Coles Group Ltd | Coles Group Members' Statement on Plastic Packaging
- Environment
- Waste and pollution
- Water and oceans
> Publicly reporting, on an annual basis, the total volumes of packaging used each year (Business to Business (B2B) and Business to Consumer (B2C) Own Brand product packaging) with detailed breakdown by material type to include, at a minimum, a figure for all plastic packaging, either as a total volume or a plastic intensity metric.[1]
> Setting a timebound overall plastic reduction target (%).
> Reporting the feasibility and opportunities to eliminate unnecessary [2] packaging through:
>> Reviews of disposable plastic packaging, proving where and why packaging is genuinely necessary, for example to reduce food waste or ensure safe handling,
>> Providing online customers an option to opt-out of plastic produce bags on loose fresh produce,
>> Providing equitable access to loose fresh produce (at the same price or cheaper compared to pre-packaged fresh produce)
>> Replacing disposable [3] packaging with reusable and refillable packaging options, in B2B and B2C, for its Own Brand products where proven alternatives exist.
> Publicly supporting state, territory and federal government policies to introduce eco-modulated extended producer responsibility (EPR) and bans on problematic and unnecessary plastic packaging, products and chemicals of concern.
Coles lags behind its peers on plastic disclosure and reductions of plastic packaging for its Own Brand products.
Coles reports on instances of reducing plastic packaging for select products and packaging types in its annual sustainability report through case studies, but this fragmented approach to reporting doesn’t help investors understand Coles’ total plastic packaging footprint.
By contrast, Woolworths Group reported its plastic intensity for the first time this year [4], and ALDI Australia has previously published this measure, the amount of packaging it placed on the market, the plastic intensity of its packaging and its plastic reduction target [5]. Public reporting in this manner by Coles utilises data which is collected currently.
Various global reporting frameworks require or encourage large retailers to disclose much of the information we are requesting [6]. Of the 10 largest European and UK grocers, five report own brand plastic footprints and reduction targets [7]. For example, Tesco UK discloses packaging use and reductions by material type, split into own-brand and vendor-branded products, as a total tonnage amount, against its targets. Tesco UK and Ocado reported on their reuse/refill trials with suppliers, including methodology and customer education, challenges and success measured against KPIs [9]. Reuse and refill models have shown overseas they can offer customer convenience at no extra cost while reducing overall plastic use [10].
In 2023, 185 investors with over US$10 trillion in assets called on the largest companies in the fast-moving consumer goods and grocery sectors to set a clear plan of action to make absolute reductions in single-use plastic packaging on defined timescales, including through scaling up reuse options [11].
Using excessive disposable plastic packaging is a risk to Coles’ brand.
Excessive plastic packaging is a reputational risk to Coles, which is financially material when research attributes over one third of all shareholder value to reputation [12].
Data collected by Seabin between July 2020 and July 2026 found Coles Own Brand packaging was in the top 10 most common pieces of litter found in Sydney Harbour, and 91% of Sydney Harbour plastic litter comes from items that are available on Coles supermarket shelves [13]. This makes Coles a prominent face of the plastic polluting Australia’s ocean and wildlife.
Plastic pollution harms marine life and habitats. Sea turtle hatchlings [14] and seabird chicks [15] suffer biological damage from plastic ingestion, harming Australian species populations [16]. Seals and whales are regularly injured by entanglement [17] and corals in contact with plastic are 20 times more likely to become diseased [18].
Coles is already exposed to reputational damage through its sourcing of Tasmanian salmon farmed in Macquarie Harbour - which is the primary threat to the endangered Maugean skate. Additionally, Coles was assessed as a company at high-risk of exposure to deforestation of the habitat of iconic Australian species, like koalas, through its beef supply chains [19]. Association with harm to other iconic Australian species through plastic pollution may compound public perceptions that Coles harms nature, rather than protects it.
Plastic is a growing source of Scope 3 emissions for retailers
In 2019 plastic accounted for 3.8% of global emissions - double that from aviation - and could grow to 15% of the global carbon budget by 2050 [20]. One-third of plastic globally is for packaging, mainly for food and beverages [21]. The largest source of Scope 3 emissions for Coles is upstream emissions in products Coles sells, accounting for 27.1% of its Scope 3 emissions [22]. Investors would benefit to know how much Coles’ plastic packaging use contributes to this and how reducing it will contribute to its emissions reductions goals.
Companies connected to harm from plastic face growing financial liabilities from litigation and policy
There is a growing body of research linking plastics and related chemicals ingested by humans to serious diseases [23], and that food packaging is one of the most direct and recurrent pathways of plastic exposure in everyday life [24]. Plastic packaging is a vector for toxic chemical ingestion by humans and results in micro and nano plastic pollution [25].
Litigation in Australia against consumer-manufacturers of toxic products for falsely marketing their products as safe, healthy and environmentally friendly is growing [26]. This is a live risk for Coles when it is only prioritising making plastic packaging easier to recycle and including more recycled content [27], rather than eliminating unnecessary disposable plastic packaging and offering reuse/refill options [28].
In 2026, the Australian Government sued 3M for $2 billion over the concealment of the health and environmental harms of PFAS [29] and misleading conduct. Given the substantial and growing body of research on the harm plastic pollution causes to marine life, habitats and human health, Coles faces exposure in relation to its use of disposable plastic packaging. Legal analysts expect more such claims, drawing a comparison to asbestos [30].
Disclosing Coles' plastic packaging exposure, excluding proprietary information, enables shareholders to assess associated risks and opportunities.
