes went to landfill – a recovery
rate of about 69%. If Victoria simply
maintains the status quo in terms of
resource recovery, the sector will need
to be able to process over 12.5 million
tonnes of material by 2038/39.
The past 18 months have shown that the
status quo is unsustainable. More of the
materials recovered for recycling are being
stockpiled or disposed of in landfill due to
lack of an end market, which means the
69% of resources that are recovered
are not all being recycled. We have an
opportunity to truly recycle these materials
for other uses. However, Victoria’s recycling
and resource recovery system lacks the
capacity and capability required to process
recovered materials to a standard that
means they can be re-used locally or
exported for re-use overseas.
A circular economy could also improve the
quality of recyclable material collected and
increase demand for recovered materials.
In this advice, we consider some of the
challenges facing the recycling and
resource recovery sector in Victoria,
focusing on boosting resource recovery
rates and promoting use of recycled
material. However, many of the solutions
proposed will be costly to sustain in the
long-term, unless Victorians change their
attitudes to waste. Reducing the amount
of waste Victorians generate will not only
help to manage these costs, but also
reduce pressure on finite natural resources
and lessen the environmental impacts
of production and consumption.Waste generation in Victoria, now and into the future
Re-using, recycling,
recovering energy and
disposing of waste all incur
economic and environmental
costs. The most cost-
effective way to manage
waste is to create less in
the first place.
45
What we found Infrastructure Victoria


7,000,000
6,000,000
5,000,000
4,000,000
3,000,000
2,000,000
0Waste generated (tonnes)
Construction &
DemolitionCommercial &
IndustrialMunicipal
Solid Waste1,000,000Figure 3: Recovery of household and commercial
waste is low, and is an opportunity
Landfilled Recovered Source: Blue Environment
Each type of material (i.e. paper and
cardboard, organics, glass, plastics) will
require particular processing with different
infrastructure to meet our growing needs,
and each will have different end markets.
Therefore, it is important to understand the
projected growth for each material stream.
Priority materials are plastics, glass,
organics, paper and cardboard, tyres and
e-waste. The following section looks at
each of these materials in more detail. We
have identified opportunities to improve the
recycling and resource recovery rates for
these materials through a mixture of policy
and infrastructure responses. These include improving infrastructure
capacity and capability for processing,
developing end markets, or reducing
the amount of these materials entering
the recycling and resource recovery
system altogether.
Each type of material
(i.e. paper and cardboard,
organics, glass, plastics) will
require particular processing
with different infrastructure
to meet our growing needs.
 46
Advice on recycling and resource recovery Infrastructure Victoria


There are six priority materials
for the sector to manage
While Victoria’s overall recovery rate
is relatively high, the recovery rate for
each material varies significantly. This
depends on how easy the material is
to recover, its quality, and how strong
end markets are for that material.
Metals, for example, have a high recovery
rate (around 91%). Metals are relatively
simple to recover and process and have
a relatively high value in end markets.
Plastics, on the other hand, have a low
recovery rate (around 23%) due to the
complexity and cost of recovering and
processing them, and weak end markets.
For Victoria to increase its overall recovery
rate, we need enough capacity and
capability to process increasing amounts
of a range of materials. At the same time,
the way we process these materials needs
to change if Victoria is to meet the policy
objectives announced by the Council of
Australian Governments (COAG) in March
2020, which progressively bans export
waste from 1 July 2020. We also need to
change to meet the increasingly high import
standards from international markets.
The COAG export ban will require a
step-change in recycling and resource
recovery in Victoria. The ban will be
introduced in phases over the next
two years, starting with the export of
unprocessed glass, which will be banned
by July 2020, followed by mixed waste
plastics by July 2021, all whole tyres in
December 2021 (except bus, truck and
aviation tyres for re-treading), and mixed paper and cardboard, by 1 July 2024.
Value-added materials can still be exported
under the proposed ban. These include:
\ Plastic: clean plastics sorted to a
single resin type and processed ready
for further use (e.g. flakes and pellets).
\ Paper: paper pulp and
single stream bales.
\ Glass: cullet ready for further use.
\ Tyres: crumb rubber, powder
and granules, shredded tyres
for tyre-derived fuel or bus, truck and
aviation tyres for re-treading.
Victoria has relied heavily on export
markets for recovered materials.
Metals have a high recovery
rate because they are
relatively simple to recover
and process and have a
high value. Plastics, on the
other hand, have a low
recovery rate due to the
complexity and cost of
recovering and processing
them, and weak markets.With the introduction of the ban, Victoria will
need to ensure materials can be processed
to meet the export standards, and develop
local markets for recovered materials.
In our advice, we are focusing on
organics, e-waste and the four materials
covered by the proposed export ban.
These materials either:
\ align with specific elements of the
terms of reference for this advice
\ make up a high volume of material
entering the recycling and resource
recovery stream
\ have low recovery rates
\ represent a high environmental impact
\ have a combination of these factors.
Figure 4 shows a range of materials
assessed against these criteria. Materials
including masonry, metals and textiles
do not meet as many of the criteria and
have been excluded from in-depth analysis.
The proposed export ban reinforces
the need to improve Victoria’s recycling
of these materials.
47
What we found Infrastructure Victoria


Data from Blue Environment * based on SV/RMIT 2013 method, considers CO2,
energy & water saved only
** red means export markets at risk from export ban  *** estimate of economic opportunity considering likelihood
that export market will decline and/or local supply will increase,
potential for value-added local or export uses, commodity
value uplift likely from changes to sorting and collection
Source: Brock Baker Environmental ConsultingOur analysis of the current infrastructure capacity for these priority materials
identifies 430 facilities across Victoria. Figure 5 summarises these facilities.
Figure 5: Resource recovery infrastructure comes in many different forms
Infrastructure type Paper &
cardboardPlastics Glass Tyres Organics E-waste Multiple
Processing Infrastructure
Reprocessing Facility 9  32  6  3  19  4  -
Recovery Infrastructure
Specific Materials Recovery Centre  7  -    1  5  5  24  -
Materials Recovery Facility  -    -    -    -    -    -    13
Resource Recovery Centre  1  -    -    -    -    -    265
Bulk Haul Consolidation Centre  -    -    -    -    -    -    1
Drop-off Centre  -    -    -    -    -    6  15
Other  -    -    -    -    -    -    14 Figure 4: Some materials are more problematic than others
Organics Plastics Glass Paper &
cardboardE-Waste Masonry Metals Tyres Textiles
Tonnes of material generated 2,522,497 593,983 349,313 2,024,337 84,662 6,633,503 1,610,570 64,164 192,894
Tonnes of materials
recovered1,096,433 138,981 267,846 1,500,784 67,147 5,576,791 1,473,986 57,916 168
Recovery rate 43% 23% 77% 74% 79% 84% 92% 90% 0%
Proportion of waste
generated that is exported*2% 7% 3% 32% 1% 0% 31% 62% 0%
Indicator of
environmental hazardMethane Litter, micro
plastics in
wasterways,
foodStockpile
safetyFire risks Hazardous Inert Leaching Fire risks Not
significant
Net environmental
benefit of recycling**High Medium High High Not
assessedNot
assessedHigh Not
assessedNot
assessed
Opportunity to increase
value adding in Vic***High High High High Medium Low Low Medium Low
48
Advice on recycling and resource recovery Infrastructure Victoria


