Having arrived here in Aotearoa New Zealand just over six months ago, as a Brit with 28 years in environmental consultancy, the WasteMINZ team kindly invited me to give my first impressions.
To begin with, it all seemed as expected - gorgeous scenery, friendly locals, more cows and sheep than people, quirky small towns, and fascinating and profound Māori culture. But the outside world’s view of New Zealand as a pristine environment, with largely green policies, started to look somewhat shaky as I began to have conversations that took me back to the mid-1990s. Through these conversations, I discovered the gaps in regulation and the lack of strategic environmental thinking and investment!
The first real surprise was finding that there is still no Duty of Care for waste producers, and no Waste Licencing for waste operators: UK law since 1974, reinforced in 1994. This is going to be fixed (subject to how ‘waste’ is defined here), I understand, in the forthcoming change to the Waste Minimisation Act (WMA), so I’ll move on to the next elephant in the room: the very high levels of landfilling, in particular of biodegradable waste, and a lack of other waste infrastructure.
Biodegradable waste still going to landfill
The 1999 Landfill Directive in the EU came into force to control landfill engineering, and drive biodegradable waste out of landfill into composting and anaerobic digestion. This has largely been done (only 24% of waste in the EU is now landfilled, with a 10% 2035 target for municipal waste, and an obligation to collect biodegradable waste separately by 2024). The Directive was implemented because the control of leachate from landfill was a problem, it is generally not possible to capture the methane emissions completely (especially over the whole lifetime of a landfill), and because it is a waste of valuable resources. According to the European Union Methane Strategy, published in October 2020, 26% of the continent’s methane emissions still came from waste, and methane is 84 times more potent than CO2 on a 20-year timescale.
It was a surprise to find that the waste strategy consultation of 2021 (Te kawe i te haepapa para |Taking responsibility for our waste) appears to have no firm plans to phase out biodegradable waste landfilling, to bio-stabilise it, or to sort it before landfilling, and ony aspirations to increase diversion and improve gas capture for energy generation. While greenhouse gas emissions from waste are covered under the New Zealand emissions trading scheme, this, and the landfill levy - which is very low by EU standards (the UK landfill tax is currently close to NZ$200, versus only NZ$10 here, $60 in 2024) - seem to have done relatively little to abate the landfilling of waste. Despite slight improvements in 2019 and 2020, the long-term trend suggests that waste to landfill is still increasing.
Waste-to-energy is not the answer
In terms of waste-to-energy, there is nothing but guidance from MfE as yet, while councils and iwi, large and small, get pursued by technology providers of various kinds. I want to make clear that the dash for incineration in Europe, once found a sensible way to avoid emissions from coal-fired power stations, has increasingly become unhelpful in carbon terms as:
a) electricity generation is decarbonised (the UK is now below 6% coal/oil fired, and below 40% gas); and
b) we move to a circular economy (CE).
In my view, incineration is something that New Zealand, with such a high proportion of renewable electricity, should avoid in favour of greater emphasis on reduction, reuse and recycling.
The UK now has over 56 waste-to-energy incineration plants, taking more than 48% of the waste (2020/21), which many believe is constraining England’s ability to meet recycling targets, whilst even incinerator operators are asking the Government for a moratorium on new plants to help support a more circular economy. In Denmark, incinerators are being mothballed as the country moves to a more circular economy; incineration now being considered ‘leakage’ from the system, alongside landfill. The EU has excluded waste-to-energy incineration from a list of economic activities (the EU Taxonomy) considered suitable for ‘sustainable finance’. To cut overcapacity, seven incinerators in Denmark will need to close, however, because many of the facilities were financed and/or owned by local municipalities, central government is having to offer financial incentives for incinerators to close.
A lack of product policy
The next thing to mention is product policy here in Aotearoa. I’ve noticed things on sale here that would be unnaceptable or restricted in Europe, including poor-quality appliances and non-recyclable packaging. Another concern is the large number of abandoned cars on paddocks and properties across the country. In Europe they have to be de-polluted of their fuel, oils, and batteries in licenced facilities. The producers pay for their collection and treatment under the End of Life Vehicles Directive, partly to avoid problems created by scrap metal market fluctuations. I was also concerned to see that hazardous substances, like Chrome Copper Arsenic used on timber, are still allowed here, having been effectively banned in the EU since 2004, and bizarrely, refrigerants (many with extremely high global warming potential) are only partially treated, and even then, outside the fledgling e-waste regime – something that is holistic and far more comprehensive in Europe.
Product policy, in its most holistic sense, is fragmented and incomplete in New Zealand, with only partial coverage of key product groups in terms of product stewardship (PS) schemes; different approaches to these schemes where they do exist; a focus on waste management at end of life; and a lack of coordination between related schemes. As yet, there are very few policy instruments in New Zealand to help drive product circularity at the top-end of the waste hierarchy, and to reduce demand for new products made from virgin materials. As Eunomia studies have recently shown, even the very highest levels of material recycling will not be enough to ensure that a 1.5 degree increase in average climate temperatures is achieved. A CE for products can make a major contribution to accelerating the reduction in emissions and resource depletion, as well as creating local jobs.
