Aotearoa New Zealand has a poor record on waste. We have one of the highest per capita rates of landfill waste in the Organisation for Economic Co-operation and Development. Every year, we send around 35,000 tonnes of plastic waste offshore instead of processing it here. Single-use plastic items are lost to landfill, instead of being recycled or reprocessed, or they become litter in our communities, waterways and ecosystems.

Plastic waste ruins the landscape and can be fatal to marine life. We need to take action to protect the environment and enhance New Zealand’s clean, green international reputation that so many of our businesses and communities rely on.

New Zealanders care deeply about this issue and are keen to take action. We saw your passion for solving waste issues after plastic bags were banned in 2019. We saw it again during this consultation, where over 7800 New Zealanders had their say. Thank you to everyone who took the time to make a submission.

Decisions we make today affect the choices of future generations. We have to transform the way we think about, use and dispose of resources and waste. Together, we can create a more flourishing environment for all generations.

From 12 August to 4 December 2020, the Ministry for the Environment (the Ministry) consulted on two connected proposals to phase out certain hard-to-recycle plastic packaging and seven single-use plastic items.

Proposal one includes a plan to progressively phase out all polyvinyl chloride (PVC) and polystyrene food and beverage packaging, all other expanded polystyrene packaging (EPS) and all oxo-degradable plastic products.

Proposal two includes a plan to phase out seven more single-use plastic items following the success of the plastic bag ban in 2019.

For both proposals, the Government has suggested creating regulations to prohibit the targeted plastic packaging and items from manufacture and sale under the Waste Minimisation Act 2008.

The Government received over 7800 submissions. These included substantive submissions (received through our lengthier consultation tool, email and post) and a short-form survey. This report summarises the views expressed in submissions and outlines the main findings, common themes and overall support for each proposal.

The report does not provide recommendations in response to any views expressed. Any recommendations will be made through policy advice to the Minister for the Environment, Hon David Parker.

Key findings – Proposal one

Submitters wanted more action on plastics

Most submitters (97 per cent, 7675) supported more action being taken on plastic in New Zealand.

Most submitters also supported proposal one (96 per cent, 7607). This includes a mandatory phase out for all PVC and polystyrene food and beverage packaging, all other expanded polystyrene packaging and all oxo-degradable plastic products.

Affected industries and businesses cited concerns

Submitters from affected industries and businesses were less likely to support proposal one. They cited concerns over finding suitable alternatives and the additional costs involved in development of and investment in new equipment and processes.

Submitters shared specific challenges relating to items that may be more difficult to replace, such as expanded polystyrene used to transport temperature-controlled food or medicine.

Timeframes for proposal one

A combined 97 per cent of submitters supported the proposed timeframes or wanted timeframes brought forward. Fifty-six per cent of submitters supported the proposed time frames and 41 per cent called for sooner action. General public submitters were more likely to support faster action.

Most plastic industry submitters and manufacturers wanted more time or disagreed with the proposed timeframes.

Key findings – Proposal two

Submitters want more action on single-use plastics

Most submitters supported proposal two (96 per cent, 3705 of substantive submitters). The short-form survey also showed high numbers of support for phasing out each item in proposal two.

Many submitters wanted action on additional single-use items, such as disposable coffee cups and wet wipes (60 per cent, 4780).

Many submitters are concerned about accessibility

Many submitters raised concerns around the accessibility (including affordability) of alternatives to single-use items, if they are phased out. In particular, 42 per cent (3330) of submitters raised concerns around the phase out of plastic straws for disabled people or medical purposes.

Timeframes for proposal two

Of the 820 submitters who commented on proposal two timeframes, 58 per cent suggested they should depend on each item. Business and industry submitters generally proposed a longer phase-out period for some items and general public submitters were more likely to support faster action.

About the consultation

This document reports on the findings of public consultation conducted by the Ministry in late 2020. The consultation sought feedback from New Zealanders on the next steps for reducing the harm of plastics on the environment, proposing a mandatory phase out of several hard-to-recycle plastics and single-use plastic items.

The Government can make regulations under section 23(1)(b) of the Waste Minimisation Act 2008 that prohibit the sale and manufacture of products that contain a specified material. The Government proposed phasing out several plastic items, as discussed below.

Proposals

Proposal one: Phase out of hard-to-recycle plastics

The Government proposed phasing out plastics that are low value or hard to recycle, including:

The phase outs are proposed to follow two stages. Stage 1 would cover all PVC and some polystyrene food and beverage packaging, and all oxo-degradable plastic products. Stage 1 is proposed to occur by 2023.

Stage 2 is proposed to cover most of the remaining polystyrene food and beverage packaging not captured in Stage 1. It could also include other polystyrene, such as expanded polystyrene packaging used outside of food and beverage packaging (for example, homewares and electronics packaging).

