Our submission on EPA Victoria’s draft guidance for minimising pollution and waste risks in a changing climate focuses on making climate regulation work in practice.

Dairy processors already manage climate-related risks every day – from heatwaves and extreme rainfall to power disruption and water scarcity. These risks are embedded in existing EPA licences, RMMPs, food safety systems and export assurance frameworks.

We support the EPA’s objective of strengthening climate resilience. But guidance must be proportionate, aligned and clear, particularly for low- to medium-risk food manufacturing sites.

In our submission, ADPF recommends a risk-based approach that recognises sector differences, avoids duplicating existing requirements, and allows evidence already assessed through RMMPs and other regulatory processes to be reused. We also call for clearer guidance on what “reasonably practicable” controls look like for dairy processing, consistent interpretation across EPA regions, and practical, co-designed tools to support compliance.

Our position is straightforward:

• focus on risk
• reduce duplication, and
• align new guidance with systems that already work.

Because effective climate-risk regulation should lift environmental performance, not add unnecessary complexity for regional manufacturers delivering essential food every day.

More: Read our submission.