See below some guidelines to help you navigate this new policy.
You can also find:
- the policy itself HERE
- the webinar recording HERE
- the contamination table for lid bins HERE (to help staff identify the most common contamination issues)
- the FAQ HERE
- the form to request:
- new infrastructure for lids (bin/bags)
- voucher for the shop if you have purchased some “lids off” products recently
- recycling of A frame
- a review of your existing large-scale signage with the “lids off” messaging
- the feedback form
1. Introduction
A. Background
Since Western Australia’s Container Deposit Scheme began in October 2020, WARRRL has required Refund Point Operators remove lids from 10¢ containers before collection by logistics providers. Until now, loose lids brought in by customers, and lids removed from bottles during the counting process, were aggregated in bins or bags and kept ready for collection.
There have been major changes in the beverage and recycling industry since the start of the Scheme. In the European Union, a directive now mandates that caps on plastic beverage bottles (up to 3 liters) must remain attached to the bottle, a practice known as “tethered caps”. This regulation, in force since July 3, 2024, aims to reduce litter and improve recycling by ensuring both the bottle and cap are collected together.
While not yet mandatory in Australia, it is expected tethered caps will be introduced here in the next few years. Both beverage suppliers and recyclers have been preparing for the change and recyclers have upgraded their equipment to be able to process containers with caps left on.
B. Overview of the Policy
This new Lids Principal Policy overrides the initial contractual requirement for 10¢ container lids to be removed prior to, or during, the sorting process. From Tuesday 1 July 2025, Refund Point Operators must accept bottles with lids left on, if the bottle is empty.
Refund Point Operators must also still accept loose 10¢ container lids, collating them in bins or bags and ensuring there is no contamination (see 3b) before they are collected by logistics.
You can find the policy HERE.
C. Why is the Policy being implemented?
Customers and Network Partners are no longer required to remove lids from 10¢ containers before returning them through the Scheme.
This Policy is being implemented to align with evolving global recycling and beverage industry practices, and in response to feedback from Refund Point Operators.
This decision follows an assessment of operational considerations over the past five years, in consultation with our recycling and logistics partners. WARRRL has determined that leaving lids on 10¢ containers presents minimal risk to processing, while also improving access and convenience for customers.
Customers should continue to empty their 10¢ containers before returning them to prevent contamination.
2. Policy implementation and Compliance
A. Timeline
RPO Webinar: Wednesday 29 May, 2025
Launch of Policy: Tuesday 1 July 2025
Compliance Signed Declaration: 4 weeks from launch (Before Tuesday 29th July 2025)
May to August 31 2025: Online form available for RPOs to send feedback on the Policy implementation.
B. Proof of implementation & ongoing compliance
WARRRL will require RPOs to confirm they have taken the necessary steps to correctly implement the Policy. Examples of implementation may include, but are not limited to:
- Staff/volunteers training (know what containers can be accepted or not, safe procedures to handle containers that still have liquid inside);
- Induction update;
- Messaging updates at site(s), for example posters; and
- Infrastructure in place to collect loose lids from 10¢ containers and strategy to avoid contamination in infrastructure.
Compliance Declaration
The Compliance Declaration will be sent on Tuesday 1st of July by Assurance & Integrity via [email protected] to your organisation’s legal entity contact.
Note: If you are unsure who that person is for your organisation, please contact your Contract Manager.
The Compliance Declaration will be sent as an editable PDF document.
Compliance Declaration deadline
To confirm the policy has been implemented, Refund Point Operators are required to return the signed Compliance Declaration to WARRRL on or before Tuesday 12th of August 2025.
Compliance Declaration submission process
When returning the Compliance Declaration, Refund Point Operators must ensure it is:
- Signed once all necessary changes have been implemented by the final decision maker – for example, owner, chairperson, CEO (same process as for the Annual Stat Declaration); Signed by an authorised witness (see FAQs for more details);
- Sent to Assurance and Integrity at: [email protected]
The Compliance Declaration can be either signed electronically or printed and signed.
Ongoing compliance:
From Tuesday 1st of July 2025, the Lids Principal Policy will form part of the ongoing requirements that can be checked at any time by either WARRRL’s Network Delivery or Assurance and Integrity teams.
3. Expected impacts & change in operations
A. Safely dealing with non-empty/contaminated containers
As per the policy, caps from empty 10¢ containers will be able to be left on (from 1st of July 2025). Those containers can be counted and sorted directly into your collection infrastructure.
Non-empty 10¢ containers must be dealt with as follows:
- If it is safe to do so, remove the lid and empty the container. The lid can then either be screwed back on the bottle or added to the loose lids collection infrastructure.
- If it isn’t safe to do so, or you are unsure of the contents of the container, dispose of the container appropriately.
FAQ : How to safely accept and deal with containers.
- When is too much liquid in the bottle?
- Any liquid more than the very last remainder of contents is too much,and will need to be emptied out, if safe to do so.
- Can I remove liquid via other means (ie. slicing the bottle, piercing it)?
- No, this can cause extra hazards and may result in injury.
- How do I know if the contamination can be removed or not?
- Do not remove contents of closed 10¢ containers if the liquid is a different colour to the original contents, or if you’re unsure what it might be. For example, if it is thick, black, or contain solids. This should be determined by visual assessment only.