Whilst I understand that things have improved, with the introduction of regulated PS for priority products, it still seems a relatively weak system with a number of key gaps, in particular that:
- Some intensive carbon sectors are still missing (some not even in development), including vehicles (which could be integrated with the large batteries scheme), textiles and shoes, mattresses, furniture, construction, and potentially food (although not normally subject to EPR, it could be used to help develop infrastructure);
- The Government sets no targets for the schemes, which seems like a serious problem in terms of driving progress – all EU legislation has progressively tougher targets, year on year; and
- A lack of strong central Government governance - the Gazette Guidance is not currently mandatory and somewhat incomplete, as are the WMA criteria, and existing vested interests take the lead in the ‘co-design’ of most of the PS schemes.
The importance of product stewardship
Product stewardship in the WMA is, however, framed in a way that could be a vehicle for a suite of policy measures, going far beyond simple waste management cost recovery, and working in combination to drive the circular economy. This needs the Ministry for the Environment (MfE) and Ministry of Business, Innovation and Employment (MBIE) to work together, to bring the top end of the waste hierarchy together with an invigorated green sector in New Zealand. This needs to happen to make the most of CE business models - creating economic growth and skilled jobs in reuse, repair and remanufacture, as well as recycling (the last resort in CE terms!)
To make some of this happen, I’d like to see New Zealand follow EU/European good practice:
· Mandatory ecodesign minimum requirements for ‘durable’ products and buildings, removing the worst products from the New Zealand market. Design for recycling/disassembly, recycled/bio-based content, material/product ‘passports’ (on chemical content), tighter controls on hazardous substances, and minimum warranty periods; that follow the EU approach, including the new EcoDesign for Sustainable Products Regulation planned for 2023.
· Mandatory minimum requirements for PS schemes, in line with EU Extended Producer Responsibility (EPR) requirements under the 2018 Waste Framework Directive, and European good practice. This would include mandatory target setting for PS schemes (standard in EU Producer Responsibility Directives), including ‘preparing for reuse’/’reuse targets’ as well as recycling targets, and the use of financial incentives (e.g. eco-modulation of fees) to drive eco-design progress beyond the minimum requirements noted above.
· Formal Green Public Procurement (GPP), using established criteria from other jurisdictions to help drive the markets.
· A virgin fossil plastics tax on single use plastics, not just in packaging, to stimulate plastics recycling/circularity – as per the UK, Italy and Spain.
· A simple consumer eco-label for all products, along the lines of the Australian Healthy Food 1 to 5 index, that utilises relatively simple common-sense criteria including embodied carbon, recyclability/reusability, water use, and free warranty period.
· More hands-on support for businesses to accelerate their move to CE or circular economy business models (Zero Waste Scotland offers a good example of this).
I’ve heard it expressed that New Zealand is a small market and it cannot influence global manufacturers and brands, but we know from our experience at Eunomia that what these companies want is global harmonisation and a level playing field. It’s not so much about the small market size, but rather about another respected nation lending weight to the argument by calling for the same requirements as set out in Europe – ensuring New Zealand avoids becoming a dumping ground for products and packaging that don’t meet higher international standards. There is an argument that low-income Kiwis need low-cost products, but what they don’t need is the exploitation that poor quality products represent – requiring repeat purchases and generating extra waste. They need affordable, good-quality products, new and re-made, which is something else that the circular economy can bring.
On packaging, it is not such a surprise to see how compostable packaging, which rarely - if ever - gets composted, is being used as an excuse for perpetuating human kind’s obsession with convenience at any cost. It would also be great to see something along the lines of the EU Single Use Plastics Directive, and the French Anti-Waste Law, banning all inappropriate and unnecessary single use items across New Zealand, where reuse and refill make more environmental sense.
A lot of the good practice is already here, but often only in local initiatives or partial solutions. Local councils, and some bigger cities, are asked to do an awful lot with very little expertise or money. New Zealand is a small country with limited resources, and in my view it needs economies of scale, and national and strategic solutions. These solutions must still find room for, and harness, the local community experience and the guiding principles of Te Ao Māori. EPR, as part of wider product stewardship, is one way to bring finance to build the better waste and circular economy infrastructure that is so sorely needed, without the need for increased local or national taxation.
Action is needed now
This has to happen quickly, given the ‘lost years’ of the 2000s and 2010s. Yet the timescales around the new Waste Strategy and WMA (both delayed), and the PS schemes seem relatively slow, with the postponement of the CRS another disapppointment. It seems that New Zealand is perhaps 20 years behind Europe in some ways, but has the opportunity to leapfrog to the present – avoiding the mistakes of the past. We are in an extremely serious situation globally with climate change currently likely to hit +2.4C or more, with catastrophic consequences if we don’t do more, and quickly. We are now only talking a five-year remaining carbon budget, with carbon emissions globally still rising. The recent Auckland floods and cyclone emphasise this, and while some things cannot be rushed, there does seem to be a real need for clear and science-driven regulation with real teeth and a sense of urgency, to drive a more rapid move to a genuinely circular economy for New Zealand. And I’d very much like to be here to see that happen!
Author: Mark Hilton, Eunomia
Mark is an aeronautical engineer by background and has a master’s degree in environmental engineering and 39 years of experience in industry and environmental consultancy. He specialises in resource-efficiency, circular economy, sustainable procurement, product stewardship, eco-design and environmental training and behaviour change. Mark will be presenting at the WasteMINZ Conference, Expo + Workshops in May.