Priority material2025
(COAG ban & 70% RR)2030
(80% RR)2039
(90% RR)
Paper
and cardboard
Plastic
Organics
E-waste
Glass
TyresIn addition to the COAG export ban,
we have assessed the impact of other
policy changes already announced by
the Australian and Victorian Governments
that focus on improving recycling and
resource recovery, specifically the National
Waste Policy Action Plan targets. We have
modelled the impact of these targets in
our analysis and, where relevant, discussed
their potential impact on the infrastructure
and market development that will
be needed.
Here we assess the projected generation
and processing capacity for each priority
material to show the potential infrastructure
required for each to meet the COAG waste
ban requirements and particular recovery
rates (%RR). The data used in this section
are based on future projections, and should
be considered approximate only. Figure 6
summarises our analysis, with further
details below.National Packaging Targets and
the National Waste Policy Action Plan
The Australian Government and other
state and territory governments have
adopted targets initially proposed by
the Australian Packaging Covenant
Organisation (APCO) to greatly improve
the management of packaging waste
by 2025. The four targets for 2025 are:
\ 100% reusable, recyclable or
compostable packaging
\ 70% of plastic being recycled
or composted
\ 30% of average recycled content
included in packaging
\ phasing out problematic and
unnecessary single-use plastics.In 2018, the Australian Government
released the National Waste Policy:
Less waste, more resources. The
policy was agreed on by Australia’s
Environment Ministers and the
President of the Australian Local
Government Association in
December 2018.
The National Waste Policy Action
Plan presents targets and actions
for its implementation. The Action
Plan established a target of 80%
average resource recovery from all
waste steams following the waste
hierarchy and a 50% reduction
in food waste by 2030. The plan
is intended to complement and
support the implementation of
the national packaging targets.
Figure 6: Reprocessing
capacity varies by material
49
What we found Infrastructure Victoria


Seven different categories of plastics
are recovered in Victoria. End-of-life
plastics are forecast to increase from
586,300 tonnes in 2018 to more than
735,000 tonnes in 2039.27
Around 130,000 tonnes of plastic were
recovered in 2018, or 23%. Over half
of the plastic recovered comes from MSW.
The majority is commercial and industrial
packaging material.
Recyclability varies depending on plastic
type. Polyethylene terephthalate (PET) and
high-density polyethylene (HDPE) tend
to have higher recovery rates than other
types of plastic. Recovery rates also vary
across sectors. Recovery rates of MSW
plastics were estimated at around 32%
in 2018, with C&I and C&D at 18% and
10% respectively.
Victoria has the capacity to manage
end-of-life plastics at current recovery rates
until 2022, but the challenges go beyond
capacity. Victoria, like many jurisdictions,
relies heavily on export markets for plastics,
with around 63% of recovered plastics
exported for processing offshore. The
COAG Waste Export Ban will stop mixed
and unprocessed plastics from being
exported.
The COAG Waste Export Ban requires
that from July 2021, the export of mixed
plastics that are not of a single type
(i.e. they require further sorting, cleaning,
and reprocessing before they can
be remanufactured) will be banned. Plastics
Figure 7: End-of-life plastic generation is expected to grow in Victoria
Figure 8: Plastics processing shortfall is expected by 2025Source: Brock Baker Environmental Consulting
27   Brock Baker Environmental Consulting (2020) Waste and Resource Recovery Infrastructure
Data and Spatial Analysis, report for Infrastructure Victoria, and Infrastructure Victoria analysis800,000
700,000
600,000
500,000
300,000400,000
200,000
0Tonnes
2018 2022 2025 2039 2030100,000
Priority material2025 (COAG ban and
70% recovery rate)2030 (80%
recovery rate)2039 (90%
recovery rate)
Generation 641,100 676,700 735,300
Current processing
infrastructure capacity160,050 160,050 160,050
Projected recovery required
to meet policy settings448,700 541,300  661,800
Excess or shortfall
in capacity -288,650 -381,250 -501,750
50
Advice on recycling and resource recovery Infrastructure Victoria


By June 2022, this will extend to single-
resin plastics that have not been re-
processed (e.g. cleaned and baled
PET bottles). From July 2022, only clean
plastics sorted into a single resin type
and processed for further use (e.g. flakes
and pellets) will meet the new export
requirements. National recovery targets
of 70% for plastics by 2025 and 80%
overall recovery by 2030 further complicate
this, as shown in Figure 8.
Victoria has limited infrastructure to sort
or process plastics so they can be used
locally or exported. Victoria’s collections
systems and MRF sorting infrastructure
cannot sort plastics adequately by type
(plastics codes 1 to 7) or process these
into value-added flakes and pellets for
use as plastics feedstocks.
There is an immediate need to plan
for investment in plastics reprocessing
infrastructure in Victoria. Investment
will also be necessary to meet the APCO
and National Waste Policy target recovery
rates of 70% and 80% in Melbourne and
regional Victoria, respectively. Current
plastic processing facility capacities range
anywhere from 100 to 15,000 tonnes.
Most regions generate enough plastic
waste to support new infrastructure,
as long as there is a market for the
recovered material.There is also a gap in capacity to sort
mixed plastics from MRFs, with no
market for recovered material. This
means material is either being stockpiled
or landfilled. Because resource recovery
rates for plastics are very low, at 23%,
significant change in people’s recycling
behaviour is also necessary to complement
any infrastructure upgrades.
51
What we found Infrastructure Victoria


The amount of end-of-life packaging
glass is forecast to increase from
344,000 tonnes in 2018 to more than
442,000 tonnes in 2039.28
About 264,000 tonnes of glass were
recovered in 2018, around 77%. Of this,
MSW recovery rates were 87%. This glass
was made up of packaging glass such as
jars, bottles and other containers. C&I and
C&D make up very little of the material
stream — 2% and 0% respectively. Glass
recovered from C&I is mostly packaging
glass. There is limited data on other glass
types generated by C&I, and no data on
glass recovery from C&D.
There are two main markets for recovered
packaging glass:
\ recycling into new glass packaging,
such as bottles and jars
\ recycling into glass sands, aggregates
and other uses, such as abrasives,
beads and rendering.
The capacity and capability of
infrastructure to meet these markets
varies. In Victoria, two beneficiation
plants recover glass cullet from packaging
glass as feedstock for glass manufacturing,
and there is only one manufacturer
of glass packaging. This reliance on
a single manufacturer is a potential
risk for future glass reprocessing.Glass
Figure 9: End-of-life glass generation will grow by 2039
Figure 10: Glass processing is sufficientSource: Brock Baker Environmental Consulting
Source: Brock Baker Environmental Consulting (2020) Waste and Resource Recovery Infrastructure
Data and Spatial Analysis, report for Infrastructure Victoria, and Infrastructure Victoria analysis500,000
300,000400,000
200,000
0Tonnes
2018 2022 2025 2039 2030100,000
Priority material2025 (COAG ban and
70% recovery rate)2030 (80%
recovery rate)2039 (90%
recovery rate)
Generation 382,000 404,900 442,600
Current processing
infrastructure capacity494,200 494,200 494,200
Projected recovery required
to meet policy settings267,400 323,900 398,400
Excess or shortfall
in capacity 226,800 170,300 95,800
28   Brock Baker Environmental Consulting (2020) Waste and
Resource Recovery Infrastructure Data and Spatial Analysis,
report for Infrastructure Victoria52
Advice on recycling and resource recovery Infrastructure Victoria


However, recovering glass for use as
glass sand is growing in Victoria. There
has been significant new investment in
resource recovery in this area, supported
by changes to construction specifications,
which have increased how much recycled
glass sand can be used in road and rail
construction. Victoria’s infrastructure
construction pipeline provides a significant
market for these materials.
As Figure 10 shows, across these two
uses, there is expected to be enough
infrastructure capacity to manage end-
of-life glass generation and recovery
rates over the next 20 years.
Using materials at their highest value for
as long as possible is key in a circular
economy.29 Turning recycled glass into
glass sand rather than back into glass
packaging can be seen as ‘downcycling’.
However, with limited domestic demand
for glass production, glass sand will be
particularly important in resource recovery
end markets. Glass sand is also one of the
only end-uses for glass fines – small glass fragments that are difficult to recover
with existing MRF and glass beneficiation
infrastructure.
Glass sand will play a vital role as virgin
sand becomes scarce due to growing
demand for infrastructure. Scarcity
of virgin sand is leading to significant
increases in cost, and in many metropolitan
uses, recycled glass sand is very cost
competitive. Using glass sand will also
reduce the need to quarry for virgin
sand. This will support a circular economy
in which already extracted natural resources
continue to cycle through the economy.
The capacity for packaging glass and
glass sand reprocessing only exists in
metropolitan Melbourne. There may be
opportunities to invest in small-scale
glass crushing infrastructure in regional
areas, allowing these facilities to process
locally collected glass packaging into
glass sand for use in local roads.
This would require the collection and
aggregation of glass in regional hubs.
Turning recycled glass into glass sand rather than back into glass
packaging can be seen as ‘downcycling’. However, with limited
domestic glass production, glass sand will be particularly important
as a market for recycled glass.
29  Department of Environment, Land, Water and Planning (2019) A circular economy for Victoria – Creating more value and less waste53What we found Infrastructure Victoria


