Submissions to Gov on plastic phase out proposals
Industry submission to Gov on plastics phase-out proposal
Submissions have been made on behalf of members regarding the Government’s proposed plastic phase out proposals.
7 December 2020
The Packaging Forum, and its Soft Plastic Recycling scheme, have both made submissions largely in favour of the intent behind the Government’s proposed phase-out of hard to recycle plastics and some single-use plastic items.
However both are concerned about the phase out overlapping work being done on product stewardship, as required by this year’s declaration of all single-use plastic packaging as a priority product. There is also concern expressed about whether the timeframes are achievable. Both submissions support the government’s acknowledgement that some use-cases will require exemptions and want the process around exemptions to be very clear.
In a bid to engage the public, the consultation document was condensed down from 74 pages to an eight-page summary with an accompanying video. People were invited to submit by completing a short survey on the Citizen Space platform.
Ministry for the Environment Deputy Secretary Sam Buckle says more than 5,000 submissions had been received by 1 December, with the consultation closing on 4 December.
Businesses and industry organisations like The Packaging Forum were encouraged to make more detailed submissions based on the longer consultation document, which contained more background and nuance.
The Packaging Forum and Soft Plastic Recycling Scheme responses were formulated by consulting with members via a survey, online meetings and member meetings.
While the Forum’s membership is largely supportive of the proposals, it cautions against the creation of unintended negative consequences and advises a holistic approach be adopted:
- Any phase-out must go together with the development of recycling and end of life infrastructure for alternative materials.
- When identifying materials and/or items for phase-outs it’s important to include full lifecycle analysis of all packaging items (and possible alternatives) as well as food safety aspects.
- Care must be taken to avoid unintended consequences through a largescale move to alternative packaging materials without standards, labelling and end-of-life solutions being in place.
- Alternative materials, such as compostable and fibre (paper and cardboard) packaging have challenges. These include a lack of a New Zealand standard and currently limited recycling or reuse options.
- Where packaging is already managed through kerbside or industry led recycling schemes such as the Soft Plastic Recycling Scheme, there is no need for a ban.
The Forum also raised concerns around five issues:
- A full cost benefit analysis which follows Treasury guidelines is required to asses impact on business, food safety, shelf life and cool-chain (particularly for export items).
- The proposal overlaps with work by industry following the declaration of single-use plastic packaging as a priority product under the Waste Minimisation Act 2008 – requiring regulated product stewardship solutions.
- A lack of alignment with other work, such as the standardisation of kerbside collections.
- More detail is needed for exceptions, such as packaging which maintains the integrity of contents. This is particularly relevant for export items.
- The Forum notes this consultation calls the phase-out a starting point. More certainty is needed on any further phase-outs if business is to invest in replacement technology and processes with a long-term return.
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