Proposal two: Taking action on single-use plastic items

The Government has proposed phasing out seven single-use plastic items including:

Background to the consultation

Understanding plastics

The problem of plastics is vast and complex. Plastic is fundamental to our modern-day lives. It has many desirable properties: it is versatile, durable, flexible, affordable and lightweight. We use plastic for many things, for example, in construction, clothing, food production and distribution, farming, healthcare and packaging.

Poorly managed waste plastics result in significant sources of plastic entering the environment, whether from littering, illegal dumping or escaping from waste management systems. Confusion occurs between different types of plastics, known as ‘polymers’, because some are recyclable in New Zealand while others contaminate recycling, have little or no domestic and international markets, and must be sent to landfill.^{^[1]}

New Zealanders want change

New Zealanders care deeply about plastic waste and pollution and want to do the right thing. The Government often hears from people of all ages from across the country about how plastic waste and pollution concerns them. Yet New Zealand also has one of the highest rates of waste-to-landfill per capita in the Organisation for Economic Co-operation and Development.

Rethinking plastics

In December 2019, the Office of the Prime Minister’s Chief Science Advisor released the report Rethinking Plastics in Aotearoa New Zealand. The report makes several recommendations to help shift New Zealand towards a low-waste, sustainable and more circular economy for plastics.

Following this, the Government announced the intention to shift away from low-value and hard-to-recycle plastics and phase out more single-use items. This is part of a wider ambition to make New Zealand an economy where plastic rarely becomes waste or pollution, and the natural environment and marine life are protected from the impacts of plastic waste.

Consultation process

How we consulted

Consultation tools

To make this consultation as accessible as possible, submitters were able to give feedback through four main channels:

· online substantive submissions, which asked various questions, including some specific to business and industry

How to read this document

Substantive submissions versus short-form submissions

Throughout this report, we refer to two datasets: substantive submissions and short-form submissions.

· Substantive submissions refer to all the long-form submissions, emails and letters.

· Short-form submissions refer to those received through the online survey tool.

Who responded

The Ministry received 7878 submissions to the consultation, which is a strong response. Most submitters were members of the public, reflecting the high public concern about plastic pollution. Of these submitters, 3350 used a common form organised by a non-governmental organisation (NGO) who prepared a template response that people could use.

A good response was received from affected businesses, environmental and community groups, and local government agencies.

Overwhelming support for taking action on plastics

New Zealanders showed high support for more action on plastic waste and problematic plastic items (figure 1). Of submitters, 97 per cent (7675) supported more action being taken on plastics in New Zealand.

Note: The figure includes numbers from both short-form and substantive submissions.

General public submitters were most likely to support the Government in taking more action on plastics

As shown in figure 2, most respondents supported the Government in taking more action on plastics either in full or in part. Members of the public were highly likely to agree.

Note: The figure includes numbers from both short-form and substantive submissions.

In our short-form survey, we asked: “Do you support the Government taking some more action to remove hard-to-recycle plastic and single-use items from use (in principle)?”. Of the 4030 people who responded, 99.35 per cent supported more action to remove problematic plastics from use (4004 yes, 21 no, 5 did not know).

In the short-form survey we asked: “Do you support the proposed mandatory phase out of PVC and polystyrene plastic packaging and all oxo-degradable plastic items?”. Of the 4030 respondents, 96.2 per cent indicated their full support, and a further 2.8 per cent supported in part (3877 yes, 113 yes in part, 32 no, 8 not answered).

What we heard – Proposal one

Strong support for phasing out PVC and polystyrene food and beverage packaging

The support levels for phasing out PVC and polystyrene food and beverage packaging were very high (figure 3). Most submitters supported the proposal.

Note: The figure includes numbers from both short-form and substantive submissions.

Based on submitter type, members of the public supported the proposals (figure 4). Manufacturers, the plastics industry and some recyclers were more likely to disagree with the proposals. These submitters are more likely to be directly affected by a ban. The challenges faced by some of these industries are discussed later in this document.

Note: The figure includes numbers from both short-form and substantive submissions.

Despite the challenges some businesses and industries may face, the proposal does have support within the most affected sectors. Many have already taken steps to remove hard-to-recycle plastic packaging from their supply chains and operations. One industry and business submitter noted:

Additionally, our wholesale businesses … which supply packaging products to other businesses, including the convenience, food service, and hospitality sectors, are now ranging fibre-based alternatives, and are managing a gradual exit from supplying polystyrene packaging. A mandated phase-out of these products would quicken this process as we currently compete with third-parties that pitch the cheaper polystyrene.^{^[3]}

As shown in the previous figures, few submitters disagreed with proposal one and made additional comments. However, one industry group commented on practical considerations for business and industry:

Members have signed up to the Plastic Packaging Declaration which sets targets for 2025. They therefore question why products should be banned before that agreed deadline. Further, without an understanding of how many companies are using PVC and PS packaging, it is difficult to understand whether the time frame is feasible. The likely costs or benefits of phasing out all PVC and polystyrene packaging needs a full and separate economic analysis. For companies that do use these products, multiple packaging lines will need replacing and often an R&D component will be needed. By the time economic insights are drawn, alternative materials and infrastructure are available, and trials are concluded the end of 2022 is impossible and even the end of 2024 is probably not achievable in totality.^{^[4]}

Oxo-degradable items can easily be phased out

Agreement was high that oxo-degradable plastics be phased out (figure 5). The proposal is to phase out all oxo-degradable plastics (not just for food and beverage uses) because they are simply plastics that contain chemical additives to make them break down faster into smaller plastic pieces (microplastics). They are generally not recyclable or compostable.