Organics include food organics (FO),
garden organics (GO), mixed food
and garden organics (FOGO), timber
and biosolids.
Organic material is one of the largest
waste streams in Victoria, estimated
to make up around 35% of household
garbage bins.30 Given almost all this
material can be recovered in some way,
this represents a significant opportunity
to improve resource recovery.
In 2018, the overall resource recovery
rate for organics in Victoria was 43%.
The amount of organic waste generated
in Victoria is forecast to increase from
2,489,200 tonnes in 2018 to more
than 3,128,400 tonnes in 2039.
Organics recovery from MSW was 29%
in 2018. This was mainly garden and timber
waste. Some food waste is recovered from
MSW, but less than garden and timber
waste. One reason for this could be the
relatively small proportion of councils
offering FOGO collection. C&I sector
resource recovery rates were 58%, made
up of garden, timber and food wastes,
while recovery rates in C&D were around
91%, which mainly came from recovered
timber construction materials.31
One of the biggest opportunities
to improve resource recovery is by
increasing household food waste
recovery. Organics
Figure 11: More organic waste is expected over time
Figure 12: Organics processing shortfall is expected by 2025Source: Brock Baker Environmental Consulting1,500,0002,500,0003,500,000
3,000,000
1,000,000
1,000,000
0Tonnes
2018 2022 2025 2039 2030500,000
Priority material2025 (COAG ban and
70% recovery rate)2030 (80%
recovery rate)2039 (90%
recovery rate)
Generation  1,277,700  1,348,900  1,466,400
Current processing
infrastructure capacity 764,800  764,800  764,800
Projected recovery required
to meet policy settings 894,400  1,079,100  1,319,800
Excess or shortfall
in capacity -129,600 -314,300 -555,000
Source: Brock Baker Environmental Consulting (2020) Waste and Resource Recovery Infrastructure
Data and Spatial Analysis, report for Infrastructure Victoria, and Infrastructure Victoria analysis54
Advice on recycling and resource recovery Infrastructure Victoria


Currently, a significant proportion of
household food waste enters landfill in
Victoria because there is no separate
collection service, leading to an MSW
recovery rate for food of 10.6%.32 However,
more local governments are introducing
kerbside FOGO collection, which is
expected to increase FOGO recovery over
time. Based on current FOGO recovery
rates, our analysis suggests there is enough
capacity to recover FOGO from households
and businesses through to 2022. Beyond
2022, we expect there to be a shortfall,
particularly if more local governments
introduce kerbside FOGO collection.
Metropolitan Melbourne will need more
capacity to manage current and future
organics recovery. Given the challenges in
processing organics material – particularly
the infrastructure and buffer zones required
– the opportunities for significant new
reprocessing in Melbourne will likely be
limited and small-scale. A more practical
solution is to aggregate and consolidate
organic material, with initial processing
that reduces weight and volume followed
by transport to regional areas for additional
processing and use. Regional Victoria
will also need more capacity to manage
its organic waste.Given the challenges
in processing organics –
particularly the
infrastructure and buffer
zones required – the
opportunities for significant
new reprocessing will
be in regional Victoria.
30   Sustainability Victoria (2014) Victorian Statewide Garbage
Bin Audit 2013
31   Brock Baker Environmental Consulting (2020) Waste and
Resource Recovery Infrastructure Data and Spatial Analysis,
report for Infrastructure Victoria
32  ibid. 55
What we found Infrastructure Victoria


Paper and cardboard includes
mixed paper and cardboard, office
paper, and newspapers and magazines.
End-of-life paper and cardboard is
forecast to increase from 1,997,800
tonnes in 2018 to more than 2,491,500
tonnes in 2039.33 (see Figure 13)
The overall recovery rate for paper and
cardboard in Victoria was 74% in 2018.
The vast majority of recovered paper
and cardboard in Victoria comes from the
C&I sector, with a resource recovery rate
of 81%. Paper and cardboard collected
directly from businesses is a single type
(a clean stream) making it easier to process
and more valuable. Paper and cardboard
from MSW, however, is mostly commingled
and has a recovery rate of around 35%.34
C&D only accounts for a small amount
of recovered paper and cardboard.
There is currently enough capacity to
manage end-of-life paper and cardboard
in Victoria. However, once the COAG export
ban comes into effect, there is expected
to be a reprocessing shortfall from 2024
onward. The COAG Waste Export Ban
requires that by July 2024, all mixed paper
and cardboard be banned from export.
Paper will need to be pulped or sorted by
paper type in order to be exported.Paper and cardboard
Figure 13: End-of-life paper and cardboard volumes are expected to
increase
Figure 14: Paper and cardboard processing shortfall is immediateSource: Brock Baker Environmental Consulting1,500,0002,500,000
2,000,000
1,000,000
0Tonnes
2018 2022 2025 2039 2030500,000
Priority material2025 (COAG ban and
70% recovery rate)2030 (80%
recovery rate)2039 (90%
recovery rate)
Generation  2,178,400  2,296,300  2,491,600
Current processing
infrastructure capacity1,116,105 1,116,105 1,116,105
Projected recovery required
to meet policy settings 1,524,900  1,837,000  2,242,400
Excess or shortfall
in capacity -408,795 -720,895 -1,126,295There is an immediate need to plan for future
investment in paper and cardboard reprocessing
infrastructure in Victoria, particularly to meet the
COAG Waste Export Ban.
Source: Brock Baker Environmental Consulting (2020) Waste and Resource Recovery Infrastructure
Data and Spatial Analysis, report for Infrastructure Victoria, and Infrastructure Victoria analysis56
Advice on recycling and resource recovery Infrastructure Victoria


There is an immediate need to plan for
future investment in paper and cardboard
reprocessing infrastructure in Victoria.
Most paper and cardboard reprocessing
in Victoria is located in metropolitan
Melbourne with one notable paper mill,
Australian Paper, in regional Victoria.
To meet the COAG Waste Export Ban,
Victoria will need to invest in more paper
pulping or more paper type separation at
MRFs.
33  Brock Baker Environmental Consulting
34   There are several conflicting data sources in the public
domain for paper and cardboard and it is suspected
that the MSW recovery rate for paper and cardboard
may actually be around 50%.
57
What we found Infrastructure Victoria


