Why Shopping Centres Should Be Preparing for NABERS Waste Today

Most shopping centre operations and sustainability teams are well across NABERS Energy and Water ratings, but the Waste framework is less familiar territory. The framework is still developing, formal ratings for retail assets are not yet available let alone mandatory, and for many centres, waste reporting remains a patchwork of contractor summaries and unverified assumptions.

That is about to change. The NABERS Waste benchmark for shopping centres is close to being finalised and released. Of all the asset classes yet to be formally rated, shopping centres are next in line.

NABERS Waste is the emerging benchmarking framework for waste performance across the built environment. For shopping centres, the direction of travel is clear. What the sector can learn from office buildings, currently the only asset class with a formal NABERS Waste rating, is that early preparation is key to achieving a strong outcome. The data systems, dock infrastructure and downstream relationships that determine a rating are built over months and years, not weeks. Centres that prepare now will enter the framework with clean data, defensible reporting and a baseline they can build on. Centres that wait will likely find their constraints are structural and slow to fix.

Beyond the rating itself, there is growing pressure from above. Investors, fund managers and reporting frameworks like GRESB are increasingly expecting verified waste performance data that goes beyond diversion rates. NABERS Waste provides the standardised, auditable framework that makes that possible.

This article walks through what genuine preparation looks like, across data integrity, dock infrastructure, downstream transparency and timing. Data Integrity Is a Governance Issue

Recycling rates alone are not a reliable indicator of performance. Before asking how well a centre is diverting waste, the more important question is whether the underlying data is robust and defensible enough to support that claim.

Most centres do not have a clear answer to that question. Waste reporting across retail assets typically relies on a mix of measured weights, volume-to-weight conversions and contractor-provided summaries. Where measurement gaps exist, assumptions fill the space. Those assumptions, if unchallenged, quietly shape reported outcomes year after year.

A useful starting point is understanding Actual Weights Coverage: the proportion of total reported waste supported by verifiable weight data such as truck scale or weighbridge records. Actual weights are the preferred method under NABERS Waste as they are directly measurable and fully defensible. Low coverage does not necessarily mean poor recycling performance, but it does mean poor data quality and reported performance that cannot be fully defended.

Where actual weights are not available, volume-to-weight conversions are used. In these cases, the quality of the density assumptions applied matters significantly. Site-specific densities derived from onsite dock audits are the preferred approach, as they reflect the actual waste profile and performance at the source. Generic industry densities are the least preferred option. They are not site-specific and can produce results that are either inflated or understated, depending on how closely the site matches the assumptions behind the figure.

Beyond measurement methodology, centres should also be asking:

• Whether daily transactional reports are available from the waste contractor that meet NABERS Data Quality requirements, or whether only summary reports are being provided. Detailed transactional reporting is often only available if it is specifically requested and written into the service contract.

• Whether waste streams are clearly separated in reporting by equipment type, including bins, compactors and balers.

• Whether non-operational waste such as fitout, base building works or contractor waste is being captured within operational reporting and distorting results.

• Whether contractor reporting actually reflects what is physically occurring onsite, or whether it is being generated from internal systems with historical assumptions without site-level verification.

When measurement systems are weak, reported outcomes become unreliable regardless of operational effort. Data integrity is not a reporting detail. It is a governance issue, and it is the foundation on which everything else in a NABERS Waste rating sit.

Dock Configuration Drives Reported Performance

Waste performance in shopping centres is heavily influenced by physical infrastructure. Tenant behaviour and recycling programs matter, but they operate within a system that the dock either supports or undermines.

Dock layout, bin sizing, equipment selection, signage and overflow management determine whether waste streams remain separated or become contaminated, and whether reported data reflects what is actually happening onsite. When those elements are poorly configured, cross-stream mixing increases; recovery rates fall and reported performance suffers regardless of how engaged tenants are.

In practice, underperformance is frequently attributed to tenant behaviour when the dock itself is the root cause. Most centres have never had their dock independently reviewed or audited. Configuration decisions made at the time of construction or at the start of a contractor relationship tend to remain in place indefinitely, even as waste volumes, stream mix and reporting requirements change around them.

A periodic independent dock review should examine more than cleanliness or housekeeping. It should assess whether the waste system is designed to support the specific needs of the site, accurate reporting, and high recovery rates. Key questions include:

• Whether collection equipment is right-sized to actual waste generation patterns. A mismatch between bin capacity and generation volumes leads to low efficiency or overflow and cross-contamination.

• Whether equipment selection has been driven by site needs or by what the contractor has available. These are not always the same thing, and the difference has a direct impact on reported performance and potential savings.

• Whether contamination rates are understood, measured and periodically audited, or simply assumed to be acceptable.

• Whether general waste composition has been assessed to understand how much recoverable material is being lost to landfill.

• Whether signage and labelling systems are consistent and legible across tenants, cleaners and dock staff.

• Whether overflow management protocols exist and are being followed, or whether overflow is routinely directed into general waste without being recorded.

Infrastructure design is a structural performance lever. It directly influences recycling rates, contamination levels, data integrity, and ultimately NABERS Waste outcomes. Treating it as a background operational detail is one of the most common and costly mistakes centres make.

Downstream Transparency Is Increasingly Material

Stating that material is “recycled” or “diverted” is no longer sufficient. Knowing the next destination alone is not enough; what matters is the full chain of custody and the material outcomes achieved.

Centres must understand:

• Which facilities receive each stream

• What material outcomes are produced from those streams

• The recovery rates achieved at each facility

• Whether recovery rates and outcomes are verified or assumed

• How downstream outcomes support genuine circularity rather than disposal or low-value recovery

A full chain of custody across all destination facilities is critical. Waste rarely moves directly from a shopping centre to a final processing facility. In many cases, material may first go to a transfer station, then to a Materials Recovery Facility (MRF), then to secondary processing facilities. Some materials may be processed domestically, while others may be exported overseas for further processing and remanufacturing.