The Ministry heard that oxo-degradable plastic items are a significant point of confusion for people, with some not understanding what the term means or how to dispose of these items correctly. One general public submitter noted:

… the green-washing associated with these products threatens to undermine the public education that is required to make reuse and recycling models more efficient and free of contaminants.^{^[5]}

Another submitter captured the confusing nature of oxo-degradable plastics stating:

You think you are buying ones that decompose but they are actually still made of petroleum products that just break down into micro plastics. Oxo degradable plastics gone forever ASAP please.^{^[6]}

Oxo-degradable plastics cause public confusion and are relatively new in the New Zealand market. This provides New Zealand with an opportunity to remove these items from its system before they become too widespread.

Most submitters support proposed timeframes, many wanted faster action

The Government proposed the following staged approach to phasing out hard-to-recycle plastics. This is to ensure manufacturers and businesses have adequate time to shift their packaging to sustainable alternatives, while also balancing environmental impacts.

· all food and beverage items that contain polystyrene packaging not captured in Stage 1

Overall, 56 per cent of submitters supported the proposed staged phase-out timeframes of 2023 to 2025 for PVC and polystyrene food and beverage packaging (figure 6). A significant portion of submitters (41 per cent), however, wanted faster action, many preferring a 12‑ or 18‑month phase-out period for all in-scope items. Others called for it to happen as soon as possible.

Note: The figure includes numbers from both short-form and substantive submissions.

Industry and business submitters favour a longer lead-in time

Figure 7 shows that some industry and special interest groups are concerned about the proposed timeframes. They want more time to consider the options, or further engagement with government, suppliers and retailers, to find appropriate and sustainable alternatives.

Note: The figure includes numbers from both short-form and substantive submissions (excluding submissions received from general public submitters).

Manufacturers, the plastic industry, and other industry and business submitters were most likely to either want more time before phase outs come into force or signalled no support for the proposed timeframes.

As discussed in the following sections, some of the concerns raised by individual industries or businesses are related to specific items or uses for PVC and polystyrene in food and beverage packaging, rather than an overall disagreement with taking action on problematic plastics.

Some items are more challenging to phase out, requiring a longer lead-in time

Although most submitters supported more action on plastics, some applications for PVC and polystyrene food and beverage packaging present unique challenges to manufacturers, producers, recyclers and consumers.

Timeframes

We heard calls to stage certain phase outs later than the proposed timeframes, to allow business and industry to find suitable alternatives to specific items that are challenging to phase-out within the proposed categories (PVC and polystyrene). This was echoed by a local government submitter who noted:

PVC and PS/EPS are used for packaging for high value products, medications and to ensure food products are kept at suitable temperatures for transportation. It is possible that exemptions might be needed for medical use if suitable alternatives are not available. PVC is also used in the construction industry for a variety of materials. Phase-out of this packaging may inadvertently lead to increased waste in other high value materials and products.^{^[7]}

Specific challenges for phasing out hard-to-recycle plastics

Flexible types of PVC are harder to replace (for example, PVC cling wrap). This is because PVC has unique moisture and gas transmission barrier properties. This makes it a good packaging material for products like cheese, seafood and meat, particularly where shelf life is important.

We heard from some submitters that hard polystyrene is preferred over other plastic types for some products because it is strong, malleable and can be made to be very thin. Polystyrene also has unique ‘snap’ properties, which allow businesses to present individual portions (such as yoghurt) in break-apart multi-packs. Feedback from industry and business submitters suggests a phase-out is possible but additional costs will be involved in making this change, including for new infrastructure, research and development, packaging redesign and product testing.

Phasing out expanded polystyrene is likely to be more challenging

Beyond food and beverage applications, such as takeaway food containers, expanded polystyrene is used to protect objects during transit, like delicate homeware items, whiteware, larger consumer electronics, and heat pumps. Striking a balance between what is needed and what could be replaced remains challenging for some of these uses.

Some submitters raised concerns about whether expanded polystyrene can, or should feasibly, be phased out. The material is lightweight, capable of protecting goods from collision and impact damage, and has temperature-controlling qualities. This presents benefits to users, but, because it is lightweight, bulky and easily fragments, how we manage, process and dispose of it is challenging. Some submitters (see quote below) believe applications exist where expanded polystyrene cannot currently be phased out without having major impacts on the trade or supply of certain use cases.