Tyres are a composite product made
from natural and synthetic rubber,
steel, carbon, fibre and bonding agents.
Tyres are shredded to separate the
materials, most of which have markets
for recovery. The amount of end-of-
life tyres is forecast to increase from
91,700 tonnes in 2018 to more than
113,000 tonnes in 2039.35
In 2018, the overall resource recovery
rate for tyres in Victoria was 87%. Of this,
MSW recovery rates were 100%. This is
because only a small proportion of tyres
are managed through the MSW sector.
These are usually tyres that are disposed
of at Resource Recovery Centres and
Transfer Stations, or collected through
the clean-up of tyres dumped on local
government land. Whole tyres are banned
from landfill in Victoria, but shredded
tyres can be disposed of in landfill.
The vast majority of tyres in Victoria are
managed through the C&I sector with a
resource recovery rate of 83%. This is
because end-of-life tyres are removed at
and collected by tyre retailers when new
tyres are fitted. A contractor then removes
tyres from these premises for processing
or export. Data indicates that there are
some tyres entering landfill. C&D does not
contribute to generating end-of-life tyres.Tyres
Figure 15: End-of-life tyres are expected to increase by 2039
Figure 16: Tyre processing capacity is sufficientSource: Brock Baker Environmental Consulting
35   Brock Baker Environmental Consulting (2020) Waste and
Resource Recovery Infrastructure Data and Spatial Analysis,
report for Infrastructure Victoria80,000120,000
100,000
60,000
0Tonnes
2018 2022 2025 2039 203040,000
20,000
Priority material2025 (COAG ban and
70% recovery rate)2030 (80%
recovery rate)2039 (90%
recovery rate)
Generation  99,700  104,900  113,600
Current processing
infrastructure capacity 112,500  112,500  112,500
Projected recovery required
to meet policy settings 69,800  83,900  102,200
Excess or shortfall
in capacity  42,700  28,600  10,300
Source: Brock Baker Environmental Consulting (2020) Waste and Resource Recovery Infrastructure
Data and Spatial Analysis, report for Infrastructure Victoria, and Infrastructure Victoria analysis58
Advice on recycling and resource recovery Infrastructure Victoria


There are three main pathways for
recovered end-of-life tyres:
\ baling of tyres for export as Tyre
Derived Fuel or as casings for
re-tread/seconds markets
\ shredding of tyres for export
as Tyre Derived Fuel
\ further reprocessing into feedstocks
such as crumb rubber, granules
or powder.
Victorian infrastructure capacity and
capability are different for each of these
recycling pathways. The COAG Waste
Export Ban requires that by December
2021, all whole tyres, including baled
tyres, will be banned from export, except
for bus, truck and aviation tyres for
re-treading. Tyres will need to be shredded
for use as tyre derived fuel, or further
processed into crumb rubber, granules
or powder.
Figure 16 shows there is enough
mechanical infrastructure in Victoria to
shred or crumb tyres to meet a range
of product requirements. There is no
immediate need for future investment in
tyre reprocessing infrastructure in Victoria.
All major tyre reprocessing in Victoria
is located in metropolitan Melbourne.
Given the high level of investment
mechanical reprocessing of tyres
requires to create shred or crumb
rubber, it is likely that future investments
will continue to be in Melbourne. There have been several attempts at
regional reprocessing through pyrolysis
(thermal treatment), but so far none
have been successful. In fact, proposed
pyrolysis facilities have resulted in notable
stockpiles such as those at Stawell and
Numurkah, both of which have recently
been cleaned up by the EPA and
respective local governments, at
a cost to Victorian taxpayers.
Given the high level of
investment mechanical
reprocessing of tyres
requires to create
shred or crumb rubber,
it is likely that future
investments will continue
to be in Melbourne.
59
What we found Infrastructure Victoria


E-waste covers a wide range of
electronic items – anything with a
battery or a plug – including televisions,
computers, mobile phones, kitchen
appliances and whitegoods. These items
can contain both valuable and
hazardous materials. E-waste is forecast
to increase from 83,400 tonnes in 2018
to more than 106,500 tonnes in 2039.36
In 2018, the overall resource recovery
rate for e-waste in Victoria was 79%.
Since then, an e-waste landfill ban was
introduced in July 2019. As a result, we
expect a drop in reported e-waste disposal
to landfill. As e-waste is such a broad
category it is important to note that
approximately one third of e-waste in
Victoria is made up of large household
appliances, i.e. whitegoods that are
predominantly metals.
These materials are largely managed
by metals recyclers, not dedicated
e-waste recyclers. As Figure 18 shows,
based on the best available data, there
is enough reprocessing capacity to
manage e-waste containing hazardous
materials in the short-term, with a small
shortfall from 2030 onward.
However, waste projections suggest
increasing tonnages of hazardous items
that are yet to reach their end of useful
life, such as solar photovoltaic panels
(PVs), entering the waste stream in future.E-waste
Figure 17: E-waste is projected to grow
Figure 18: E-waste processing shortfall is expected by 2030Source: Brock Baker Environmental Consulting
36   Brock Baker Environmental Consulting (2020) Waste
and Resource Recovery Infrastructure Data and Spatial
Analysis, report for Infrastructure Victoria80,000120,000
100,000
60,000
0Tonnes
2018 2022 2025 2039 203040,000
20,000
Priority material2025 (COAG ban and
70% recovery rate)2030 (80%
recovery rate)2039 (90%
recovery rate)
Generation  63,400  67,100  73,200
Current processing
infrastructure capacity 49,400  49,400  49,400
Projected recovery required
to meet policy settings 44,400  53,700  58,500
Excess or shortfall
in capacity  5,000 -4,300 -9,100
Source: Brock Baker Environmental Consulting (2020) Waste and Resource Recovery Infrastructure
Data and Spatial Analysis, report for Infrastructure Victoria, and Infrastructure Victoria analysis60
Advice on recycling and resource recovery Infrastructure Victoria


E-waste: The waste of the future, today
Future e-waste is likely to look
very different from current forecasts
due largely to two technologies –
one existing and one emerging –
solar PVs and electric vehicles.
Currently, low volumes of PV system
components enter Australia’s waste
stream, with minimal impact. However,
solar PVs are an emerging e-waste
stream. Industry and government are
concerned that there will be insufficient
options to safely dispose of end-of-life
PV system components across
Australia, as well as a lack of
established reprocessors and recyclers
capable of recovering valuable and
hazardous resources.
As PV equipment reaches the
end of its useful life span, the level
of recovery, recycling, re-use and
safe disposal becomes important
to the environmental benefits of  PVs. End-of-life management is also
important to protect the environment
and human health from the uncontrolled
release of hazardous materials.
PV panels and system components
have an estimated average life span
of approximately 25 years and are
expected to enter Australia’s waste
stream in significant volumes from
around 2023, due to the recent boom
in solar installations since 2010. In
Victoria alone, it is estimated that by
2035 there will be 22,000 tonnes
of PV panel waste requiring disposal.
In addition, automated and zero
emissions vehicles are emerging
technologies that could also produce
significant volumes of e-waste.
In our Advice on automated and
zero emissions vehicles infrastructure,
we found that if the entire vehicle fleet transitioned to battery electric vehicles,
the volume of lithium battery waste and
other e-waste generated would exceed
current projections and infrastructure
plans. We recommended the Victorian
Government make changes to the
Statewide Waste and Resource
Recovery Infrastructure Plan to
incorporate the impacts of automated
and zero emissions vehicles.
Without proper planning, e-waste
could greatly exceed the capacity
of waste infrastructure, leading to
increased illegal dumping, stockpiling
or illegal exporting – issues that are
already a concern for e-waste.
Finally, there is also the potential
to develop local industry to handle
and reprocess e-waste in a more
economically and environmentally
viable manner.
61
What we found Infrastructure Victoria