Understanding this chain, and the flow of materials through it, is important not only for reporting and compliance, but also for operational strategy and tenant engagement. For example, if certain plastic streams are ultimately exported and processed overseas into pellets, while container streams are processed domestically and support local circular manufacturing, centres can use this information to guide tenant education, procurement decisions and packaging preferences, helping close the loop within local supply chains. However, this is only possible when full visibility and transparency across the chain of custody is established.

Historically, this level of downstream transparency has not been a major priority in the waste industry. However, this is changing rapidly. Ratings and certification frameworks such as NABERS Waste and GECA (Good Environmental Choice Australia) are increasingly placing greater emphasis on downstream reporting, recovery verification, and chain-of-custody documentation. The focus is shifting from simply reporting diversion rates to demonstrating verified material outcomes.

One useful way to assess downstream performance is to track the proportion of total waste according to final material outcomes, for example assess the proportion of materials that are:

• Circular recycled (materials recycled into similar products)

• Downcycled (materials recycled into lower-value applications)

• Linear recycled (materials partially recovered and not returned to the same product cycle)

• Converted from Waste to Energy via PEF / incineration

• Landfilled

Another useful metric is the proportion of waste treated domestically versus overseas. Understanding how much material is processed within Australia compared to exported for processing overseas provides additional insight into circular economy outcomes, supply chain risk and ESG reporting transparency.

For NABERS Waste and broader ESG reporting, aggregated statements and supporting documentation are often required from downstream processors and contractors. These statements typically include destination facilities, material outcomes, treatment processes, recovery rates and acceptability criteria for each stream.

A documented chain of custody — from dock to final processing facility — should therefore be maintained and reviewed at least annually. As scrutiny increases from ratings bodies, regulators and investors, downstream transparency becomes part of defensible ESG reporting, not just operational reporting.

Without a clear chain of custody and verified downstream outcomes, diversion claims may lack substance.

Timing Creates Risk

One of the most common structural weaknesses in retail waste management is submission-season reactivity. Reviewing systems in the final quarter of a reporting period rarely produces meaningful improvement. By that point, the conditions that determine a rating have already been set.

Density assumptions for collections with no actual weights, audited contamination rates and dock-level densities, compaction efficiencies and contractual misalignments are not problems that can be corrected when looking backwards. They are embedded in infrastructure, reporting systems and service agreements that take time to identify, negotiate and change. When those issues are discovered late, the options are limited and the rating reflects it.

The centres that perform well under NABERS Waste treat it as a year-round discipline rather than an annual submission exercise. In practice that means:

• Live access to audited waste reporting across the portfolio, rather than waiting for periodic contractor summaries.

• Quarterly data reviews that identify drift in stream volumes, density assumptions or contractor reporting quality before it compounds.

• Ongoing annual minimum onsite dock assessments that track whether infrastructure is performing as intended and whether equipment configuration still matches waste generation patterns.

• Clear Operational Waste Management Plans that are actively maintained and not simply filed after the first year.

• Periodic validation of density assumptions through site-based audits rather than relying on figures that may not have been reviewed in years.

• Tenant engagement that goes beyond compliance notices and builds genuine understanding of waste stream requirements at the dock.

• Service contracts that are structured around performance objectives rather than collection schedules alone.

The conditions that drive a strong NABERS Waste rating are built across the full year. Waiting until submission approaches to review systems is not preparation. It is reactionary, and a reactionary approach is always more expensive and less effective than a proactive one.

At EC Focus, we have developed a structured approach to help centres take preemptive action before the benchmark is finalised. Our Waste Scanner tool allows operations and sustainability managers to assess waste data at a portfolio level, identify where gaps exist in data quality, reporting coverage and downstream transparency, and understand where operational improvement is possible. By collating a centre's waste data and standardising it in a NABERS-aligned format, we help centres build a defensible baseline now, so they are not starting from scratch when formal ratings arrive.

Structural Preparation Creates Advantage

Like emissions boundary setting in carbon reporting, early structural decisions in waste create path dependency. Density assumptions, reporting structures, contractor relationships and dock configurations, once embedded, shape performance outcomes year after year. They are difficult to change quickly and expensive to correct under time pressure.

Centres that address data integrity, infrastructure design and downstream transparency now will be positioned to enter the NABERS Waste framework with confidence. They will have a defensible baseline, a reporting system that holds up to scrutiny and the operational visibility to identify where genuine improvement is possible.

Centres that delay will likely find that their constraints are systemic rather than behavioural. The gap between those two positions will widen as the benchmark is finalised and formal ratings become the standard against which shopping centre waste performance is measured.

NABERS Waste is not simply a rating exercise. It is an operational governance challenge, and preparation begins well before submission. Contact our team to learn more! Author: Ramiro Nasta - Lead Consultant at EC Focus Ramiro leads EC Focus’ work in NABERS Waste benchmarking, GECA certification, and material flow analysis, managing over 35 NABERS ratings annually and the development of WastePerformer, our internal benchmarking tool. He also manages assurance projects such as GECA certifications for the Sydney Opera House (via WasteFree) and Premier Waste, and supports clients with material flow analysis to improve performance. With a Master’s in Sustainable Development (Distinction) from Macquarie University and a background in psychology, Ramiro brings expertise in behavioural change and education to the sustainability sector. Since 2018, he has helped organisations meet sustainability KPIs, reduce Scope 3 emissions, and embed lasting circular economy practices.