…there are not currently, practical alternatives to replace a number of ‘hard-to-recycle’ packaging because we are not seeing these globally. However, the industry would embrace practical alternatives if they emerged commercially.^{^[8]}

Polystyrene and the ‘cold chain’

We heard it may be particularly challenging to phase out expanded polystyrene within the ‘cold chain’. Specifically, this term refers to how expanded polystyrene is used to package and transport chilled products, namely seafood items in small chiller-bin style packaging. This packaging keeps the seafood (or other chilled products) protected during transit and temperature controlled. This is important throughout long supply chains where products can be in transit over several hours or days in varying heat conditions. We heard that, while work is being done to find alternatives to expanded polystyrene, few exist that are viable that businesses could use in the short term. Challenges include finding an alternative that is capable of protecting stock, reserving its quality and food safety, and is not worse for the environment.

…significant concern has been raised by our industry regarding the proposed mandatory phase-out of expanded polystyrene (EPS) transport boxes. A large portion of seafood is distributed in live or chilled form using EPS transport boxes both throughout New Zealand and to many export markets, including markets in China, the United States of America and Europe. Products include live rock lobsters, shellfish, eels and other high value chilled and processed seafood products. The annual export value of live and chilled seafood alone is approximately $530 million…

…live and chilled seafood is extremely perishable and places high demands on packaging during transport. Thermal properties, liquid containment and product protection (requiring a high degree of rigidity), are necessary to maintain the product’s integrity and to ensure high quality, safe seafood reaches its destination.^{^[9]}

What we heard – Proposal two

Widespread support for phasing out single-use plastics

Overall support levels

Support for proposal two was high across nearly all submitter types. Of the 3848 substantive submitters, 96 per cent (3705) agreed in full with proposal two, 1.87 per cent (72) agreed in part, 0.5 per cent (2) disagreed, and 1.6 per cent (65) did not answer (figure 8).^{^[10]} Short-form survey respondents were asked to indicate their support item by item so their data are excluded from figure 8.

Note: The percentages in the figure are from 3780 substantive submissions that talked about their support level for proposal two (excluding responses from the short-form survey, which did not cover this question).

Reasons for disagreement

Four substantive submitters disagreed with proposal two. Two individuals said the seven proposed items should not be phased out because they serve vital functions.[11] Two businesses were concerned about the significant impact that a phase out of one particular item would have on their operations.^{^[12]}

In our short-form survey we asked “Which single-use items do you support for phase out?”. Of the 4022 respondents, 94.29 per cent supported produce bags, 91.89 per cent supported tableware, 96.72 per cent supported produce labels, 96.23 per cent supported drink stirrers, 95.01 per cent supported single-use cups and lids, 87.77 per cent supported cotton buds, 92.93 per cent supported straws (3.03 per cent did not support the phase out of any item, 0.20 per cent did not answer).

The main points raised, and reasons why some submitters did not agree with the proposed phase out of a particular item in proposal two, are summarised below.

Produce bags can easily be phased out

The consultation document proposed a phase out for produce bags, which are under 70 microns thick, without handles, and used for carrying fruit and vegetables.

Many submitters suggested expanding the scope to include ‘net’ type produce bags.^{^[13]}

Of the 3848 substantive submissions, two submitters opposed the ban on produce bags. Short‑form submitters who provided comment around why they did not support a phase out of produce bags said they were useful.^{^[14]}

Tableware can easily be phased out

The consultation document proposed a phase out for plastic tableware and cutlery intended for single use (including multipacks).

None of the 3848 substantive submissions specified if they opposed a phase out of plastic tableware. Many NGO^{^[15]} and individual^{^[16]} submitters suggested broadening the scope for phase out to include plastic-lined tableware (for example, plastic-lined cardboard bowls and containers).

Short-form submitters who commented on why they did not support a phase out of plastic tableware were concerned about the accessibility effects for disabled people^{^[17]} and the environmental consequences that could come from switching to another single-use material (for example, cardboard).^{^[18]}

Significant support for phasing out produce labels, with some challenges

The consultation proposed a phase out of plastic produce labels used on fruit or vegetables sold in New Zealand and made partly or wholly of plastic that is not compostable. The consultation document proposed that produce for export could be exempt if a plastic label is required to meet market conditions.

Wide support, but challenges identified by the horticulture industry

Of the 3848 substantive submissions, five industry submitters did not support the phase out of produce labels and would prefer a voluntary approach. While this is a relatively small number of submissions, they represent key manufacturers and the horticulture industry most affected. Comments from these submitters included:

Fruit stickers play a vital part in food identity, food traceability, brand identity (as all other packaging is being removed) and preventing product fraud.^{^[19]}

Some industry members have committed to have an effective home compostable label solution in market by 2025. Adding a mandatory phase-out legislation on top of the existing positive momentum seems distracting, unnecessary and potentially wasteful.^{^[20]}

Moving to an eco-compostable label, cost increase would be +70 per cent of current costs as quoted by supplier.^{^[21]}

Significant process changes may be required if a phase out of produce labels was implemented. In New Zealand, most major crops are labelled and packed at the time of harvest without always knowing the final product’s destination (for example, exported or sold domestically).