Residual waste is material that is unable to be recovered for alternative
uses or has otherwise reached its end-of-life. Currently almost all residual
material is disposed to landfill.
Disposal is the least preferable outcome
on the waste hierarchy, as all remaining
value of these materials is lost. There will
always be a role for landfill in broader
waste management systems and it plays
a particularly important role in contingency
planning (as shown in the last 18 months).
However, there is an alternative to landfill
for some residual materials that allows for
some of the energy embedded in these
materials to be recovered through
waste-to-energy processes.
There are a number of residual waste-to-
energy infrastructure projects currently
proposed for Victoria. These have the
potential to further reduce Victoria’s
reliance on landfill when combined
with waste avoidance and improved
resource recovery.
If Victoria continues its current, business-
as-usual trajectory, the amount of
residual waste going to landfill is
projected to increase from 4.4 million
tonnes in 2017/18 to 5.7 million tonnes
in 2037/38.37 Alongside developing
waste-to-energy projects, Australian and
Victorian Governments could reduce this
by taking steps to reduce the amount of
materials going to landfill. This could
include banning organic material from
landfill or mandating the use of re-usable,
recyclable or compostable packaging.The amount of residual waste in the
future is highly uncertain. We estimate
that the combined impact of the two
policy interventions above could reduce
the amount of material going to landfill
in 2038/39 by around 700,000 tonnes
each year, with a projected 5 million
tonnes of residual material going to
landfill. Our analysis suggests that by
2038/39, Victoria will generate 650,000
tonnes per year of residual waste from
the six priority materials alone, assuming
a 90% recovery rate. Not all of this
residual waste will be suitable for
waste-to-energy.
The need for waste-to-energy to manage
residual waste will be highly dependent
on efforts to reduce waste and recycle
materials, as well as the planned landfill
capacity. The Recycling Victoria policy’s
stated capacity cap of one million tonnes
per year for waste-to-energy should be
regularly reviewed to manage these
uncertainties. If combined efforts to
reduce waste generation and recycle
material are not highly successful then
there is a risk that significant amounts
of residual waste will remain above the
one million tonne waste-to-energy cap
and be consigned to landfill.Residual waste
37  Blue Environment (2019) Victorian Waste flows projections, report for Infrastructure Victoria
62
Advice on recycling and resource recovery Infrastructure Victoria


Landfills, waste-to-energy, and the circular economy
Using materials for as long as
possible is key to a circular
economy. When those materials
no longer have a useful role to play,
it is often still possible to extract
energy as an alternative to disposal.
The waste hierarchy shows that
recovery of energy is better than
disposal or containment of waste,
because this recovers some value,
reduces greenhouse gas emissions
from organic waste and lessens the
long-term environmental impacts
of landfills.
As a result, waste-to-energy is a
pragmatic approach to managing
residual waste, but is less desirable
than waste reduction, re-use and
recycling. There are some risks
associated with waste-to-energy
infrastructure while also transitioning
to a circular economy.
Waste avoidance and increased recycling
and resource recovery can reduce the
amount of feedstock for waste-to-energy
infrastructure, particularly thermal
waste-to-energy plants. Conversely,
over-investment in waste-to-energy
infrastructure could discourage transition
to a circular economy. The two most common forms of
waste-to-energy technologies are
thermal and biological. Thermal
technologies use heat to release
energy from waste, for example
through incineration and capture
of energy. Biological processes use
microorganisms that feed on organic
waste to produce heat, energy,
biogas and ‘digestate’. The most
common biological process is
anaerobic digestion.
Both biological and thermal waste-to-
energy facilities could stop some residual
waste going to landfill – particularly
organic material – and recover some
energy from the material. The solid
residues that remain could be further
reused and recycled. For example,
digestate from anaerobic digestion
processes could be transformed into
soil conditioner, while some of the
bottom ash from thermal processes
could be used in construction.
Landfills will remain part of Victoria’s
waste management system.
Landfills can assist in residual
waste management and sector
contingency planning. They may
also be the best option in regional
areas where there is not enough
waste to support an economically
viable waste-to-energy facility.  Further, there are some materials for
which containment or landfill is
the safest and best option.
However, Victoria’s reliance on landfill
is expected to decline in the long term
as new and better ways to avoid waste
and recover materials for reuse are
developed. Waste-to-energy can
support this by creating ways to
reduce the need for new landfills and
keeping existing airspace capacity
for unrecoverable materials into the
future. This aligns with Victorian
Government’s planning documents,
such as the SWRRIP , which aims to
minimise the amount of waste going
to landfill.
The Metropolitan Waste and Resource
Recovery Implementation Plan, for
example, does not plan for new
landfills in the metropolitan area.
Victoria’s circular economy policy –
Recycling Victoria: A new economy –
limits the amount of material that can
be processed at thermal waste-to-
energy facilities in Victoria. Limiting
the amount of material that can be
accepted by these facilities may
mean that material that could viably
be used for recovery of energy will
instead go to landfill.
63
What we found Infrastructure Victoria


If potentially recoverable resources
are not recovered, this is a missed
economic opportunity.
Figure 19 shows that based on the amount
of waste recovered in Victoria and current
commodity prices, the value of materials is
$1.21 billion. Metals makes up the largest
share, worth $889 million, or 73% of the
market. Paper and cardboard and masonry
have the next largest market shares, at 8%
and 7%, respectively. However, the value of
a number of materials (such as plastics and
paper) has fallen significantly since the
collapse of export markets. We have found that prices for some
recovered materials are higher in South
Australia. For example, glass prices
are higher due to the cleaner stream
of glass recovered from CDS. This
shows that there is potential for Victoria
to increase the value of its recovered
resources from improved resource
recovery.
To estimate the potential increase in
market value from higher commodity
values, we applied South Australian
commodity prices to the amount of
resources recovered in Victoria and found
that they would be worth up to $2 billion.  More resources,
less waste
Figure 19: Estimated value of recovered materials in 2019 –
Victorian prices / South Australian prices*
Source: Blue Environment (2019) and Infrastructure Victoria analysis
*Based on December 2019 commodity prices in Victoria and 2016/17 commodity prices in South Australia1.52.5
2.0
1.0
0.0Commodity values ($ Billions)
2019 VIC  prices 2019 SA  prices0.5
E-Waste
Glass
Masonry
Metals
Organics
Other wastes
Paper and cardboard
Plastics
Rubber
64
Advice on recycling and resource recovery Infrastructure Victoria


Increasing the amount of value
generated by the sector is also likely to
lead to more jobs. Resource recovery
activities are higher-value and more
productive than disposal, creating new
opportunities for employment and
industry growth. Victoria will be well-
placed to realise these opportunities,
but it will require ongoing evaluation
of infrastructure and policy settings.
Evidence suggests that for every 10,000
tonnes of waste recycled, 9.2 jobs are
generated compared to 2.8 jobs for
landfill.38 Using this approach, we estimate
the number of jobs in the sector could grow
to around 13,200 by 2039 if the current
recovery rate of 69% is maintained.
However, if Victoria increased its recovery
rate to 90%, the number of people working
in the sector could grow to over 15,600
by 2039 (Figure 20), an additional 2,400
jobs more than ‘business-as-usual’ and
over 5,000 more than today. Recycling can create more jobs than disposal
Figure 20: The Victorian recycling industry has the potential to
generate up to 5,000 new jobs by 2039
Source: Infrastructure Victoria Analysis, Access Economics, Blue Environment17,000
16,000
15,000
14,000
13,000
12,000
11,000
10,000
9,000
8,000Estimated number of recycling jobs in Victoria
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
203015,639
13,184
10,61912,597
38   Access Economics (2009) Employment in waste management and recycling,
report for the Department of the Environment, Water, Heritage and the ArtsResource recovery and recycling are higher value
and more productive than disposal, creating new
opportunities for employment and industry growth.
What we found Infrastructure Victoria
65


Figure 21: Reprocessing infrastructure is highly concentrated around Melbourne
< 5
5 to 10
10 to 25
25 to 50
50 to 100
100 to 250
250 to 500
500 to 1000
1000 to 2500
2500 to 5000
5000+Population/Sq Km
MORWELLMANSFIELD
GEELONG
PORTLAND
WARRNAMBOOLWANGARATTA
BENDIGO
BALLARAT•BENALLA
•HORSHAM
• HAMILTON
• MOUNT GAMBIER• ARARATSHEPPARTON
BAIRNSDALEMELBOURNEMELTON •
• CAMPERDOWNPAKENHAMMILDURA
SUNBURYRecovery Infrastructure Capability
Baling
Manual separation and sorting
Mechanical separation and sorting
Other
Shredding
Stillages / skip bins / cages
Processing Infrastructure Capability
Anaerobic Digestion
Blast furnace
Compaction
Composting
Crushing / grinding / washing
Extrusion/injection moulding
Flaking
Granulating / crumbing
Hazardous processing
Other
Paper and pulp
Shredding
Unknown
Infrastructure Status

