Business isn’t known for welcoming government regulation, but the news that plastic packaging will be regulated is cause for celebration by all of us who care about our impact on our environment.

That includes businesses already contributing to better environmental outcomes for their packaging and shouldering the cost through voluntary stewardship schemes. Regulation allows for the removal of ‘free-riders’ – businesses which have previously not participated.

Now all Importers, manufactures and brand owners whose goods use plastic packaging will have to contribute to schemes that address its environmental impact. So work begins designing what effective regulated product stewardship looks like in New Zealand. The Packaging Forum members are up for the challenge.

Where packaging already has a voluntary stewardship scheme, (such as The Packaging Forum’s Soft Plastic scheme), they can work to transition to a regulated model. With everyone on board, the opportunity to scale up the impact with more comprehensive solutions is exciting. For packaging types where no scheme exists (e.g. rigid plastic packaging), they will have to be designed.

We are looking forward to working on behalf of our members with the Ministry for the Environment, local government, the resource recovery sector and key community and industry groups on scheme co-design.

I believe there are clear criteria that contribute to success for a product stewardship scheme.

Whole of life cycle, circular approach

The most successful schemes don’t just deal with end-of-life solutions and aren’t just collection systems. They have whole life cycle approach. They encourage product design that removes unnecessary packaging and promotes materials which have a higher recycling value. Other aspects of the life cycle they can address are effective collection, processing infrastructure and demand for material with a high recycled content. In some cases, reusable or refillable packaging may be part of the answer.

Our Soft Plastic Recycling scheme highlights the importance of this approach. When popularity with consumers and collections quickly outgrew processing capacity, the scheme had to be temporarily suspended. New processors were found onshore who worked to develop end markets for their recycled products. The scheme is now back up and running in 74 locations across the North Island, and looking to expand further as new processing capacity develops.

Business led

Regulation simply sets the scene for solutions. Business will provide the mechanisms, infrastructure and innovation for them to be carried out. Business must lead the co-design of schemes in collaboration with local and national government, the resource recovery sector and key community groups.

Our Glass Packaging Forum scheme has shown that collaboration with key stakeholders for investment in pragmatic solutions can have a big impact. Our grant funding to bolster efficiencies in the South Island saw over 340% growth in the volume of glass returned for recycling through one processor alone between 2017 and 2019. It’s investment like this that has helped it reach a recovery rate of over 70% of container glass for recycling and reuse.

Easy for consumers

While there will always be people who choose not to recycle, the more convenient it is, the more likely they are to do it. Whether it’s access to kerbside recycling, clear and useful recyclability labelling, or colour-coded recycling bins in public places, consumer engagement is a must-have in any stewardship scheme.

Onshore solutions

We’ve seen what happens when there is too much reliance on overseas recyclables markets. A lack of onshore capacity left New Zealand and much of the world exposed and sending recyclables to landfill when other countries effectively shut the door. Taking responsibility for our own packaging onshore isn’t just the right thing to do, it’s an investment in employment opportunities and New Zealand’s economic resilience.

The right packaging choices protect our food, our goods, and us. Now we have an opportunity for those choices to keep our environment safer from harm too.

His comment is in response to Greenpeace’s statement shortly after the announcement they were disappointed, “the new scheme doesn’t tackle one of the country’s biggest plastic pollution problems – single-use drinks bottles.”
The Packaging Forum is the country’s biggest packaging industry member-based organisation.

The remarks follow the announcement by Associate Minister for the Environment Eugenie Sage that six product categories, including plastic packaging, have been declared priority products under the Waste Minimisation Act. This triggers the creation of regulated product stewardship schemes to manage these products throughout their lifecycle, especially at end of life through reuse, recycling or proper disposal.

Rob says single-use plastic beverage containers do fall under the category of ‘plastic packaging’ announced by the Minister. “It’s important to understand no regulated product stewardship schemes have yet been established for the multitude of packaging types which are affected.

“A container return scheme is being developed as a possible option for stewarding beverage containers, which I am involved in, but the group working on this is yet to report to the Ministry. The announcement made by Minister Sage was about what would be included in regulated stewardship schemes, not how they would be stewarded.”

The Forum had welcomed the announcement as regulated stewardship is a highly effective way of dealing with packaging and is the most significant move to date by a New Zealand government in the war on waste, Rob says.

“Successful product stewardship schemes are not just collections systems. They must address the entire lifecycle of packaging material – including product design that minimises waste, collection systems, labelling that is clear and meaningful for consumers, onshore recycling infrastructure, through to genuine and valuable use of recycled products. A circular, evidence-based and industry-led approach is critical,” he says.