Drink stirrers can easily be phased out

The consultation proposed a phase out for plastic drink stirrers that are made partly or wholly of plastic.

None of the 3848 substantive submitters specified if they disagreed with a phase out of plastic drink stirrers. No supporting comments were made from any short-form submitters who opposed the phase out of plastic drink stirrers.

Cotton buds can easily be phased out

The consultation proposed a phase out for plastic cotton buds made wholly or partly of plastic with cotton wrapped around one or both ends, not designed or intended for reuse.

One retailer^{^[22]} said they have already voluntarily banned plastic-stemmed cotton buds from being sold in their stores. A general public submitter did not support the phase out of plastic-stemmed cotton buds saying they are concerned about the poor quality of alternatives (for example, wooden cotton buds).^{^[23]}

Three short-form submitters who provided comment for why they did not support the phase out of plastic-stemmed cotton buds said they may be required for medical purposes.^{^[24]}

Feedback on phasing out drinking straws is mixed

The consultation proposed a phase out for single-use drinking straws made wholly or partly from plastic and not designed or intended for reuse. The consultation document noted an exemption will be considered to allow access to plastic straws for disabled people and for medical purposes.

Many New Zealanders raised concerns around a phase out for straws

Of the submitters, 3330, including two disability advocacy groups (46 short-form and 3284 substantive), disagreed with, or raised concerns about, a phase out and/or exemption for plastic straws. These submitters were supportive of a move away from plastic waste, but were concerned about the impact on disabled people who may need single-use plastic straws to drink. Comments from these submitters included:

We don’t support banning plastic straws. A plastic straw ban would be discriminatory. Some people need a plastic straw to drink. Reusable alternatives work well for some people, but not for everyone.^{^[25]}

There are currently no alternatives that provide the access features that single-use plastic straws provide. Paper straws in particular are a very poor substitute and are unsuitable for the large majority of disabled people who use straws. Re-useable steel and silicone straws are also not suitable for some disabled people.^{^[26]}

Some submitters were also concerned about the lack of detail around a possible exemption in the consultation document. They suggested further consultation should be held with the disability community.^{^[27]}

Some businesses support an exemption for drink carton straws

Two business submitters suggested that on-the-go drink carton straws be exempt until a practical alternative is found.

Widespread support for phasing out cups and their lids

The consultation proposed a phase out for single-use plastic cups and their lids made from hard-to-recycle plastics (plastics 3, 4, 6 and 7). The proposal included paper cups lined with plastic or bio-based plastics. The proposal excluded disposable coffee cups and proposed an exemption for cups made from recyclable plastics such as PET (1), high-density polyethylene (HDPE_ (2) and polypropylene (PP) (5).

Many submitters disagreed with the scope and wanted it to include more cups and lids

Of the 3848 substantive submitters, 14.62 per cent (510) opposed exempting cups made from recyclable plastics, such as PET (1), HDPE (2) and PP (5), from a phase out. These submitters reiterated the problems such items can cause in the litter stream and that they may contaminate recycling.^{^[28]}

Some local government submitters said the phase out of these cups would result in cost savings. For example, a territorial authorities forum group submitter^{^[29]} commented: “if more people use reusable cups, there will be savings for businesses and less waste and therefore less burden on territorial authorities who bear the cost of a linear system”.

Businesses and retailers support the phase out

Business and retail submitters were generally supportive of moving away from plastic cups that are hard to recycle. They also supported the exemption for plastic cups made from plastic types PET (1), HDPE (2) and PP (5) and stated that, because these items are higher value materials, market demand would exist for their collection and recycling.^{^[30]}

Taking action on other single-use items

The consultation did not propose a mandatory phase out for disposable coffee cups and wet wipes. However, substantive submitters were asked what options could be considered for reducing the use of single-use coffee cups (with any type of plastic lining) and wet wipes that contain plastic.

Many New Zealanders want coffee cups and wet wipes phased out

Of the submitters, 3905 would like disposable coffee cups phased out and 662 would like wet wipes and/or wet wipes that contain plastic to be phased out. Some submitters made other suggestions for reducing the impacts of these items, such as reuse schemes for coffee cups, investing in infrastructure for compostable coffee cups, and mandatory ‘do not flush’ labelling on wet wipes.