Recovery Infrastructure
Processing Infrastructure
Inset: Metro Melbourne
ECHUCAWODONGASWAN HILL0 50 100 150
kilometres
66Infrastructure Victoria Advice on recycling and resource recovery


Infrastructure is unevenly spread
39   Brock Baker Environmental Consulting (2020) Waste and
Resource Recovery Infrastructure Data and Spatial Analysis,
report for Infrastructure VictoriaIn identifying challenges and
opportunities for Victoria’s regional
and rural areas we sought feedback
from stakeholders from local regional
councils and industry.
Our consultation identified high
transportation costs as a barrier
to improving recycling and resource
recovery. In many cases, it is more
economical to use landfill. Several
submissions identified a need for more
recovery infrastructure in regional areas.
Our analysis shows there are some
inconsistencies in infrastructure provision
across the state. As Figure 21 shows,
the majority of processing infrastructure –
marked in red – is clustered around
metropolitan Melbourne, while recovery
infrastructure – marked in blue – is spread
more evenly across the state.
Many of the recovery infrastructure sites
marked in blue are small, local resource
recovery centres. These often serve as
points of aggregation for materials, with
limited actual recovery occurring. Materials
will often be transported to another facility
for processing. Figure 21 also shows
that there is a specific need for MRF
infrastructure in the Grampians Central
West and Barwon South West WRRG
regions, as both these regions lack any
mechanical separation and sorting
infrastructure.39
This means material generated in regional
areas often flows to the metropolitan area
for processing. Some materials are easier to
process in the metropolitan area. Due to the
amount of material generated in Melbourne,
metropolitan facilities tend to be bigger
than regional ones. With size often comes
efficiency, meaning it is cheaper and more
efficient to transport some materials to the
metropolitan area for processing. Figure 22: Most processing occurs in Melbourne; except for organics
E-waste
GlassOrganics
Paper &
cardboardPlastics TyresMelbourne generation
Melbourne processing
Overseas processingRegional generation
KeyRegional and
interstate processingOn the other hand, some materials
require more space for processing,
such as organics.
Figure 22 illustrates the flow of materials
in Victoria, with each arrow representing
a different material type, and the thickness of each arrow representing the volume of
the material. It shows, for example, that
more organic material flows to regional
areas for processing than is processed
in the metropolitan area, and that all glass
generated in regional areas is processed
in Melbourne.
What we found Infrastructure Victoria
67


Moving materials is not necessarily a
bad thing, depending on the material.
High-volume or heavy materials such as
masonry and aggregates, or glass, cost
more to transport due to their weight.
Organic materials may not necessarily
be more expensive to transport, but
often don’t have as much value as a
reprocessed material such as compost,
making them less economical to transport.
In these instances, investment in regional
recovery and processing facilities could
lower transport costs, improve recovery
rates and support end markets for these
materials. Local recovery and reprocessing
can create jobs in regional areas.
Regional and rural areas are more likely
to have nearby markets for reprocessed
organic products, such as soil conditioner
and compost, and facilities to process
these materials due to the space available
for buffer zones. However, this needs to
be weighed against cost of transport and
the ability to aggregate enough waste
for a viable market. Overall, transporting waste is not
necessarily problematic, as long as it is
optimised. As the private sector is largely
responsible for providing this infrastructure,
the geographic spread of facilities is
not optimised to reduce transport costs.
Minimising transport costs will be important
in improving recycling and resource
recovery rates by helping recovered
materials become cost competitive with
virgin materials. Currently there are dozens
of resource recovery centres across
Victoria, of varying capacity and capability,
that aggregate materials from their local
areas for transport and further recovery.
Rationalising our resource recovery
centre network and focusing on fewer
centres that are more strategically
located and better resourced could
reduce the costs of transporting materials.
This could encourage more aggregation
of materials, resulting in fewer trips
and better economies of scale in
waste transport. To identify potential locations for
new recycling and resource recovery
infrastructure, we considered current
and predicted waste generation and
reprocessing capacity by material
type, proximity to end markets, existing
resource recovery hubs of statewide
significance, the statewide and regional
resource recovery infrastructure plans
and stated government priorities to
support regional economies in transition
(for example, the Latrobe Valley).
Using this methodology, we are proposing
87 new or upgraded facilities, many of
which are in regional areas. Shown in
Figure 23, these facilities can address
identified infrastructure gaps, minimise
transport costs, capitalise on existing
resource recovery and recycling hubs
and maximise the likely economic viability
of facilities.Waste
transportFuture infrastructure
provision
Transporting waste is not necessarily problematic, if it is optimised.
As recovery and recycling infrastructure is largely provided by
the private sector, the geographic spread of infrastructure is not
optimised to reduce transport costs to households and businesses.
68
Advice on recycling and resource recovery Infrastructure Victoria


Figure 23: Indicative location of required recovery and reprocessing infrastructure
< 5
5 to 10
10 to 25
25 to 50
50 to 100
100 to 250
250 to 500
500 to 1000
1000 to 2500
2500 to 5000
5000+Population/Sq Km
MORWELLMANSFIELD
GEELONG
PORTLAND
WARRNAMBOOLECHUCAWODONGA
WANGARATTA
BENDIGO
BALLARAT•BENALLA
•HORSHAM
• HAMILTON
• MOUNT GAMBIER• ARARATSHEPPARTON
BAIRNSDALEMELBOURNEMELTON •
• CAMPERDOWNPAKENHAMSWAN HILLMILDURA
SUNBURYMaterial type

E-waste
Glass
Mixed
Organics
Paper
Plastics
Tyres
Infrastructure Status

Existing
Required
Inset: Metro Melbourne0 50 100 150
kilometres
69
What we found Infrastructure Victoria


Not investing
can be expensive
A number of the recommendations
we make may require spending by the
Victorian Government, both in upfront
capital expenditure and also ongoing
operational expenditure. When the
Victorian Government decides whether
to make particular investments it helps
to consider both the cost of investment
and the potential costs to Victoria if
no investment occurs.
We have already seen what can occur
with a weakened market for recyclables
and without sufficient infrastructure to
process recycling. VAGO noted in its 2019
report that without clear state-level plans
for how to manage recyclables in this new
environment, stockpiles will likely continue
to grow and pose unnecessary risks, and
waste to landfills will continue to rise.40
We have broken down the potential
costs to Victoria of not increasing
recycling and resource recovery into
four categories, representing other
(often unplanned) investments and
foregone revenue from poor recycling
and resource recovery outcomes. These are:
\ Emergency and incident response costs
\ Enforcement and regulatory costs
\ Environmental impact and
restoration costs
\ Economic impact and
business disruption
Emergency and incident
response costs
Waste material mismanagement has
seen an increase in stockpile fires, waste
abandonment and illegal dumping. These
can all be costly. Based on events of the
past few years, the EPA estimates that it
costs Victoria around $193 million per year
to respond to avoidable waste management
issues. This estimate is made up of $105
million per year to respond to waste
stockpile fires, $58 million per year in annual
clean-up costs of abandoned waste sites,
and $30 million per year in clean-up costs
and lost landfill levy revenue from illegal
dumping.41 As an example, the Victorian Government recently invested $30 million
to clean up a stockpile in Lara where the
operator has gone into liquidation, which
is a job that may take several years.
Stockpile fires also incur significant costs for
other agencies. The Ecotec Somerton fire in
2015 cost the CFA alone $2.3 million to
respond to. Further costs for other agencies
responding to that fire included $242,000
for VicRoads’ emergency response,
$295,145 for Melbourne Water impact
management costs, $30,000 for Hume
City Council, and $1 million for DELWP .42
Enforcement and regulatory costs
As well as the costs of responding to
specific incidents, there are also ongoing
enforcement and regulatory costs, which
can increase over time if the scale and
frequency of poor waste management
practices increase when issues arise in
the sector. The 2019/20 Victorian Budget
allowed for $204.3 million in statutory
activities and environment protection
from DELWP .43
70
Advice on recycling and resource recovery Infrastructure Victoria