The Packaging Forum set up soft plastics collections in 2015 and the scheme received accreditation as a voluntary product stewardship scheme under the Waste Minimisation Act in March 2018.

Chair of the scheme Malcolm Everts says that the collapse of global markets for mixed plastics forced a major re-set of the scheme in 2019 and this has been further influenced by COVID-19 limiting collections and processing for a period of time.

“Our scheme is focused on supporting local processors. Two years ago, there was no onshore processing of post-consumer soft plastics. Today there are two North Island plants Future Post in Waiuku and Second Life Plastics in Levin which are great examples of Kiwi ingenuity and we are increasing every month the tonnes which we send for recycling.

“With the expansion of their capacity we can now offer soft plastic recycling to around 60% of the population with drop off points across Auckland, Waikato, Northland, Bay of Plenty and Wellington. We will be adding more stores in more regions throughout the year.”

“As a voluntary scheme, we already have over 70% of industry by volume funding the recycling programme and membership has increased by 20% in the past year to 75 companies. We are also working with members on the design of their packaging, reducing creation of plastic packaging waste, and advocate using our “return to store” labelling system.”

“Scheme members’ levies fund collections from stores, quality checks, baling, transport to end markets and contribute to the processing costs as well. This is different from the traditional model where the processor pays the collector/recycler for the materials, so we are well prepared to transition to a regulated scheme model.”

“We hope to see soft plastic recycling processing projects funded in this year’s Waste Minimisation Funding Round and through the proposed $124 million investment in recycling announced by the Government earlier this month. It is only with a substantial increase in processing capacity including the South Island that the Scheme can deliver its full potential”

“We will work with the Ministry for Environment to develop a sensible co-design process to transition our voluntary product stewardship scheme to meet the new regulations over the next three years. In the meantime, it is business as usual for our scheme.”

For this reason, the country’s biggest packaging industry group, The Packaging Forum, backs today’s packaging announcement by Associate Minister for the Environment Eugenie Sage. Under the Waste Management Act 2008, plastic packaging will be declared a priority product.

The declaration allows for new regulation that will require all importers, producers and retailers to take responsibility for their packaging under a product stewardship model.

The Forum’s Independent Chair Rob Langford says regulated stewardship is a highly effective way of dealing with packaging and is the most significant move to date by a New Zealand government.

“However, there are pitfalls” he says. “That’s why it’s crucial that solutions are developed and led by business, in consultation with other stakeholders,” says Rob. “Effective solutions require not just the right regulations, but the mechanisms, infrastructure and innovations that business can provide to solve challenges throughout a product’s life cycle.

“Successful product stewardship schemes are not just collections systems. They must address the entire life cycle of packaging material – including product design that minimises waste, collection systems, labelling that is clear and meaningful for consumers, onshore recycling infrastructure, through to gueniuine and valuable use of recycled products. A circular, evidence-based approach is critical.”

Packaging Forum members have been funding voluntary solutions for packaging for a number of years. This includes the only government-accredited schemes for glass bottles and jars, and for soft plastics, alongside delivering the public place recycling initiatives such as the Litter Less, Recycle More project.

“While our voluntary schemes have achieved great results,” Rob says, “regulation shouldallow us to step up the scale of impact by by allowing for the removal of free-riders – those brands that currently choose not to contribute.

“We will now work to transition our voluntary schemes to comply with new guidelines for regulated schemes when they are issued.

While beverage containers were not announced as a priority product today, they were included in the initial consultation.

There is a working group looking at a Container Returns Scheme (CRS) for beverage packaging, however we believe glass, which already has a recovery rate of over 70% and an established onshore recycling solution, should be excluded from any CRS. We are already working on an alternative whole of life cycle model for glass that we are confident will cost consumers substantially less than a CRS scheme.

“We also look forward to working with Ministry for the Environment, local government, the resource recovery sector, and key community groups on co-designed and regulated solutions for packaging types that currently have no stewardship scheme in place,” Rob says.

The Forum accepts there will be a cost to business and ultimately consumers, but believes doing nothing comes at a high price to our environment and future. With regulation bringing the entire industry to the table, they say solutions will be robust, efficient and cost effective. Most importantly, if well designed, they will deliver better environmental outcomes for New Zealand.

This according to the country’s biggest member-based packaging organisation, The Packaging Forum. The Forum’s Independent Chair Rob Langford says it fully supports the decision and also welcomes the announcement of $124 million in Government investment in recycling infrastructure.