Footnotes:
1. Plastic intensity could be reported by: Total volume of all disposable plastic packaging (both B2B and B2C) / total tonnage of product sold; total disposable plastic / units sold, or similar. Material types include paper and wood, metal, plastic and glass.
2. APCO’s Framework to identify problematic and/or unnecessary plastic packaging (2023) defines "unnecessary" as packaging that can be reduced or redesigned with a fit-for-purpose alternative without diminishing product integrity, compromising product accessibility, hindering ability to meet health or safety regulations, or causing undesirable environmental outcomes. Packaging that serves only a marketing or branding purpose is therefore unnecessary, as it can be removed without affecting any of these functions.
3. Packaging is considered disposable if it has not been designed for reuse. Reusable packaging is packaging that has been designed and manufactured to accomplish a minimum number of trips or rotations, is used multiple times for the purpose for which it was conceived, and supported by a system that enables repeated use. Reuse displaces the need for new packaging by maintaining items within active circulation for their intended function.
4. Woolworths Group, 2026, “Sustainability Data Pack”
5. ALDI Australia, 2020, “Plastics & Packaging Progress Report”.
6. The EU “Sustainability Reporting Standard E5” and the “Ellen MacArthur Foundation Global Commitment 2025” require disclosing plastic packaging usage by weight. “IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information” requires disclosing this information if its material to the Company. Coles reported plastic and packaging as its 4th most important sustainability-related risk in 2025.
7. Mart van Kuijk, 2022, “Plastic Perspectives: An overview of the plastic footprints, ambitions and plastic lobbying activities of listed European and UK grocery retailers and FMCGs”, The Dutch Association of Investors for Sustainable Development (VBDO).
8. Tesco, 2024, Packaging Factsheet.
9. Tesco, 2022, “Reuse Report”; Ocado, 2025, “The Refill Coalition: Key Learnings for Industry”.
10. Ellen MacArthur Foundation, 2023, “Unlocking a reuse revolution: scaling returnable packaging”,
p.35
11. Investor Statement on Plastics, 2024, “Investors call for urgent action to reduce plastics
from intensive users of plastic packaging”.
12. AMO Strategic Advisers, 2019, What price reputation? Corporate Reputation Value Drivers: A Global Report by AMO
13. Seabin, “Data Dashboard: Top 10 brands polluting Sydney Harbour”.
14. Duncan, E. M., 2021, “Plastic Pollution and Small Juvenile Marine Turtles: A Potential Evolutionary Trap
15. Rivers-Auty et al., 2022, “The one-two punch of plastic exposure: Macro- and micro-plastics induce multi-organ damage in seabirds”
16. Lavers, J., 2026, “Ingested plastics reduce recruitment and survival of an Australian seabird”
17. ; Kuhn, S. Andries van Franeker, J., 2020, “Quantitative overview of marine debris ingested by marine megafauna”.
18. Lamb, J. B. et al., 2018, “Plastic waste is associated with disease on coral reefs”.
19. Forest500, 2025, Company Profile: Coles.
20. If the demand for plastic continues to grow at its current rate of 4% a year. See Jiajia Zheng & Sangwon Suh, 2019, “Strategies to reduce the global carbon footprint of plastics”, Nature Climate Change. If the demand for plastic continues to grow at its current rate of 4% a year.
21. OECD, 2024, “Policy Scenarios for Eliminating Plastic Pollution by 2040”, OECD Publishing, Paris, p.11.
22. Coles Group Limited, 2025, “Sustainability Report 2025”, p.16.
23. Lee Bell and Jenny G it litz, 2023, “Chemical Recycling: A Dangerous Deception”, IPEN, p.17.
24. Fauroux, M., Boucher, J., & Perreard, S., 2026, “From Pack to Plate: A Global Assessment of Micro- and Nanoplastics Migrating from Food Packaging into Food”; Earth Action: www.e-a.earth “Per-capita intake is on the order of ~130 mg/ person/year on average, increases to several hundred milligrams under high-use scenarios, and may exceed ~1 g/ person/year for very high-use consumers, corresponding to hundreds of millions to billions of particles annually. “
25. Genevieve Gatt, 2024, “Microplastics created during recycling harming our environment”, University of Wollongong.
26. McKenzie Moore et al, 2026, “From Chemicals to Court Rooms: Tracking the Expanding
Landscape of PFAS Litigation”, Piper Alderman.
27. Reducing the overall amount of plastic packaging used can reduce these risks. Additionally, recycling alone will not end plastic pollution, actions higher on the waste hierarchy must be prioritised.
28. Coles Group, 2025, “Sustainability Report 2025”, p.8.
29. Also known as “forever chemicals”
30. Rosa Pritchard and Alice Merry, 2022, “Plastics on Trial: a briefing series on evolving liability risks related to plastics. Brief 2 Hazardous chemicals ”, Client Earth, p.9.
DISCLAIMER: By including a shareholder resolution or management proposal in this database, neither the PRI nor the sponsor of the resolution or proposal is seeking authority to act as proxy for any shareholder; shareholders should vote their proxies in accordance with their own policies and requirements.
Any voting recommendations set forth in the descriptions of the resolutions and management proposals included in this database are made by the sponsors of those resolutions and proposals, and do not represent the views of the PRI.
Information on the shareholder resolutions, management proposals and votes in this database have been obtained from sources that are believed to be reliable, but the PRI does not represent that it is accurate, complete, or up-to-date, including information relating to resolutions and management proposals, other signatories’ vote pre-declarations (including voting rationales), or the current status of a resolution or proposal. You should consult companies’ proxy statements for complete information on all matters to be voted on at a meeting.