Environmental impact
and restoration costs
Waste stockpile fires cause immediate and
long-term environmental damage to the site
and surrounding areas. For the 2017
Coolaroo fire alone, DELWP has estimated
that approximately $6 million was spent on
the management and clean-up of the site.
This amount does not include the ongoing
management costs and clean-up costs
borne by several agencies, particularly the
EPA but also Melbourne Water, Yarra Valley
Water and Hume City Council.44 Economic impact
and business disruption
When dangerous incidents happen, the
costs to the state can go beyond the cost
of the immediate response. There can also
be an economic impact on surrounding
communities if businesses are disrupted.
The impact on the local community and
businesses of the 2017 Coolaroo fire was
quantified in a recent class action, where
over 200 residents of Coolaroo succeeded
in a claim against the operator of the
Coolaroo site, who was ordered to pay
$1.2 million.45 DELWP separately estimated
that the cost of this fire in business
disruptions alone amounted to $200,000.46
40   Victorian Auditor-General’s Office (2019), Recovering
and Reprocessing Resources from Waste
41   Deloitte (2019) Regulatory Impact Statement: Proposed
environment protection regulations, report for the
Department of Environment, Land, Water and Planning
and the Environment Protection Authority
42   Department of Environment, Land, Water and Planning
(2018) Management and storage of combustible recyclable
and waste material, Policy Impact Assessment
43   Department of Treasury and Finance (2019) Victorian
Budget 19/20 – Budget Paper No. 344   Department of Environment, Land, Water and Planning
(2018) Management and storage of combustible recyclable
and waste material, Policy Impact Assessment
45   7 News (2019) Class action win for residents affected by
Coolaroo recycling plant fire. Available at https://7news.
com.au/news/court-justice/class-action-win-for-residents-
affected-by-coolaroo-recycling-plant-fire-c-378097,
accessed on 7 October 2019
46   Department of Environment, Land, Water and Planning
(2018) Management and storage of combustible recyclable
and waste material, Policy Impact Assessment
Without clear state-level plans to manage
recyclables in this new environment,
materials will likely go to stockpiles, which
pose unnecessary risks, or to landfill.
71What we found Infrastructure Victoria


Supplements to
infrastructure investment
The Victorian Government can
work with other governments and
stakeholders to reduce the amount
of material coming into the recycling
and resource recovery system. There
are multiple approaches the Victorian
Government can take to either reduce
the amount of material entering the
system or increase recyclability
of materials.
Product stewardship
Product stewardship, or extended
producer responsibility (EPR), is the shared
responsibility of manufacturers, retailers
and consumers to manage the full lifecycle
impacts of products.
Product stewardship schemes aim to
ensure that everyone involved in making
and using a product shares the burden
of what happens to it. This addresses
one of the market failures associated
with waste, in which neither businesses
who create the products that lead to waste
or households who consume and dispose
of products as waste are exposed to
the costs of managing those materials
once they have been disposed of.
If businesses and households are
exposed to those costs, they are more
likely to minimise waste and improve
how it is disposed of. In addition, making
producers responsible for the disposal of
products may encourage them to make
products easier to re-use or recycle.The Australian Government has
established a framework for product
stewardship through the Product
Stewardship Act 2011 , a commitment
originally made in the 2009 National
Waste Policy.
The National Waste Policy was updated in
2018, encouraging the design of products
made to last, the use of recoverable
materials and minimising waste. The
legislation allows for mandatory, voluntary,
or co-regulatory schemes. In the eight
years since this Act was introduced, no
mandatory schemes have been established.
Instead, existing product stewardship
schemes tend to be voluntary, industry-led
schemes, such as those in place for tyres,
packaging products and mobile phones.47
Product stewardship in Victoria is even
less formalised and lacks legislation.
However, Sustainability Victoria has
undertaken product stewardship
partnerships for computers, batteries,
paint and compact fluorescent lights.48
Like the Australian Government’s approach,
none of these schemes are mandatory and
were effectively delivered as pilot programs.
We looked at approaches to product
stewardship around the world and found
that national, mandatory schemes are
most effective. Mandatory schemes
tend to be easier to enforce. Mandatory
schemes also enable government to apply
more stringent product standards. For
example, under a mandatory scheme,  47   Parliament of Victoria Legislative Council Environment and
Planning Committee (2019) Inquiry into recycling and waste
management – final report
48  ibid.
49   AlphaBeta (2019) Recycling and resource recovery
infrastructure in Victoria: International and Australian
comparisons, report for Infrastructure Victoriathe government could introduce product
standards to exclude materials from the
system that are hard to recycle. Countries
that perform well, such as the Netherlands,
Germany and Switzerland have mandatory
schemes that focus on problematic
materials, like electrical equipment
and packaging.49
Around the world,
mandatory product
stewardship schemes
are the most effective.
72
Advice on recycling and resource recovery Infrastructure Victoria


Container Deposit Scheme in Victoria
A common example of a product
stewardship scheme is a container
deposit scheme (CDS).
A CDS allows consumers to take
containers to collection points
(sometimes in the form of a reverse
vending machine) and deposit them
in exchange for a refund. CDSs have
operated in Australia for some time.
South Australia has had a scheme
since 1977 and, over time, other
Australian jurisdictions have followed
suit. Victoria has recently announced
an intention to implement one
by 2022/23.
One of the key benefits of CDSs is
that they can reduce contamination.
This is because the different materials
are separated at the source and are
not commingled – particularly glass
and plastics.
Cleaner material streams can
increase their potential for re-use.
A CDS can improve the chances
that glass containers will be
remanufactured into new bottles.
With plastics, a CDS allows for
separation and remanufacturing
of food-grade plastics – a product
with a strong end market. The introduction of a CDS was
commonly identified by stakeholders
who provided feedback on our
Evidence Base Report as an initiative
that could improve Victoria’s waste and
resource recovery system. We heard
from businesses, local councils and
individuals who advocated for the
introduction of a CDS in Victoria.
We separately undertook polling
of Victorians on a range of issues,
including a CDS. In total, 92% of
people we polled favoured the
introduction of a CDS.
The Victorian Parliamentary Budget
Office (PBO) recently costed a CDS
for the Victorian Parliamentary Inquiry
into recycling and waste management.
The PBO costed a model where the
cost of the scheme is borne by drinks
suppliers and the refund for each
container was fixed at 10 cents.
The PBO found that a CDS would
provide Victoria with $244.5 million
from 2019-20 to 2022-23. This is a
$253.5 million increase in government
revenue due to uncollected deposits
from containers not being returned,
partially offset by an increase in
operating expenses of $9 million
to manage the scheme. Along with financial benefits,
a CDS can:
\ act as an ‘anchor’ in a broader
network of recycling infrastructure
\ reduce litter
\ improve community engagement
in recycling as consumers benefit
when they return containers
\ increase the value of recovered
material while reducing collection,
transport, processing and
landfill costs
\ create employment
\ increase resource recovery.
A CDS has merit in Victoria as part
of a suite of reforms to collection and
processing to secure cleaner materials
streams and improve resource recovery
rates. This has been recognised in
the Recycling Victoria policy, which
commits to the introduction of a CDS.
Further work is needed to identify the
best CDS model for Victoria, but we
consider the approaches taken in
Western Australia and Queensland
to be good examples. In the longer
term, a nationally consistent approach
to CDS should be considered.
73
What we found Infrastructure Victoria


