Cement Concrete & Aggregates Australia (CCAA) welcomes public consultation on the Queensland Government’s Draft Waste Strategy 2025–2030, but warns that unless current regulatory barriers are addressed—particularly those surrounding the End of Waste (EOW) Code Framework—the Strategy risks falling short of its ambitious goals.
CCAA members play a critical role in Queensland’s circular economy by recovering and reusing construction waste such as old concrete, washout water, and surplus quarry materials. These materials are crushed, treated, and repurposed into road base, drainage aggregate, fill for construction sites, and new batches of concrete—keeping valuable resources out of landfill. This practice not only reduces environmental impact and reliance on virgin materials, but also lowers carbon emissions as less energy-intensive cement and lower energy overall is required, conserves water and supports the delivery of low-carbon infrastructure across the state.
The Queensland heavy construction materials industry is ready to lead Queensland’s transition to a circular economy, but we are being held back by outdated and cumbersome waste regulations.
“We strongly support the Queensland Government’s vision for a more circular, less wasteful economy,” said Michael Kilgariff, Chief Executive Officer of CCAA.
While the Draft Strategy aims to boost recycling and reduce landfill, CCAA warns that:
- The current EOW Code Framework is overly complex, with costly and confusing compliance requirements that undermine the benefits of recycling construction materials.
- Inconsistent permit rules (ERAs) make it unclear how and when certain waste materials become resources, creating unnecessary duplication in regulatory approvals.
- The regulatory burden for reusing materials is often greater than for disposing of them, which contradicts the Strategy’s hierarchy of reduce–reuse–recycle.
“For example, the same recycled concrete that meets environmental safety standards can require different permits depending on the interpretation of the waste code,” Mr Kilgariff explained. “This creates delay, cost, and uncertainty—all of which discourage investment in recycling.”
To ensure the Waste Strategy delivers on its potential, CCAA calls for:
- Simplification of the EOW Code Framework for low-risk materials like concrete washout and recycled aggregates.
- Clear and consistent definitions of when waste becomes a resource, reducing confusion.
- Flexibility in existing ERA permit use, enabling reuse of materials without needing multiple new permits.
- Policy alignment between circular economy goals and operational regulations, ensuring environmental benefit is matched by practical feasibility.
“Queensland has the chance to lead in sustainable construction and resource recovery, but that requires waste regulations that encourage innovation and reward—not penalise—those doing the right thing. We are ready to work with government on practical solutions that keep valuable materials in use and support the environment and economy,” said Mr Kilgariff.