“This investment is a clear signal that Government is serious about working with industry to reduce waste and increase onshore recycling infrastructure that will create jobs for New Zealanders. It isn’t simply making it more expensive to dispose of waste but wants to develop solutions which decrease the amount of waste generated in the first place,” Rob says.

“This aligns with The Packaging Forum’s goal, which is to work with its over 200 member brands to help them make all their packaging reusable, recyclable or compostable by 2025.”

The Packaging Forum and the Glass Packaging Forum, a stewardship scheme run by The Packaging Forum, made submissions to the Ministry for the Environment earlier this year in support of the increased waste levy. “We are very pleased to see what has been announced aligns with our recommendations to the Minister,” Rob says.

The Packaging Forum operates three government-accredited voluntary product stewardship schemes – the Glass Packaging Forum, Soft Plastic Recycling Scheme and the Public Place Recycling Scheme.

Disincentivising waste through a higher levy, while using the funds generated from it to develop waste reduction projects and infrastructure is a sound approach to tackling New Zealand’s waste problem, he says.

While The Packaging Forum believes the same system of levying should apply across the board, it would also like to see a lower levy for specific by-products of recycling. “It’s important the levy doesn’t disincentivise recycling activity carried out within New Zealand, creating employment opportunities,” Rob says.

The Forum also encourages the Ministry to develop a national waste levy investment plan, focused on the recovery of recyclable resources, so there is transparency about priorities. Additionally, it believes the allocation system for funding should be reviewed so funding is based on projects and their impact, not on a per-capita basis.

“Investment needs to be smart and strategic to achieve the best possible resource recovery outcomes. This goes hand-in-hand with improved tracking and measuring of waste data through robust, independent and transparent methods.”
We look forward to working with the Ministry for the Environment on an investment plan for high quality, onshore resource recovery solutions, Rob says.

Read More: The Packaging Forum Newsletter – Winter 2020

With one of the highest per-capita urban waste disposal rates in the world it’s clear we aren’t leading in terms of waste reduction – yet. While it’s easy to point the finger at consumers, it’s producers that have even more responsibility, and the ability, to pivot away from the take-make-waste, linear economy. This will in turn give consumers the ability to support a sustainable, efficient and regenerative circular economy.

The key means to achieving this is through extended producer responsibility (EPR). So, what is EPR and how is it different from product stewardship?
It’s a practice whereby importers and producers of products bear a significant level of responsibility for the impact their products have on the environment, not just at the end of their life, but throughout their lifecycles.

This involves upstream impacts like the selection of materials for the products, and impacts from the production process. It also includes downstream impacts from the distribution, use and disposal of the products and packaging.
Producers practicing EPR design their products to be environmentally friendly throughout their life cycles. They accept legal, socioeconomic or physical responsibility for environmental impacts that cannot be removed by design.

If this is sounding strikingly similar to product stewardship, it’s because the two are technically the same thing – in that producers take responsibility for the products they make and sell at end of life. However, EPR takes a broader approach to the material being used.

The cost of recovering and reusing, recycling or properly disposing of a product at the end of its life needs to be equally distributed through the supply chain. In other words, the material must own the cost of its recovery.

EPR assesses the lifecycles of the materials being used with the aim of ensuring they are cradle to cradle and challenging the use of materials which are cradle to grave. This approach drives product design centred on easy recovery and reuse or recycling as well as more efficient resource use.

Every material is different and simply overlaying a source separation collection model such as a container return scheme (CRS) will have unintended impacts, unless the full material balance is clearly understood.

It’s about understanding that creating less waste isn’t simply about using less, or maximising recycling rates, it’s about avoiding waste through smarter design and improved efficiency. It’s time to challenge the concept of waste reduction and pivot thinking to maximising resource value.

The packaging industry supports a move to an environment which drives the right material use and recovery behaviours, as well as a framework which provides clarity for investment. We also recognise that Government has a role to play in putting in place effective, evidence-based policies and regulatory drivers to support development. Industry has the innovation and expertise to take the lead in shaping solutions that work. But it takes collaboration.

The Glass Packaging Forum’s (GPF) government-accredited product stewardship scheme for glass bottles and jars is an example of moving towards effective EPR. Producers not only take responsibility for the glass containers they make, import and sell, but invest in efficient design such as bottle light-weighting, and using glass which falls into the three colours which can be recycled (clear, brown and green).

