State-by-State CDS
Performance Audit
A comprehensive, evidence-based audit of all eight Australian Container Deposit Schemes — coordinator performance, strategic plans, target achievement, and the gaps that behavioural intervention can close.
8
Schemes audited
67%
National avg. return rate
1/8
At 85% target
18%
Gap to target (national)
Audit Methodology: This audit draws on each coordinator's published annual reports, strategic plans, government regulatory publications, parliamentary inquiry findings, and independent reviews (e.g. Boomerang Alliance). Data is presented in good faith and cross-referenced wherever possible. It is not intended as a critical assessment of coordinators — all are working within the constraints of their respective frameworks. The purpose is to identify where the system as a whole is falling short of legislated targets, and what additional intervention is needed.
National Performance at a Glance
~12.1B
Total eligible containers p.a.
Across all 8 jurisdictions
~$776.4M
Annual refund pool (current rates)
At current return rates
~2.52B
Containers needed to hit 85%
The scale of the behavioural gap
~$252.4M
Additional refund value to unlock
Currently unclaimed per year
All 8 Schemes — Ranked by Return Rate
Click any scheme to view the full audit report
Queensland Parliamentary Inquiry Findings:
Infrastructure Without Behaviour Change Has Limits.
In October 2025, Queensland's Parliament tabled a 200+ page report into its own container refund scheme. The inquiry findings highlight structural limitations in the current approach — limitations that the 10c Recycling Games is designed to address.
200+
Page report
Tabled 16 Oct 2025
21
Recommendations
17 supported by Govt
10
CCC referrals
Alleged misconduct
67.1%
Recovery rate FY25
vs. 85% legislated target
The Inquiry's Finding: Behaviour Change Mechanisms Were Not Included in Scheme Design
The Queensland Parliamentary Inquiry found that after 7 years of operation, with 11 billion containers returned, $2.5 billion in revenue generated, and 411 refund points deployed — the scheme remains 18 percentage points below its legislated target. The committee's 21 recommendations address governance, transparency, and accountability. The recommendations do not include behavioural engagement mechanisms such as gamification, community competition, or layered incentives. This represents an opportunity for complementary approaches like The 10c Recycling Games.
Key Findings — What the Inquiry Actually Said
85% Target: Unmet — Seven Years Running
The inquiry's primary finding: COEX has never once achieved the legislated 85% container recovery rate. Despite growing from 18% at launch (2018) to 67.1% (FY25), the scheme plateaued 18% below the statutory floor. The committee found the scheme's structure provided no enforceable mechanism to close this gap.
QLD Parliamentary Inquiry Report No. 14, October 2025 — Terms of Reference 2(a)
$2.5 Billion Generated — Less Than 40% Returned to Queenslanders
Since inception, the scheme generated $2.5 billion in revenue. Less than 40% was returned to Queenslanders via refunds. Less than 2% went to charities. The inquiry found that COEX held substantial retained earnings — and that these surpluses were being used by founding beverage industry members (Coca-Cola, Lion) to offset their own scheme contribution costs, 'effectively shifting value from Queenslanders to themselves.'
QLD Parliamentary Inquiry Report, p. 123–131; ABC News, 16 October 2025
Structural Conflicts of Interest: Beverage Industry Controls the Scheme It Should Be Motivated to Avoid
The committee found a fundamental structural conflict: beverage manufacturers have a financial incentive to keep the scheme's costs low — which means keeping container recovery rates lower. COEX's board was member-dominated by the very beverage companies who benefit from a lower recovery rate. The committee found 'fundamental conflicts of interest for beverage manufacturers' in setting the scheme price and in meeting the recovery rate target.
QLD Parliamentary Inquiry Report, Chapter 3 — Governance Practices, pp. 76–87
No Open Tender for Scheme Coordinator — 'Fused Model' Without Precedent
COEX was appointed as Queensland's sole scheme coordinator without a public tender process. The committee found Queensland adopted a novel 'fused' model — combining coordinator and network operator functions in one entity — that had no precedent in any other Australian jurisdiction. Greater probity at appointment, including waste and recycling expertise on the board, 'may have prevented many of the problems now evident.'
QLD Parliamentary Inquiry Report, Chapter 2 — Governance Framework, pp. 37–59
Bullying, Harassment & Intimidation: 10 Matters Referred to the CCC
The committee received nearly 30 confidential submissions from witnesses who feared reprisal. It heard evidence of bullying, harassment and intimidation by COEX staff across multiple refund point operator sites. Allegations of conflicts of interest, unfair contracts, and misleading conduct were also received. 10 matters were referred to the Crime and Corruption Commission (CCC) for consideration. COEX confirmed it received the referrals.
QLD Parliamentary Inquiry Report, Chair's Foreword; ABC News, 16 October 2025
"Out-of-Home" Consumption Identified as the Critical Unaddressed Gap
The inquiry specifically identified capturing 'out-of-home consumption' as a primary mechanism for improving recovery rates — commercial venues, hospitality, events, stadiums, and workplaces. These are exactly the contexts where the 10c refund alone has zero reach, and where a gamified, prize-based behavioural engagement model — like the 10c Recycling Games — operates directly.
QLD Parliamentary Inquiry Report, Chapter 5.1.2 — Capturing out-of-home consumption, p. 201
What the Inquiry Identified — Areas Beyond Legislative Solutions
The Inquiry Identified
- ✕Recovery rate stuck at 67% — 18% below the legislated target
- ✕"Out-of-home" consumption (events, hospitality, workplaces) almost entirely uncaptured
- ✕The 10c refund alone is insufficient to drive the remaining 33% of non-returners
- ✕No credible mechanism exists to enforce the 85% target
- ✕Governance failures mean scheme surpluses are not being reinvested in performance improvement
- ✕Corporate actors (venues, employers) not sufficiently incentivised to participate
What 21 Recommendations Did NOT Include
- →No recommendation for gamification or prize-based participation incentives
- →No recommendation for community competition between suburbs, schools or workplaces
- →No recommendation for a structured charitable giving layer to drive repeat behaviour
- →No recommendation for a national cross-scheme engagement campaign
- →No recommendation leveraging behavioural economics or social proof mechanisms
- →The QLD Government explicitly rejected the one financial lever raised (refund increase)
The space between what the inquiry identified and what legislative recommendations can address represents an opportunity for complementary approaches like The 10c Recycling Games. It is not a replacement for good governance — it is a behavioural layer that operates alongside the existing scheme framework.
"Let us be clear: it is everyday Queenslanders — mums, dads, kids, and grandparents — who fund this scheme. They pay for its administration, logistics, and operations through the increased cost built into every beverage they buy."
— Rob Molhoek MP, Committee Chair, QLD Parliamentary Inquiry Report, October 2025
7 of 8 schemes are below target.
The solution is behavioural.
Every audit tells the same story: infrastructure built, awareness raised, return rate plateaued. The 10c refund alone isn't enough. The Recycling Games is the missing piece.
Important Legal Disclaimer
Please read and acknowledge these terms before continuing.