A common theme among submissions was the problems these items can cause in recycling streams and wastewater treatment systems. For example, NGO and local government submitters commented:

The waste caused by New Zealand’s coffee drinking culture and the associated costs are significant. The Rethinking Rubbish and Recycling research found that 1288 tonnes of single-use coffee cups are disposed of via councils’ household kerbside rubbish collections with a further 851 tonnes contaminating household recycling bins. In addition, there would be a significant number that are disposed of via public place and commercial collection systems.^{^[31]}

We are extremely disappointed that coffee cups & lids have been expressly excluded from the ban list. The Packaging Forum estimates that New Zealanders use 295 million coffee cups a year. The overwhelming majority get landfilled. Huge confusion surrounds their recyclability and/or compostability. They are also light and prone to escaping into the environment, and their lids are fully detachable, increasing the potential for litter.^{^[32]}

Wet wipes are a significant issue for TAs [territorial authorities], who spend thousands of dollars undoing blockages in wastewater systems. For example, Gisborne District Council [GDC] estimate wet wipes are costing roughly $100,000 per year due to complications they cause for the wastewater network’s operation and maintenance costs. In addition to that, GDC estimate a spend of about $43,500 p.a. for disposal costs at their wastewater treatment plant due to wet wipes, which would be rise under the new waste levy increases. South Taranaki District Council spends approximately $20,000 annually unblocking pipes due to wet wipes.^{^[33]}

These submitters cited various readily available alternatives for these items, particularly for coffee cups. Of the submitters, 3497 commented on the positive effects reuse systems for coffee cups can have. For example, comments included:

We support the Government investing in scaling up reuse systems, such as regional/localised washing/sterilisation facilities, implementing regulatory and policy interventions that remove some of the barriers to reuse schemes growing, including a levy or fee on disposable coffee cups, deposit return schemes for takeaway cups, and mandatory ‘reusables only’ for dine-in contexts and public buildings, providing funding to NGOs and community with track-records of engaging their communities on zero waste as the most efficient way to invest in behaviour change.^{^[34]}

The single-use coffee cup is the item that if phased out would lead to the biggest shift in consumer culture and behaviour toward a more waste-conscious approach. It would also create the necessary infrastructure in the hospitality industry to facilitate a wider shift away from all disposable service ware.^{^[35]}

New Zealanders want more single-use plastics phased out

Many submitters mentioned items not included in proposal two that they would like to see phased out (figure 9).

Note: The figure includes suggestions from both short-form and substantive submitters.

Phase-out period

Of the 3848 substantive submitters, 21.33 per cent (820) mentioned proposal two timeframes in their submissions (figure 10).

Note: Responses in the figure are from 820 substantive submissions that mentioned the proposal two timeframes (excluding responses from the short-form survey, which did not cover this question).

Of the substantive submitters who mentioned proposal two timeframes, 58 per cent^{^[36]} (479) suggested they should depend on each item (figure 11). A common theme among submissions was that timeframes need to consider availability of alternatives and time needed for businesses and manufacturers to adapt.

Business and industry submitters generally proposed a longer phase-out period for some items, allowing time to reconfigure their business, use up existing stock and find alternatives.

Retail submitters suggested changing the phase-out implementation date from January, which is peak trading season for the food and beverage sector.^{^[37]}

Note: Responses in the figure are from 820 substantive submissions that mentioned proposal two timeframe (excluding responses from the short-form survey, which did not cover this question).

Where to from here?

Moving away from single-use items and towards sustainable, reusable alternatives

Submissions argued that, as New Zealand shifts its economy towards being more sustainable, circular and low waste, good reuse systems and products need to be prioritised, to minimise the uptake of single-use items.

Reuse, or reuse systems, were the most consistently mentioned tools for transitioning away from single-use, problematic plastics. Most submitters mentioned reuse or reuse systems. Their comments often called for an increase in the scale, uptake and adoption of reusable alternatives instead of single‑use items. This reflects wider concerns around businesses or consumers choosing to adopt single-use alternatives that have worse, and sometimes unintended, environmental impacts than the plastic items they are replacing. These submitters also noted that regulatory and policy measures should ensure an even playing field exists between single-use items and their reusable alternatives.

The need to focus on reuse over single use was summarised well by one submitter, who wrote:

Facilitating reuse through regulation, policy and investment is key to reducing single-use plastics and plastic pollution, and to avoid or mitigate perverse outcomes of the proposed ban. The proposed policy of reducing single-use plastics must be supported by policy supporting infrastructure and community engagement necessary for reuse i.e. accessible, reusable alternatives and systems to support them (e.g. regional/localised washing facilities). This would allow solutions to move higher up the waste hierarchy, rather than incentivising the switch from one single-use material to another.^{^[38]}

Tools to transition away from single-use
and hard-to-recycle plastics

While a mandatory phase out of some hard-to-recycle plastics was the main focus of this consultation, we also heard about other means for transitioning away from single-use plastics. These ‘tools for transition’ included reuse systems, education campaigns, community initiatives, labelling requirements and economic incentives.

The proposed mandatory phase outs will likely need to be supported by various other tools. This would help ensure people are informed about any regulatory changes, avoid unintended or adverse environmental impacts, and support the uptake of more reusable, sustainable or useful alternatives to single-use plastics.

