Paving the way to productivity through circularity

The Productivity Commission’s interim report, ‘Australia’s circular economy: Unlocking the opportunities’ was released in March 2025, with responses invited in April to help shape the final report.

The interim report notes that Australia’s progress towards a circular economy has been slow, with materials productivity, circularity rate (that is, the proportion of non-virgin or recycled materials used, compared to materials used overall) and resource recovery rate increasing marginally over the past decade. Australia’s circularity rate of 4.6% was half the global average, which reinforces the need for the Federal Government’s targets outlined in Australia’s Circular Economy Framework including the goal to double Australia’s circularity rate by 2035.

The interim report sets the stage for a more aligned, collaborative approach between industry and government, especially through product stewardship.

Your feedback on how to incentivise participation

Our response to the interim report was informed by direct feedback from Seamless members and supporters as well as the broader clothing sector, and represents the collective voice of an industry poised for change.

In the survey we conducted in April 2025, you told us that you value the voluntary efforts of the responsible brands who have joined Seamless to date, however there was a strong consensus that voluntary action alone is not enough. 64% of respondents called for regulations that enforce mandatory participation in product stewardship schemes.

Other suggestions you shared for incentivising greater participation in Seamless were formal recognition for organisations making significant progress in circularity(58% of respondents), access to more collaborative opportunities such as pilots with industry (57% of respondents), as well as policy intervention through government procurement of sustainable clothing; and clear evidence that the scheme delivers tangible return on investment (both were nominated by 53% of respondents).  

91% of Seamless members also noted that the scheme is meeting or exceeding their expectations and their key motivations for joining Seamless were to:

• Demonstrate their commitment to a positive circular future (40% of respondents)
• Position their organisation as a circularity industry leader (39% of respondents)
• Realise opportunities to learn from and partner with like-minded organisations (35% of respondents)

Advocating for mandatory industry-led stewardship

Our response advocates for mandatory participation in accredited product stewardship schemes. With over 14,000 liable parties in the Australian clothing industry, a voluntary approach leaves responsible businesses to carry an uneven and unfair load.

Mandatory participation will ensure a proportionate and equitable contribution from all clothing brands placing product on the Australian market, not just the most responsible. It will also address the frustration and imbalance created by freeriders and will enable genuine accountability and progress.

Additionally, mandatory participation in industry-led stewardship schemes means that the administrative burden of the schemes can be shifted from government to the industry. This frees up government to focus on enforcement to ensure compliance.

Mandatory participation in industry-led stewardship schemes will:

• Ensure fair market conditions to allow liable parties of all sizes to compete and transition to a circular economy effectively
• Reduce industry uncertainty by providing clear expectations for compliance
• Motivate and fund innovation and progress in resource efficiency and diversion from landfill
• Create equity and financial sustainability for initiatives that deliver on agreed environmental impacts

Systemic transformation needs all players involved. Voluntary action will not level the playing field for the Australian clothing sector which is dominated by a few large industry players.

Seamless is also supportive of free-rider behaviour being recognised as anti-competitive behaviour under the Australian Competition and Consumer Act.

“Compulsory membership and policy measures will accelerate momentum.”
Seamless member

More highlights from our response

In addition to calling for fairness through regulated participation, our response to the Productivity Commission’s interim report also noted that:

• Whole-of-life stewardship is key: Circularity must start with product design and extend through to end-of-life, supported by clear standards and eco-labelling.
• Product design standards and eco-labelling must be regulated: Clear, consistent standards and labelling empowers consumers and encourages renewable, recyclable and more durable product design.
• Significant economic and social opportunities exist: Circularity is an economic strategy with the potential to reduce landfill costs by more than $30 million annually, create more than 4,000 jobs and generate over $2 billion in revenue through the second-hand clothing market by 2030.
• Global alignment is crucial: Keeping pace with international standards is crucial to strengthen Australia’s global competitiveness and ensure innovation and better practice across the entire product lifecycle.
• Support for small business is critical: Seamless members want more recognition and investment in local makers and recyclers to kick-start the Australian circular economy.

What’s next

As the Productivity Commission finalises its report, Seamless will continue advocating for policies that reward innovation and ensure all clothing brands share responsibility for building a circular future. Together, we remain united in fairness, circularity, and continuous improvement.