The next logical step towards true EPR isn’t simply about effectively recycling glass made from virgin material, but rather producers choosing to use glass containers which already have a substantial recycled component. This way the issue of using virgin material is addressed in favour of a cradle to cradle, circular, flow of resources.

Some producers also support and encourage the refilling of containers where possible, with the product and system design key factors in enabling easy reuse.

The GPF is an example of stewardship working. It’s also an organisation that’s evolving its own model, with a focus on how to deliver a fully costed cradle to cradle EPR solution for glass.

The Packaging Forum, together with our members, is working hard to enable the industry to pivot towards EPR solutions. At the core of this is the Forum’s Pledge 2025 in which we are working towards comprehensive stewardship solutions delivered by industry, in partnership with the whole supply chain, including local and central government and communities, so all packaging will be reusable, recyclable or compostable by 2025.

We hope you will join us as we strive together for a packaging waste-free New Zealand.

The Forum was responding to the recent call by Greenpeace which would see all plastic bottles replaced with alternatives such as glass or tin. The issue, says the Forum’s Programme Manager Adele Rose, is that while the idea of a ban is well meaning, it would create as many unwanted issues as the ones it aimed to solve – plastic going to landfill and litter.

“The entire lifecycle of different materials needs to be taken into consideration, such as overall carbon footprint, onshore recycling infrastructure capability, and health and safety, not just the end of life,” Adele says.

All packaging material types have their challenges at end of life, which is why the Forum supports the development of circular economy solutions based in New Zealand for all packaging material types, she says. The circular economy sees resources reused, repurposed or recycled rather than sent to landfill.

“Our members are committed to taking responsibility for their packaging and we have pledged to work with them to make all their packaging reusable, recyclable or compostable by 2025. Even then packaging waste could end up in landfill or as litter if government policymakers and consumers don’t also play their part.”

A ban would bring a multitude of issues into play, Adele says. “Consider how many products are imported into New Zealand in plastic bottles between 100ml and 3 litres. There are many products which aren’t sold at dairies or supermarkets, such as supplements used for medical purposes and sold at pharmacies, which would be included,” Adele says.

“Government would also have to consider issues such as the impact the ban would have on free trade agreements, as just one example.”

The Packaging Forum, which includes the Glass Packaging Forum, Public Place Recycling Scheme and Soft Plastic Recycling Scheme, agrees with Greenpeace that more can and should be done to deal with the issue of plastic pollution and littering. Public awareness and changing people’s attitude to plastic is key, Adele says.

“We are absolutely for ending packaging waste – it’s our core driver – but it needs to be done using a collaborative approach involving industry, Government and the consumer.”

The report is an annual requirement of its Government accreditation and demonstrates industry’s long-term stewardship of glass.

GPF Scheme Manager Dominic Salmon says work was focused on consolidating gains made over the previous year, particularly removing barriers to glass recycling through improvements to infrastructure, with two primary areas of focus. These being financially supporting improved glass recycling outcomes through grants, and building relationships between glass packaging manufacturers, importers, fillers, and sellers and those who collect and recycle glass.

“Our success this year was due to relationships with our members, councils, community groups, transport operators and end market users,” Dominic says.

“Profile is critical to the scheme’s success and every effort has been made to promote the infinitely recyclable nature of glass right here in New Zealand.”
Mass balance for the year showed a total glass capture rate of 73% of all glass going to market. Of this 71% was recycled – a 9% increase on the previous year – while 14% went to roading, 6% was stockpiled and 7% went to landfill.

Data improvement was a major focus this year, and will remain so, but with the scheme being voluntary it’s accepted the whole picture cannot be known. “As a voluntary scheme there is no obligation for the relevant parties to provide the required data, so it’s an on-going challenge to ensure the majority of glass handled at the various points of its life cycle are accounted for,” Dominic says. “However, we continue to look at ways we can improve our data quality.”

As part of a ‘let’s talk’ approach the GPF achieved a survey engagement response rate of over 60% from both industry and local government. This saw the scheme achieve its 2024 target for survey engagement rates.

Grant allocations were focused on “sensible infrastructure” such as glass storage bunkers and collection of glass for recycling to improve transport efficiency and viability. In total $457,983 was funded for projects ranging from infrastructure to public place recycling, plant and research. This funding helped improve the flow of 11,000 tonnes of glass.

Dominic says he is pleased with progress and believes the scheme is on track to achieving its future goals, most notably a glass capture rate of over 80% by 2024. “Our current 73% recovery rate is enviable for any material in any part of the world, but by continuing to work with stakeholders we are confident of achieving more.”
Read the full report.