The adoption of other tools to transition away from problematic plastics would also help support system-level change. Many of the tools for transition that submitters mentioned are already in place to a certain extent, but more work could be done to ensure systemic change. Many submitters reflected on the need for additional support and more or better resource recovery infrastructure, as reflected below.^{^[39]}

Transition plan or roadmap

Many submitters specifically mentioned a need for central government to provide a transition plan or roadmap. This could be produced in conjunction with key industries and based on feedback provided through this consultation. Some submitters noted that a roadmap (or similar strategy) is needed to provide certainty to industry and businesses around which materials should be embraced and which should be phased out over the long run. Similarly, local government and general public submitters signalled they would like more direction around what materials to use.^{^[40]}

Deposit return schemes

Many submitters also called for greater investment in forms of collection, recycling and reprocessing infrastructure. Nearly 38 per cent (2975) of submitters mentioned deposit return schemes, where people receive a small amount of cash back for returning higher value recyclable items for reprocessing. Some submissions particularly mentioned investigating return schemes for takeaway food packaging.

Other types of return schemes that were specifically mentioned included container return schemes (designed specifically for bottles, beverage containers and similar consumer packaging) and related product stewardship schemes where the producer of a product is responsible for what happens to it at the end of its life.

Other infrastructure and investment

To support the collection and reprocessing of recyclable materials, submitters noted the need for improved resource-recovery infrastructure and investment. Better collection and recycling methods were noted as important for various reasons, for example, providing benefits such as:

Compulsory labelling requirements

Of the submitters, 38 per cent (3026) called for further labelling requirements. Calls for better labelling covered different labels, including clear labels for recyclability, material type and other considerations, such as the ability for a product to be composted or whether an item must be sent to landfill.

Education and behaviour change

Forty-four per cent (3475) of submitters commented on the need for more education, awareness and behaviour change. Many noted that behaviour change will also be a likely benefit of these proposals, because regulation will bring attention to plastic-waste issues (in a similar way to the plastic bag ban, which created public awareness around the issue and encouraged behaviour change by requiring more people to bring their own bags when they went shopping).

Using recycled content

Forty-three per cent (3395) of submitters mentioned recycled content requirements and/or the effects that could have on providing stronger and more reliable markets for recycled resin. Many of these submitters believed that requiring a mandatory minimum amount of recycled content in the remaining higher value plastics would further reduce the environmental impacts of plastic by keeping it in the recycling system and out of landfill.

Community funding and engagement

Submitters also called for community-level interventions, such as grant funding for localised education and engagement. We heard this strongly from those who submitted through the form template submissions supplied by organisations like Greenpeace and the Zero Waste Network. Some called for additional funding for community-based activities, such as local education campaigns, reuse workshops, or single-use exclusion zones where communities and local businesses agree to only support reusable options. Some challenges with plastics are localised and may require local solutions, such as areas with particularly high litter rates or where waste infrastructure is less developed.

Compliance, monitoring and enforcement

Any mandatory phase outs will come with additional compliance, monitoring and enforcement work for the Ministry. After single-use plastic bags were banned in 2019, the Ministry launched an online portal for the public to use to report any business or retailer that they believe is providing banned single-use plastic bags. The Ministry also conducted a compliance assurance programme that focused on education and engagement with the regulated community. The programme provided resources that explained the ban to businesses across the country, to support them to adopt alternatives, and allowed the Ministry to check how the ban was working in practice. The Ministry also had a process to escalate concerns where stores, particularly those that were part of a chain, were not willing to comply with the ban. Common suggestions for how to monitor and enforce compliance with the phase outs are summarised below.

Compliance strategy

Compliance and enforcement was not one of the main topics covered in this consultation, but in the substantive submissions tool we asked: “How should the proposals in this document be monitored for compliance?”.

Of the 337 people who responded to the question, 72.4 per cent (244) of submitters mentioned the need or their support for a ‘compliance strategy’. One submitter summarised this position, and stated:

…a compliance and enforcement strategy is needed because the range of products being proposed for a ban is quite wide and will impact a variety of sectors, industries, businesses, organisations and individuals. So, the potential for noncompliance to slip through the cracks is quite high. We saw with the plastic bag ban that some businesses did push the limits of the law and after a year, 400 breaches were reported. Given the scope of the present proposal, that goes well beyond the plastic bag ban, we support the appointment and resourcing of enforcement officers, alongside relying on community members to report breaches.^{^[41]}

Public hotlines and reporting

The second most commented on idea by submitters was a public hotline that would let people report suspected non-compliance issues through an online portal that enforcement officers could check. Eighty-four submitters specifically mentioned a public hotline. This was remarked on far more than any other monitoring and enforcement measures, like waste audits or spot checks.

Next steps and policy decisions

Submissions publishing

Alongside the release and publication of this document, we will also publish and release submissions where submitters agreed to information being published. These will be available on the Ministry’s website.

Policy decisions

The Ministry is providing advice to Ministers and Cabinet on next steps for phasing out hard-to-recycle plastics and single-use items. The advice is informed by this consultation and other work the Ministry has been doing, including engaging with targeted stakeholders, consulting across government agencies, researching best-practice methods from overseas, and other work programmes.

