About the Consultation 

As part of Australia's transition to a circular economy, the Australian Government consulted on the development of a National Framework for Recycled Content Traceability. The initiative aimed to establish a coordinated approach for verifying and reporting recycled content across supply chains, enabling better sustainability claims, informed procurement, and alignment with emerging international standards such as the EU’s Digital Product Passport. 

Why is this important for GS1 members and Australian Industry? 

The ability to link recycled content data to existing product identifiers (like GTINs) can reduce compliance burden, streamline data sharing, and improve access to both domestic and export markets where sustainability claims and reporting obligations are tightening. It also aligns with broader digital transformation efforts that leverage supply chain visibility to build trust and transparency. 

The consultation sought stakeholder input on a staged approach to implementation, including the use of unique identifiers, product registries, and voluntary or mandatory requirements for traceability and verification. 

Key Documents & Links 

• DCCEEW Consultation Page
• Consultation Paper – Developing a National Framework (PDF) 

GS1 Australia Submission 

GS1 Australia strongly welcomed DCCEEW’s commitment to traceability as an enabler of a more circular and transparent packaging and materials economy. Our submission outlined several key enablers and cautions to guide implementation: 

✅ Build on existing global data standards – GS1 recommended leveraging open, globally accepted supply chain standards (e.g., GTIN, GLN, GPC) to ensure scalable traceability with minimal disruption. These standards are already embedded in thousands of Australian companies’ systems and are interoperable across jurisdictions and borders. 

✅ Use identifiers to link, not duplicate – Rather than building an entirely new registry or duplicative data entry systems, GS1 urged the government to enable traceability by linking unique product and location identifiers to sustainability and recycled content attributes. This keeps the system efficient and digitally mature from the outset. 

✅ Stage implementation and align internationally – GS1 proposed a phased approach focused first on voluntary uptake for high-priority sectors (e.g. packaging, construction materials), aligning with Europe’s Digital Product Passport and New Zealand's data traceability efforts. 

✅ Collaborate with technology and conformity bodies – The success of traceability requires more than data—it depends on consistent definitions, sector-specific guidance, and integration into certification systems. GS1 is committed to work with peak industry bodies including APCO, ACOR; technology partners and regulators to develop implementation toolkits. 

The submission concluded that traceability is a means to an end—empowering businesses and government to verify sustainability claims, comply with evolving global trade norms, and transition Australia’s economy towards lower waste, higher value circular models.

📄 Download GS1 Australia's Full Submission (PDF)