QUICK SUBMISSION
Part 1: Container Return Scheme
1. Do you agree with the proposed broad scope of beverage container material types to be included in the NZ CRS?
NO
The scope is too wide and does not require the materials included to be fully processed in Aotearoa. It is important (whether the containers are being reused or recycled) that we localise and decarbonise the entire lifecycle. The scope of material types should be limited but more priority should be placed on containers which have the ability to refillables which can be washed and reused indefinitely.
We also strongly recommend that all beverage containers, including those eligible for the scheme are limited plastic types or plastic free. The toxicity of plastic and plastic lined materials limits reusability. Aotearoa’s current onshore recycling capability and market for recycled plastic is limited and therefore can not be a closed loop material. A limited selection of plastic containers should only be accepted as long as they exist in our society, but should be phased out.
We believe consideration needs to be given to where the containers go after being processed through the CRS, we do not want to continue to send our recycling overseas, running the risk of polluting other countries. With the CRS expecting higher results of recycling the risk of transferring our problem to another country is high. We ask our government to consider banning the importation of plastics and recyclable material that can not be recycled on shore. We also ask that support be given to build and expand infrastructure within New Zealand to support the process of recycling recovered materials and reduce overwhelming existing infrastructure with high recovery rates.
Challenge breeds innovation and we will not see the required shift until high standards are required on the materials we allow to be used in Aotearoa.
2. Do you agree with the proposal to exempt fresh milk in all packaging types from the NZ CRS?
NO
New reuse systems with milk sold in refillable glass or metal containers are re-emerging across Aotearoa and should be included. As one of the most commonly used beverage containers, we should find a system that allows it to be returned, with the cost taken from the profits of the major companies instead of placed on consumers.
3. Do you support the proposed refund amount of 20 cents?
YES
This should be reviewed regularly to ensure it stays relevant through inflation, and strikes the right balance so consumers continue to be willing to return their packaging for the refund.
4. How would you like to receive your refunds for containers? Please answer all that are relevant and select your preference.
All options except vouchers should be available. Vouchers should be excluded as they limit where users can spend their refunds; the system may be exploited in this way. Vouchers also promote unnecessary spending.
Further consideration should be given to how those who are paying a deposit, but putting their containers in kerbside recycling are impacted. The proposal mentions the reduction of costs to ratepayers, but with the additional cost when purchasing beverages there is a clear disconnect for those using kerbside recycling rather than the CRS. Can it be guaranteed that councils could reduce rates? Even then, this would impact homeowners primarily (it wouldn’t likely be passed on to tenants) and would be applied universally. A clear communication strategy to educate the public on the different advantages of both kerbside and CRS will be critical.
5. Which types of location/s would you find the easiest to return eligible beverage containers to? Please answer all that are relevant and select your preference.
Strongly preferred: Waste transfer stations, community centres/hubs, supermarkets, community recycling/ resource recovery centres
Preferred: Commercial recycling facilities, local retail outlets which sell beverages, shopping centres and malls
6. Do you support the implementation of a Container Return Scheme (CRS) for New Zealand?
If you do not support or are undecided about a CRS, would you support implementation of a scheme if any of the key scheme design criteria were different? (eg, the deposit amount, scope of containers, network design, governance model, scheme financial model, etc). Please explain.
YES,
However, given how late New Zealand is in the game, great efforts should be made to implement reusable and refillery options alongside or within the CRS system. This would advance NZ’s waste efforts and work towards dropping NZ from being one of the most wasteful countries in the world.
7. Do you think refillable beverage containers should be included within a scheme in the future?
YES,
The CRS scheme is a great system that can offer a way to incorporate resubales, and we believe it should be the main objective of the system. We no longer see recycling as an effective option and is not where our priorities as a country should remain. There is no question that refillables should be required, by 2025 we expect there will be an increased awareness and demand for reusable infrastructure. A refillables target should be set from the beginning alongside the diversion targets to reflect a commitment to develop and plan for refillerys.
The options we believe would be most effective for the Government to promote and incentivise the uptake of refillable beverage containers and other refillable containers more broadly are:
Part 2: Improvements to kerbside
1. Should all councils offer kerbside recycling to households?
YES
But there needs to be clearer instructions on how people can ensure the recycling they put out is suitable for being recycled, more accessibility to information about recycling, and also the general understanding that recycling is not the best or most reliable practice for people to reduce their environmental footprint.
2. Should all councils offer kerbside food scraps bins so that food scraps can avoid going to landfill?
YES
It must be mandatory for councils to offer this service. It must be unacceptable to send food waste to landfill considering we know the negative effects and have alternatives. Kerbside collection is not the only option however, consideration should also be given to alternative options and councils should be able to explore and trial these. For example, home or community composting.
3. We propose that towns with populations of 1,000 plus should have access to these collections. Do you agree?
YES
4. Please tick below all the items from the list below which you agree should be accepted in household kerbside recycling collections.
Items included must be recyclable in Aotearoa. This means processed in Aotearoa and not sent off shore.
5. Are there any other materials which should be accepted in household kerbside recycling collections?
Items included must be recyclable in Aotearoa. We cannot continue to allow our recyclables to be sent overseas, exporting the negative impacts. There is no guarantee the recycling we are sending off shore is being recycled. In Lydia Chai’s open letter she talks about the impact New Zealand’s recycling has had on Malaysia, where our exported recycling is illegally burned and has terrible consequences.
It is no longer acceptable for our government to ignore these consequences. Despite these great proposals, we need to put deeper consideration into the top of the waste hierarchy. We need to refuse importing or creating items that become a disposal problem for the consumer, our environment or that of the receiving country.
https://our.actionstation.org.nz/petitions/stop-sending-our-plastic-waste-to-developing-countries
Part 3: Separation of food waste
1. Should all businesses also be expected to separate food waste from general rubbish?
YES
Businesses should be expected (to the point of being socially required) to divert food waste from landfills. An outcome of this will be reduced emissions, but this isn’t the sole way it should be framed. For example - this should be framed as “Businesses are expected to divert food waste from landfills as part of their environmental responsibilities”.
We do not think it is enough to assume businesses will be more motivated to “push up the waste hierarchy”. As we have already learned, for many businesses, profit is the sole objective, and assuming all businesses will work towards something altruistic is naive. Reducing food waste at its source is critical, and will be helped by education, further regulation, and societal understanding, which is already growing.
Additionally, there are many great existing organisations that divert food waste through redistribution of edible food. This includes Everybody Eats, Food Print and Kaibosh as examples. They divert food from landfill, and also provide the public with affordable food options which are being used more due to rising living costs. These organisations would need support and time to expand their service offerings to cover more clients but would be able to provide businesses with alternative options to composting that benefit the public. These should be wholeheartedly supported by local and central governments.
Considering many organisations are already making active efforts to divert their food waste all of this can feasibly be implemented before 2030.
2. Should any types of businesses be exempt?
NO
There is no reason why any business should be given an exemption. MftE must not allow businesses to opt out of protecting our environment and doing everything they can to assist with eliminating our dependence on landfills. If exemptions are given out this risks businesses finding loopholes to exempt themselves due to cost and effort to make changes.
We strongly disagree with any limitations based on population. Composting on a small scale does not need expensive infrastructure - it just needs communities to come together and be assisted to find solutions. Further, composting has always been managed by individuals, households and communities, long before landfills or anaerobic digestion were invested in. There is no need to reinvent the wheel, or exclude populations who have always been at the core of this movement.