Developed through the work of CHP Australia’s Sustainability Subcommittee together with Gadens, Sustainability Obligations for Consumer Healthcare Products provides members with an overview of the current and emerging legislative and regulatory obligations related to sustainability in the consumer healthcare sector in Australia. It is designed support members in the navigating complex policy environment and support internal planning, risk management and compliance.
Sustainability is an increasingly prominent focus for industry, consumers and regulators. The landscape is evolving rapidly, with a clear shift toward more enforceable regulatory frameworks. There is an expectation that businesses take responsibility for the full lifecycle of their products from design and manufacture through to use and end-of-life management.
In developing this report, international developments, particularly in the European Union, provided a useful reference point for where policy may be heading. These include stricter requirements on recyclability, recycled content and lifecycle impacts.
Packaging is a central focus in Australia, with both legislation and industry frameworks continuing to evolve. Australia’s current framework, including the National Environment Protection (Used Packaging Materials) Measure 2011 and the Australian Packaging Covenant, places obligations on certain businesses defined as “Brand Owners” to improve packaging design, reduce environmental impacts and meet reporting requirements. While parts of this framework have operated on a co-regulatory basis, further reforms are expected to introduce more consistent national requirements, including extended producer responsibility schemes.
Australia did not meet the 2025 National Packaging Targets, so reform activity has accelerated. APCO’s 2030 Strategic Plan sets out a pathway toward improved packaging design, stronger data and reporting expectations, and new stewardship approaches, particularly for soft plastics.
State-based legislation, including extended producer responsibility settings in New South Wales, also points to a shift toward more enforceable obligations.
Obligations relating to emissions reporting and climate disclosure are also expanding. The National Greenhouse and Energy Reporting (NGER) Scheme and the Safeguard Mechanism apply to larger emitters, while amendments to the Corporations Act 2001 introduce phased mandatory climate-related financial disclosures. These developments are increasing expectations around transparency, governance and how businesses manage climate-related risks.
Regulatory and legal risks are also increasing. Businesses may be subject to enforcement action for non-compliance with environmental, product safety and consumer protection laws, including scrutiny of environmental claims. There is also a growing number of climate-related legal cases, reflecting closer attention on how companies manage and communicate environmental impacts.
Pharmaceutical waste management is another complex consideration. Requirements vary across jurisdictions and depend on the classification of substances, particularly for higher-risk scheduled medicines. Improper disposal can create both public health and environmental risks. Industry programs provide practical disposal options, but do not replace legal obligations.
This report can be used as a reference to:
Early awareness of sustainability obligations can support better preparation and more informed decision-making.
The full report is available here to CHP Australia members here. Please log in to access the download.