If you are one of the many Kiwis who are worried about the many waste issues we currently face – plastic pollution, microplastics, reduced markets for recycling, tyre mountains, the list is endless – the best thing you can do right now is make a submission on the Ministry for the Environment’s public consultation document on priority products for product stewardship.
The consultation document is seeking the opinion of New Zealanders as to whether the following products should be part of a regulated (i.e. compulsory) product stewardship scheme:
- electrical and electronic products (e-waste)
- refrigerants and other synthetic greenhouse gases
- agrichemicals and their containers
- farm plastics
- packaging (beverage packaging, single-use plastic packaging)
That’s all very well, but what is product stewardship?
In simple terms, product stewardship is a way of reducing waste and increasing the recycling of products that cause significant environmental harm, when they become waste or are difficult to collect for recycling.
For example, a consumer may pay extra when they purchase a product but be able to dispose of the product at the end of its useful life for free. Or a refundable deposit may be included in the price of a beverage and this deposit returned when the empty container is taken to a collection point.
So, going back to the issue of plastic pollution, a scenario under a product stewardship scheme could be:
- For all beverage containers a small fee would be added onto the cost of all beverages.
- When the beverage container was returned to a collection point the consumer would receive a small refund.
- The scheme managers would need to ensure the returned beverage containers (and potentially their lids) are recycled.
- The scheme would have recycling targets to meet and would need to ensure the majority of New Zealanders have access to a collection point.
Overseas, successful container deposit schemes have raised recycling levels to about 85% for beverage containers, given community groups and schools a fundraising opportunity and significantly reduced littering of beverage containers.
Or we could look at e-waste. A recent masters thesis by Vicktoria Blake found that only 1.8% of the estimated e-waste generated in the Whangarei District each year was being recycled through the municipal services available. Under regulated product stewardship for ewaste, consumers would probably pay a fee when they buy an appliance, mobile phone or computer. But this upfront payment would cover the cost of recovery, refurbishment or recycling at the end of it’s useful life.
Click here to see Associate Minister for the Environment, Hon Eugenie Sage, explain regulated product stewardship.
But aren’t some of these products already part of a product stewardship scheme?
At the moment some of these products are part of voluntary product stewardship schemes. These voluntary schemes have been set up by stakeholders within each industry and have tackled hard to recycle waste such as tyres, synthetic greenhouse gases, agrichemicals and farm plastics. However, the organisations running these schemes all welcome regulated product stewardship because of the issue of free riders.
Free-riders are organisations who sell the product that is part of the product stewardship scheme but do not contribute financially towards the delivery of the service. They are called free-riders because most schemes will still accept their products, meaning that it is not a level playing field across that product sector.
What should I include in my submission?
WasteMINZ members have been asking a lot of questions about product stewardship over the last few weeks since the launch of the proposed priority products and guideline announcement, 9 August. Below are questions you may wish to think about when you make your own submission.
Tyres are the biggest source of microplastics in the ocean and long-life tyres produce fewer microplastics, so if you think compulsory lifespan labeling of tyres or compulsory labeling of tyre abrasion should be included in a product stewardship scheme for tyres, please let MfE know.
If you think we need to encourage a change in consumer behaviour towards e-waste (i.e. tackle the top of the waste hierarchy) then addressing planned obsolescence by manufacturers, or compulsory lifespan labelling, which tells the consumer how long a product will last, might be good points to include as a suggestion for an e-waste scheme.
Plastic lids are one of the top 3 pieces of litter found on beaches and in marine animals. So should lids and fastenings be included in the scope for priority product stewardship for beverage containers?
The consultation document is considering single use plastic but some WasteMINZ members think that compostable plastic (both home and commercial) and “biodegradable” and “oxydegradable” plastics and packaging with similar claims should also be explicitly included in the scope. Why?
- The current limitations of existing infrastructure to collect and process compostable materials
- There being no proof that biodegradable packaging breaks down when littered
- The danger that producers could switch to compostable and biodegradable packaging, if it is excluded from a priority product scheme solely to avoid being part of a regulated product stewardship scheme.
Compulsory end of life labeling is another idea that could be included in submissions because currently many products are poorly labelled or not labelled at all. Compulsory labeling would state clearly whether a product is recyclable or not and if so, whether it can be recycled at kerbside or via an in-store drop off.
A Container Deposit Scheme is alluded to in the consultation document but not explicitly mentioned. If a container deposit scheme makes sense to you, make sure you mention this.
Buildings are now shrink-wrapped and shrink-wrap is used in vast quantities when goods are being transported on pallets. So, should all plastic film be included in the scope for this product?
What do I need to know about Table 3?
Table 3 outlines the guidelines for designing a regulated product stewardship scheme – that is, how the scheme will look and who will run it. Here are some things you might want to think about in your submission about Table 3.
- Section 13 of Table 3 is Design for Environment. Paragraph A. indicates that schemes will contain financial or other incentives for applications higher up the waste hierarchy. Energy recovery is listed as being below recycling or composting but above safe treatment and disposal. Should “energy recovery” be excluded as an acceptable disposal route for difficult to recycle materials that are part of a regulated product stewardship scheme?
- Section 16 of table 3 is all about monitoring, compliance and enforcement. If a scheme fails, should the government or another independent body be able to take it over?
- Section 17 of Table 3 is accessible collection networks. Under paragraph A. should “reasonably accessible” be defined for all schemes rather than left up to scheme managers to define? I.e. within a 20-minute drive of most households or other measurable definitions.
Additional elements you may wish to comment on include:
Timeframes – are the timeframes being proposed by the Ministry for the Environment long enough?
- 1 year for implementation for existing schemes
- 3 years where no scheme exists
You might want to consider that if the scope for collection of products is wider than what is currently being collected by an existing scheme, a staged implementation is permitted to allow time for end markets or recycling facilities to be developed for new schemes? e.g.
- 1 year for implementation if it is an existing scheme with existing products
- Up to 3 years to expand the existing scheme to include the wider range of products
Should other supporting measures such as Right to Repair and circular design legislation be considered by the government to support product stewardship?
How do I submit my views?
First up read the document prepared by the Ministry for Environment by clicking here.
Then click here to make your submission before 5pm on the 4 October.
WasteMINZ will be making a submission on the document via the TAO Forum and Product Stewardship Sector Groups. To belong to a sector group you must be a WasteMINZ member, so please contact CJ@wasteminz.org.nz
We strongly urge as many New Zealanders as possible to do make a submission, because this legislation if enacted will make a significant difference to the way we create and deal with waste in Aotearoa.
If you need more information, the WasteMINZ Product Stewardship Sector Group webpage has lots of useful information about product stewardship.
Please feel free to contact firstname.lastname@example.org if you would like more information or help with your submission.