- Needles and other drug paraphernalia should not be touched or removed from the bottle.
- Any item or substance that does not look like the original liquid should not be removed.
- Anything that has a bad odour that is noticeable without opening the container.
- If the container is covered in any substance that isn’t the original liquid (ie faecal matter, slime).
- How do I dispose of the liquid removed from containers?
- As per your RPA requirements, you must correctly dispose of liquid waste. If you are unsure of how to dispose of liquid appropriately, you can contact your local council, find resources online or reach out to your Contract Manager.
B. Lids collection process
Loose lids from 10¢ containers will continue to be collected as normal by Refund Point Operators. Lids are to be aggregated in the provided bins (in Perth metro) or bags (in regions) and will continue to be collected by logistics providers.
There will be a renewed focus on avoiding contamination in loose lids bins and bags. Logistics providers will be asked to check loose lids bins/bags at the point of collection and have the right to refuse collection if the bins/bags are too contaminated.
C. Compaction model impact
More logistics movements may be required (Perth, Peel and Bunbury only) due to reduced compaction in the rear lift trucks or onsite (for sites with compactors) of 10¢ containers with lids. This is expected to be a minimal increase and any changes to your site’s collection frequency will be communicated appropriately.
Please review your traffic management plan to allow for pick-ups during opening hours. A reminder: any changes to your traffic management plans need to be communicated to WARRRL and the logistics providers for consultation and approval before implementation.
4. Contamination and Recycling outcomes
A. Contamination in lids collection infrastructure
It is important lids from 10¢ containers are collected with as little contamination as possible. Contamination greatly affects the recyclability of the lids and has been an ongoing challenge within the WA Container Deposit Scheme.
WARRRL is committed to providing recycling outcomes for lids of 10¢ containers, but that can only be achieved with uncontaminated lids. You can and should refuse lids brought in by a customer if they are:
- Contaminated (with leaves, dirt, pebbles etc)
- Not from 10¢ containers accepted under Scheme regulations
- Not loose (Ie. lids in a bag or a bottle)
- Not 10¢ container lids, for example:
- Batteries;
- Stubby holders;
- Smaller containers not accepted under Scheme regulations (Yakult, shot glasses);
- Other small plastic objects (laundry powder scoop, pegs);
- Paper (including thermal rolls from tills); or
- Vape canisters.
Contamination from counting tables can also be an issue. Avoid transferring lids to the loose lids bins/bags if there are contaminated by:
- Glass shards (most common);
- Polystyrene;
- Organics (leaves, dirt, pebbles); or
- Liquids.
A contamination table is available for staff training in the RPO portal.
Logistics providers will not pick up lids if they are visibly contaminated when presented for collection.
B. Strategies to avoid contamination
Don’t scrape sorting table content into the loose lids bins or bags;
- Use funnel, grates or smaller openings on your loose lids bins to stop customers dropping bagged lids and bigger lids/tops that aren’t accepted;
- If 10¢ container lids are presented in a bag by customer, ask customers to decant them into the lid bin and dispose of the bag themselves;
- Use signage to guide your customers;
- Train your staff so they can recognise contamination; and
- Make sure staff and customers do not use the loose lid bins and bags for general waste.
We recommend using a smaller loose lids bin in your customer area that can then be decanted into the 240L bin or bags. This way you can screen for contamination before aggregating the lids.
C. Recycling outcomes
As always, we are committed to having the best recycling outcomes possible for loose lids and tethered lids on 10¢ containers.
Loose lids and 10¢ containers with tethered lids will undertake different recycling processes. However, the outcome for both is similar with the material being cleaned, sorted, shredded and then melted to produce new recycled objects or pellets.
5. Communication at Refund Points
A. Refund Point Operator staff messaging
You can use the documents provided by WARRRL to assist with staff training such as the webinar recording, the FAQ and the contamination table for lids bins.
B. Customer messaging
There will not be a public announcement or advertisement that the “lids off” rule is no longer applicable. WARRRL has prepared reactive communications for customers who enquire about the new Policy.
Refund Point Operators are also not required to actively communicate the change to customers. However, it is no longer appropriate for Refund Point Operators to instruct customers to remove lids from 10¢ containers. If customers do have questions, please refer to the supplied FAQs. Customers can also be directed to the Containers for Change Help Desk (13 42 42 and [email protected]).
C. Marketing material
Please remove any of the below messaging at your Refund Point/s on or before Tuesday 1st of July 2025
Marketing Collateral |
Disposal options |
![]() |
Corflute A frame:
|
Poster:
|
|
![]() |
Stickers:
Unfortunately, stickers cannot be recycled and belong in the general waste bin.
|
If you have purchased any of the above material in the last 6 months, please fill out the form to request a shop voucher.
If you have existing large-scale signage at your refund point that includes the Lids Off messaging, please fill out the form (you will be asked for a photo of the signage) or speak to your Contract Manager about how WARRRL can assist you in updating this. WARRRL will provide signage support on a case-by-case basis.
6. Review/feedback on policy
As Scheme Coordinator, WARRRL wants to make this transition as smooth as possible for our refund point network. If you have any feedback or concerns about the policy, please contact your Contract Manager.
An online feedback form is also available.