Home Insights On your marks, get set, FOGO: the race to keep organic waste out of landfill

On your marks, get set, FOGO: the race to keep organic waste out of landfill

Food organics and garden organics (FOGO) are favourites in the race to reduce landfill waste, but community disinterest or confusion, policy gaps (particularly in research) and legislative constraints present major hurdles. Further, if there is no audience (or end user) is there any point in sprinting to the end?

The race course

Every year, Australians dispose of 28 million tonnes of materials into landfills,[1] losing the value of those resources and missing opportunities to create jobs. For every 10,000 tonnes of waste that is recycled, 9.2 jobs are created, compared with only 2.8 jobs if the same amount goes to landfill.

Waste is responsible for approximately 2% of Australia’s emissions, consisting largely of methane gas from decay of organic material in landfill.[2] While composting will create landfill gases its contribution is far less than that produced by landfills.

One of the most obvious ways to reduce ‘waste’ is to reduce the amount of FOGO disposed to landfill. This will slow the demand for costly landfill.

Organic waste may be able to be used as a mulch and soil conditioner and, by finding alternatives to landfill, will also reduce Australia’s greenhouse gas emissions – leading to better environmental outcomes.

The rules

Both the National Waste Policy Action Plan 2019 and the Queensland’s and Resource Recovery Industry 10 Year Roadmap and Action Plan 2019 present targets and actions to implement the 2018 National Waste Policy and Waste Management and Resource Recovery Strategy, respectively. The targets and actions are intended to guide investment.

National Target 4 is to significantly increase the use of recycled content by governments and industry.

National Target 6 is to halve the amount of organic waste sent to landfill by 2030.

Queensland has set targets about the waste that is to be diverted from landfill by waste stream.

The hurdles

Contamination and inconsistent output

Inconsistent separation (or ‘wish recycling’) of household recycling (or ‘wish recycling’) of household recycling from rubbish contaminates otherwise reusable materials, increasing costs and the amount of recyclable waste being dumped. The level of contamination in a garden organics bin (green bin) directly affects the recycler’s ability to recover resources effectively.

Green bins are commonly contaminated with:

  • pot plants

  • treated timber

  • soil

  • large branches

  • food waste

Similarly, organic food bins are commonly contaminated with:

  • soft plastics

  • coffee pods

  • food tags (i.e. bread tags)

  • cardboard that is lined or laminated (e.g. frozen food packaging)

  • treated timber and soil

This contamination may lead to entire loads being diverted from composting to landfill.

Further, the end product of composting is subject to the habits of the consumers and subject to, among other things, seasonal weather and festive seasons (where the types of foods eaten may significantly change and interest in disposing of waste appropriately may decrease) meaning the products in and the end product out are often inconsistent. Things such as nitrogen, phosphorous and micro-organics can be added to the compost to ensure its quality but this adds to the cost.

There is also a growing awareness[3] of per- and polyfluoroalkyl substances (PFAS) and heavy metal contamination (among other things) in compost and consideration should be given to this – particularly whether such compost is appropriate for agricultural land[4] where food crops are produced. Perhaps compost should, at this stage, be restricted to rehabilitation, use on parks and near roads?

Need for greater policy levers to ensure more collaborative research

There are a number of institutions currently investigating some issues associated with waste, with some having a particular focus on composting FOGO. However, it is suggested that more needs to be done before possible end users are confident to use FOGO.

More research is needed about the adverse impacts of composting facilities, e.g. does it have adverse impacts on overland flow and groundwater quality, generally and specifically looking at PFAS, as well as how best to reduce nuisance impacts in terms of odour, dust and management of pests.

Research is also required in respect of the quality and possible impacts[5] of any mulch or soil conditioner produced, whether such mulch or conditioners increase agricultural output; whether that output improves the quality of the product and is suitable for human consumption; and its cost effectiveness when compared with other fertilisers currently used and tested. Otherwise, why would a farmer risk using this compost material?

Legislative constraints could be lessened by pilot programs

There is no doubt that organic material processing can have adverse impacts on the environment and nearby residents. For that reason, in Queensland organic material processing of more than 200 tonnes by way of composting or anaerobic digestion is an environmentally relevant activity (ERA 53) for which an environmental approval is required. Compost from organic matter from agriculture or livestock production is excluded.

However, applications for these activities are costly with numerous expert reports required to support them. But given the uncertainty of product and demand, it is difficult to see increased facilities being developed in the near future unless and until there are greater policy levers being employed; perhaps funding or a collaborative research approach with universities and governments at all levels. In Queensland, the Department of Environment and Science is developing an Organics Action Plan.

It may be appropriate to allow pilot programs in this space where application fees are waived and limited expert reports are required, on the basis that monitoring will be conducted and research shared, with an exclusion from liabilities should environmental harm be caused. 

After a prescribed period, an application for an environmental authority would be made in the ordinary course. Perhaps, organic material processing could be extended to agricultural land in limited circumstances.


The race is not yet run. While both Federal and State governments have been more active in the waste management fields in recent years, there remains much industry uncertainty. Government education programs, including at local government level, about what can and cannot be recycled need to be clearer and uniform. Consideration should also be given about increasing the frequency of FOGO waste collection. Financial incentives to universities and waste bodies to conduct research would be beneficial; so too some legislative approval easing for those trying to ultimately improve environmental outcomes.

[1] National Waste Policy Action Plan 2019, p12.
[2] Quarterly Update of Australian’s National Greenhouse Gas Inventory: December 2017, Commonwealth of Australia 2018
[3] See also Choi, Y., et al Perfluoroalkyl Acid Characterisation in US, Municipal Organic Solid Waste Composts Environ. Sci. Technol. Lett. 2019, 6, 6 372-377
[4] See for example, PFAS National Environmental Management Plan v 2.0 and comments about the reuse of PFAS contaminated material on agricultural land, 12.2.
[5] See for example, Chan, K.Y and Fahey, D.J Effect of composted mulch application on soil and wine grape potassium status, Soil Research 49(5) 455-461 https://doi.org/10.1071/SR1108...


Leanne O'Brien

Special Counsel


Environment and Planning

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