Stay up to date

Policy decisions are expected in mid-2021. You can visit the following sites, to stay up to date on any decisions and announcements:

[1] Office of the Prime Minister’s Chief Science Advisor. 2019. Rethinking Plastics in Aotearoa New Zealand. Auckland: Office of the Prime Minister’s Chief Science Advisor. Retrieved from https://www.pmcsa.ac.nz/topics/rethinking-plastics/ (May 2021).

[2] Ministry for the Environment. 2020. Reducing the impact of plastic on our environment. Retrieved from https://consult.environment.govt.nz/waste/plastics/ (May 2021).

[3] Other business and industry submitter, submission reference number 1765.

[4] Industry group submitter, submission reference number 1775.

[5] General public submitter, submission reference number 1462.

[6] General public submitter, submission reference number 1461.

[7] Local government submitter, submission reference number 1756.

[8] Business and industry submitter, submission reference number 1725.

[9] Business and industry submitter, submission reference number 1714.

[10] Percentages have been rounded and do not add up to 100 per cent.

[11] For example, general public submitter, submission reference number 1287.

[12] For example, business and industry submitters, submission reference numbers 1457 and 1661.

[13] For example, NGO submitter, submission reference number 1471.

[14] For example, general public submitter, submission reference number 6051.

[15] For example, NGO submitter, submission reference number 1447.

[16] For example, general public submitter, submission reference number 1300.

[17] For example, general public submitter, submission reference number 6413.

[18] For example, general public submitter, submission reference number 9170.

[19] For example, business and industry submitter, submission reference number 1661.

[20] For example, business and industry submitter, submission reference number 1726.

[21] For example, business and industry submitter, submission reference number 1661.

[22] For example, retail submitter, submission reference number 1765.

[23] General public submitter, submission reference number 1395.

[24] General public submitter, submission reference number 7047.

[25] Business and industry submitter, submission reference number 1309.

[26] Disability advocacy group, submission reference number 1589.

[27] For example, disability advocacy group, submission reference number 1589.

[28] NGO submitter, submission reference number 1745.

[29] Local government submitter, submission reference number 9542.

[30] For example, industry association, submission reference number 1728.

[31] NGO submitter, submission reference number 9542.

[32] NGO submitter, submission reference number 1741.

[33] Local government submitter, submission reference number 1727.

[34] General public submitter, submission reference number 1336.

[35] NGO submitter, submission reference number 1745.

[36] This is 58 per cent of the 820 substantive submitters who commented on proposal two timeframes.

[37] For example, retail submitter, submission reference number 1765.

[38] General public submitter, submissions reference number 9564.

[39] Numbers and percentages in the ‘Tools to transition away from single-use and hard-to-recycle plastics’ section are taken from all 7878 submissions received. We did not ask for responses on additional policy tools in our short-form survey, but some submitters who completed the short-form survey provided suggestions around additional policy tools in their comments, which we have captured.

[40] The Ministry is working on a national plastics action plan as part of its response to the Rethinking Plastics in Aotearoa New Zealand report. This plan should support long-term planning and signal best practice methods for producers and consumers. The Ministry will continue to seek advice from experts and engage with producers and consumers on this work.

[41] Business and industry submitter, submission reference number 1399.

Message from the Secretary for the Environment

Submitters wanted more action on plastics

Affected industries and businesses cited concerns

Timeframes for proposal one

Key findings – Proposal two

Submitters want more action on single-use plastics

Many submitters are concerned about accessibility

Timeframes for proposal two

Proposal one: Phase out of hard-to-recycle plastics

Proposal two: Taking action on single-use plastic items

Understanding plastics

New Zealanders want change

Rethinking plastics

How we consulted

Consultation tools

How to read this document

Substantive submissions versus short-form submissions

Who responded

Overwhelming support for taking action on plastics

General public submitters were most likely to support the Government in taking more action on plastics

Industry and business submitters favour a longer lead-in time

Timeframes

Specific challenges for phasing out hard-to-recycle plastics

Phasing out expanded polystyrene is likely to be more challenging

Polystyrene and the ‘cold chain’

What we heard – Proposal two

Overall support levels

Reasons for disagreement

Wide support, but challenges identified by the horticulture industry

Many New Zealanders raised concerns around a phase out for straws

Some businesses support an exemption for drink carton straws

Many submitters disagreed with the scope and wanted it to include more cups and lids

Businesses and retailers support the phase out

Many New Zealanders want coffee cups and wet wipes phased out

New Zealanders want more single-use plastics phased out

Transition plan or roadmap

Deposit return schemes

Other infrastructure and investment

Compulsory labelling requirements

Education and behaviour change

Using recycled content

Community funding and engagement

Compliance strategy

Public hotlines and reporting

Submissions publishing

Policy decisions

Stay up to date