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07. What we heard from stakeholders

Infrastructure Victoria is committed to consultation and creating recommendations through an open, evidence-based, transparent process.

The consultation program for this advice included two main phases. The first phase ran from April to August 2019. We met with more than 150 individuals and organisations from across the waste sector, business and government, all of whom provided valuable input and helped us refine the scope of our research and analysis. A report that summarises the outcomes of this phase is available at

Throughout our work, we also regularly consulted with a Sector Advisory Group which included people representing local government, the WRRGs, the waste management industry and broader industry.

We released our Evidence Base Report for consultation in October 2019. This report discussed the findings of technical research we commissioned in developing the evidence base. Consultation on the Evidence Base Report was open from 13 October 2019 to 13 December 2019.

In our Evidence Base Report, we posed seven questions for response:

  1. Have we identified the right outcomes for Victoria to aim for?
  2. Have we identified the most effective potential actions for government to take?
  3. Which, if any, of the initiatives implemented in Wales would you like to see applied in Victoria?
  4. What do you think of the market design opportunities proposed to improve waste sector outcomes and efficiency?
  5. Where do you think government should focus their efforts to increase recycling and resource recovery? (For example, through setting targets, promoting consistency or funding local councils?)
  6. Which materials or infrastructure types present the most opportunity in your region?
  7. What is a legislative barrier or enabler that you have encountered when trying to use recycled materials?

We received 53 submissions from individuals, organisations, business and local governments. The feedback we received helped us understand stakeholders’ priority issues and concerns and helped us refine our advice and recommendations.

There were several key themes that emerged in the feedback we received on the Evidence Base Report. A summary of the most common issues and how they relate to our final advice to the Victorian Government is below. Submissions are available in full at

The feedback we received from stakeholders has provided highly valuable insights that have informed our final advice. Infrastructure Victoria would like to thank everyone who contributed to this work.

Container Deposit Scheme (CDS)

The most commonly raised issue in the submissions we received was the desire for a CDS in Victoria. Victoria is the only jurisdiction in Australia that has not introduced or announced it is planning to introduce a CDS.

Reasons for introducing a CDS in Victoria ranged from the potential to reduce contamination of other materials streams in resource recovery to supporting stronger end markets for recycled glass and ensuring consistency across Australian jurisdictions. Some feedback we received suggested there should have been more consideration given to a CDS in our Evidence Base Report.

In this report, we included additional analysis of the costs and benefits of a CDS, including research and consultation undertaken by the Victorian Parliamentary Inquiry into Recycling and Waste Management. Our analysis of the evidence suggests that a CDS can improve outcomes in recycling and resource recovery as part of a broader suite of initiatives.

Product stewardship and extended producer responsibility

The concept of product stewardship schemes received support from many stakeholders, particularly for hard-to-recycle products like electronics or complex packaging. Our analysis supports this position.

We found that without well-designed product stewardship schemes there is little incentive for consumers or producers to consider the cost of waste. This is a market failure, suggesting there is a role for government to intervene. We also found that the most successful product stewardship schemes in high-performing jurisdictions around the world are compulsory. There are a number of product stewardship schemes in place across Australia, but none are compulsory.


The terms of reference for this advice asked Infrastructure Victoria for advice on the infrastructure required for, and the role for government in providing support to, a waste-to-energy sector that prioritises extracting recyclable material and recovers energy only from residual waste.

A number of stakeholders identified waste-to-energy as a preferable to landfill, which aligns with the waste hierarchy, but noted the importance of prioritising avoidance, re-use and recovery. Stakeholders also identified practical barriers to establishing waste-to-energy infrastructure in Victoria being the lack of policy clarity around waste-to-energy in Victoria, the lack of an end market for residual waste to energy by products, and the role of the landfill levy in influencing the competitiveness of waste-to-energy.

Landfill Levy

The Landfill Levy was identified as having potential for better use. Some stakeholders suggested that, at a minimum, the Victorian Government should consider making the Landfill Levy consistent with neighbouring states. Victoria has recently announced an increase to its levy and is leading efforts for national levy consistency under the National Waste Policy Action Plan.

This work can consider the potential for the Landfill Levy to be used to further support a transition toward a circular economy and alternatives to landfill, such as waste-to-energy. This view aligns with a point made by multiple stakeholders who highlighted the need to reinvest more of the Landfill Levy with a specific focus on infrastructure that supports a transition towards a circular economy.


Stakeholders commonly identified that the approach to kerbside collections is a barrier to improving resource recovery, particularly for MSW. We received feedback that improved source separation –  particularly separating paper and cardboard from other co-mingled recyclables –  and a more consistent approach to collections across councils, could increase recovery rates. We agree.

Our analysis suggests that greater source separation leads to cleaner streams, which can improve resource recovery rates. At the same time, a more consistent approach to kerbside collections makes it easier for households to separate their waste correctly and reduces contamination.

Market development

We heard that the Victorian Government has a role to play in supporting end markets for recycled materials. Without an end market for recycled materials, the design of collection and processing systems is irrelevant.

Government procurement can go some way to supporting an end market for these materials by buying them directly. The Government can also support their use in the broader economy by facilitating the development of standards and specifications for recycled products (such as compost, digestate from anaerobic digestion, bottom ash from thermal waste-to-energy, and plastics in construction or packaging applications).

Standards and certification can build consumer confidence in these products, supporting a market. Stakeholders commonly identified the lack of confidence in these products as a barrier.

Regional infrastructure

Regional stakeholders identified lack of access to recycling services and infrastructure as a barrier to resource recovery in regional areas. In some cases, geographic consolidation of infrastructure makes sense due to economies of scale.

In others, providing processing infrastructure in regional areas can reduce costs by eliminating or reducing transport costs, leading to improved recovery rates. Our analysis supports this, particularly with materials that are sensitive to transport costs and gate fees, such as organics. Regional infrastructure can also provide jobs in regional areas.

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