Financial incentives
Businesses that manufacture products that
are later disposed of by households do not
often face the cost of disposal. In the
absence of costs that would change their
behaviour, this can lead to excessive and
unnecessary waste. This market failure can
be addressed by putting a price on waste
through taxes or levies on virgin materials
to encourage greater use of recycled
content, or on specific products to
disincentivise their production altogether.
The UK Government recently implemented
a plastic packaging tax on the production
and import of non-recyclable plastic
packaging that will come into effect in
2022. This will incentivise the use of
more recycled plastics and reduce plastic
waste. The tax was a response to high
levels of plastic packaging waste, which
predominantly came from new plastics.50
It is difficult for the Victorian Government
to unilaterally impose a similar tax, mostly
because Victoria is just one part of a larger
market and products can flow across state
borders relatively easily, limiting the impact
of a state-based tax. However, the Victorian
Government can work with the Australian
Government to investigate the potential
costs and benefits of taxes or levies on
specific materials, such as plastics or
virgin materials.Product bans
The most definitive legislative tool the
Victorian Government could use to reduce
residual waste is a ban on certain materials.
Single-use plastics, such as plastic bags,
straws and disposable food packaging, are
commonly identified due to their high profile
in discussions around waste and the
visibility of their environmental impact.
In November 2019, the Victorian
Government banned the provision
of single-use plastic bags through
amendments to the Environment Protection
Act 1970, with penalties for businesses.
A similar approach could be used for other
materials. For example, the European
Union issued a directive in June 2019
on the impact of certain plastic products
on the environment. This included a ban
on single-use plastic products such as
cotton bud sticks, cutlery, plates, straws,
beverage stirrers, balloon sticks, and
polystyrene food and beverage containers.
The Member States have until 2021 to
transpose these bans into national law.
The Victorian Parliamentary Inquiry into
recycling and waste management identified
difficulties with this approach. Certain
industries rely on single use plastics
for medical or research purposes.
Although this problem could be addressed
through exemptions or other ban
50   AlphaBeta (2019) Recycling and resource recovery
infrastructure in Victoria: International and Australian
comparisons, report for Infrastructure Victoria51   Parliament of Victoria Legislative Council Environment and
Planning Committee (2019) Inquiry into recycling and waste
management – final reportdesign considerations, it could be highly
problematic to impose a ban on some
items.51 There are alternatives to banning
specific materials without creating
unintended difficulties, such as product
stewardship schemes or minimum
recycled content requirements.
In November 2019, the
Victorian Government
banned the provision of
single-use plastic bags
through amendments to
the Environment Protection
Act 1970, with penalties
for businesses. A similar
approach could be used
for other materials.
74
Advice on recycling and resource recovery Infrastructure Victoria


52   Centre for Market Design (2019) Opportunities to improve
infrastructure investment in the Victorian waste economy,
report for Infrastructure Victoria53   Opportunities to improve infrastructure investment in the
Victorian waste economy, report for Infrastructure VictoriaMarket failures are stopping
the sector from performing
at its best
Several challenges make the Victorian
recycling and resource recovery sector
less efficient. In our Evidence Base
Report, we described the sector as a
decentralised system in which sorting,
collecting, processing, reusing and
disposing of waste is done by private
individuals or businesses. This means
it is difficult for government to achieve
public policy objectives because the
motivations of these businesses do
not necessarily align with the objectives
of the Victorian Government. Market
design approaches can help with this.52
At the same time, the market for recovery
and reprocessing services in Victoria is
dominated by a few large players. This is
especially true of MSW recovery. Victoria
relies on a relatively small number of MRF
operators – a problem known as ‘thin
markets’ – which makes the sector less
resilient and created problems if one player
exits the industry. Victoria’s approach to
procuring collection and recovery services
has, in part, contributed to this thin market
problem. It has led to consolidation in the
market as businesses bid for larger and
larger numbers of local government
contracts to achieve economies of scale. This has led to a significant power
imbalance between firms and the local
councils seeking to procure their services.53
Market dynamics can also impact on the
full utilisation of all infrastructure where it
may be to one player’s advantage to slow
throughput in certain circumstances.
These market failures contribute to
poor recycling and resource recovery
outcomes. In Victoria’s decentralised
waste management sector, where market
failures exist across the waste lifecycle,
single and centralised solutions are unlikely
to be effective. A combination of policies
is most likely to succeed in addressing
these failures.
75
What we found Infrastructure Victoria


MSW is made up of a wide range
of materials and is mostly generated
by households. Although a large
proportion of the waste generated
could be reused, processed or
recycled, only around 39% of
MSW was recovered in 2018 with
the remaining amount sent to landfill.54
There are a number of reasons MSW has
a lower recovery rate than C&I and C&D
streams. One of the biggest causes is the
diversity of the waste stream. Households
consume a varied range of products,
which flow through to the waste they
generate. In some cases, the materials
are not suitable for recovery, and rightly
become residual waste. However, audits
of landfill bins in Victoria have found that
a large proportion of material in these
bins could be recovered.55
Contamination of materials in recycling
bins also presents challenges for
processors and can have an impact on
their recyclability. These are both problems
that could be addressed by better source
separation and improved sorting.
Sorting is the first step in waste recovery.
Households (and businesses) need to
invest time and effort to separate residual
waste and segregate the remaining items
into relatively clean streams suitable for
recycling. Failures at this ‘front-end’ of
the system can reverberate through the
whole system. Contamination of one bin can flow through
the system and affect the recyclability of
a larger amount of material.
Countries that have high rates of resource
recovery from MSW tend to have a more
consistent approach to sorting and
collection. Currently, sorting and collection
differs across Victoria’s 79 local councils.
Not all councils accept the same materials
in recycling due to differences in what
some processors will accept. For
example, some councils have contracts
that allow them to separate soft plastics
for recycling, but others consider soft
plastics a contaminant. There are also
multiple approaches to organics
collection, including combining food
and garden organics – 19 councils allow
residents to put food scraps in their green
waste bin – and some councils
do not separate organics at all.
Added to these issues, bin lid colours and
meanings differ across local government
areas. As Figure 24 shows, nine councils
were fully compliant with the Australian
Standard for Mobile Waste Containers
as at December 2016. Sorting MSW
Victorians on their
best behaviour
Victorians feel strongly about recycling.
In June 2019, we undertook a
community survey to understand
Victorians’ views on recycling and their
willingness to change. 89% of people
we surveyed were open to changing
the way they sort and dispose of their
waste. A big reason for this is that
Victorians feel strongly about the
environment, and these feelings are a
strong driver of how they recycle.
However, the way household
collections currently work throws up
barriers to good recycling. Differences
in bins across councils and sporadic
and inconsistent messaging is leading
to uncertainty about what can and
cannot be recycled. This doubt can
lead people to put their recyclables in
their landfill bin, to be safe, or to throw
everything into their recycling bin to
let the system take care of it.
We also ran focus groups to
understand what would work for
Victorians, and identified three critical
factors that would support improved
sorting practice:
54  Blue Environment (2019) Victorian Waste Flows,
report for Infrastructure Victoria
55   Sustainability Victoria (2014) Victorian
Statewide Garbage Bin Audit 2013
76
Advice on recycling and resource recovery Infrastructure Victoria


Colours of garbage bin lids Colours of organics bin lids Colours of recycling bin lids \ Frictionless – simple to use and
understand
\ Clear environmental benefits –
a compelling reason, such as
reducing material going to landfill
\ Consistently functional – the right bin
capacity and collections approach
These findings are promising about the
potential success of future efforts by the
Victorian Government to affect change in
households’ behaviour and provide an
insight of what needs to be done. We
know that Victorians want to recycle, and
are open to ways to do it better, so they
do not need much convincing to change.
What they do need, and what the
Victorian Government can provide,
is the means to do it (easy-to-use,
more consistent infrastructure at home),
information on how to do it (clear and
consistent messaging, with local nuance
if needed), and confidence that their
efforts are not wasted. Figure 24: Bin lid colours
are inconsistent across Melbourne
Overall:
\ 9 councils are fully compliant
with bin lid colour
\ 12 councils are compliant with
recycling and organics bin lid
colours
\ 1 council has compliant garbage
and recycling bin lids
\ 9 councils have systems
that do not complyColours of garbage bin lids Colours of organics bin lids Colours of recycling bin lids
Colours of garbage bin lids Colours of organics bin lids Colours of recycling bin lids
Source: Sustainability Victoria (2019): Victorian Local Government Annual Waste Services Report 2017-18
77What we found Infrastructure Victoria