Compostable packaging has significant value in the packaging system in specific applications where it can bring nutrients to composters for composting, thus diverting organic waste from landfill. Globally, diverting wasted food from landfill is a priority. In New Zealand (NZ), our Climate Change Commission recently declared organic recycling a top priority for reducing carbon emissions in the waste industry, alongside capturing more methane from landfills.

“Compostable packaging” incorporates a wide range of material types used in a variety of applications.  However, some applications are not globally considered as best practice for the generally accepted “use case” for compostable packaging.

In this consultation document we aim to discuss:

• The system for compostable packaging in NZ
• Some existing international use cases for compostable packaging
• The NZ position previously published by WasteMinz Organic Materials Sector Group in 2016
• The range of existing compostable packaging materials and applications in the NZ marketplace, and,
• A proposed use-case for all stakeholders to work from as a step towards a working system for compostable packaging in NZ

Consultation closing date: 30 June

Download the consultation document

How to make a submission

Simple submissions with answers less than 50 words per question may be submitted through our online survey.

Fill in the short submission

For more detailed submissions, please email your submission, preferably in a word document.

Emailed submissions will need to include the following information:

• First and last name
• Email address
• Company or organisation you represent (if applicable)
• Part of the supply chain you represent:
  • Manufacturer from raw materials
  • Manufacturer from imported materials
  • Packaging distributor
  • Brand owner importing packaging for own goods
  • Brand owner using packaging from distributor/manufacturer
  • Brand owner of a compostable product
  • Waste management company/organisation
  • Local body
  • Industry organisation
  • Compost facility
  • Consumer
  • Other

Email your detailed submission

Next steps

Following the closing of the consultation, we will be analysing the results and publishing a summary document which will include recommendations.

The survey, conducted in early March by Horizon Research for The Packaging Forum, also found more people believe there is a problem with litter where they lived, compared with a year earlier.

The survey spoke to over 1,200 people about public place recycling and rubbish bins and found the number of people who have access to public bins continued upwards to 2.4 million adults (66% of respondents). This was an increase of 2% on 2020 and 25% from the first survey in 2014.

Bins to make recycling easier, better

The Packaging Forum CEO Rob Langford says they have been working over recent years to rollout new colour-coded bins which help making recycling and disposing of rubbish easier to get right.

“There are a lot of people who want to do the right thing and recycle, but don’t have the information to do so correctly which causes unintended contamination issues. With the right information they have the potential to have a hugely positive impact.”

While awareness of these colour-coded bins declined slightly to 50%, it was still well up from 37% in 2019.

“The Covid-19 pandemic has had an impact and the research shows a drop in awareness where the bins were removed during lockdown but have not been returned,” Rob says.

It was very encouraging to see awareness was highest among people aged 18 to 24, he says. “Those aged 75 and over had just as much awareness, so it’s the group in the middle where more focus is needed.”

The colour-coded bins have continued to be very effective, Rob says, with 81% of people reporting they made knowing what to recycle and what to put in the rubbish easier. “This has been the consistent response over the past three years, so the design is working.”

More litter, less effort

He says it was interesting to see that while litter was perceived as more of a problem, with 34% people agreeing it was (up 5%), individuals were less likely to make an extra effort to use public bins. The report showed 28% of people would walk more than 40 metres to find a bin, down from 37% in 2020.

However, while attitudes towards telling someone else to pick up litter they had dropped changed little from 2020, people were slightly more likely to pick up litter themselves – up 3% to 39%.

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.

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.”