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Summary of Product Stewardship Submissions

The following is an extract from a brief summary of the submissions received on the Product Stewardship (PS) and Water Efficiency Labelling (WELS) Discussion Document 2005.  The extract was circulated to stakeholders in December 2005.

The full summary of submissions for the Product Stewardship (PS) and Water Efficiency Labelling (WELS) Discussion Document 2005 was printed in August 2006.

Main issues discussed in submissions

Summary of responses

Submitter

Councils

Industry

Sector Groups

Personal

NGO & others

Total

Number of submissions

22

39

20

25

11

117*

Preferred option:

1 – Status quo

 

12

12

 

 

24

2 – Free rider regulation

2

4

1

 

 

7

3 – Mandatory approach

1

3

1

16

7

28

4 – Regulatory safety net

19

11

5

2

4

41

Some regulation

 

5

 

7

 

12

No preference

 

4

1

 

 

5

* There were a total of 130 submissions received, but 13 dealt only with WELS.

Definition

  • Most submitters agreed with the definition of product stewardship in the discussion document, and that “all in the chain have a part to play”.
  • The following opinions were voiced about who should pay:
    • the waste generator;
    • those benefiting from the product;
    • those benefiting from the waste reduction;
    • in cases of near-universal use (e.g. packaging) “there can be no differentiation between ‘user’ and ‘ratepayer’”.

Benefits and disadvantages of regulation

  • The largest group supported a mixed approach, with a preference for voluntary action with regulatory backstops if necessary.
  • Some thought that, as industry was in a stronger position to understand how to make improvements, regulation would reduce the efficiency and effectiveness of PS schemes. Regulation may also encourage a “wait and see” attitude, rather than industry being pro-active.
  • Alternatively, some thought that voluntary schemes meant that only soft targets were being addressed, or that “there are still companies who will only change practices if legislation is introduced”. Regulation may be able to speed up what was considered to be the currently slow adoption of PS.
  • Existing schemes were given by some as an example of how purely voluntary schemes can succeed with challenging targets, and by others as an example of how voluntary approaches have “overall, produced mediocre results”.

Concerns for product stewardship

  • The largest concern was about free-riders, both within sectors and between sectors. However, a few felt that not all free-riders undermine schemes, so case-by-case evaluation was needed before regulation.
  • A number noted the importance of imported goods, and that this should be a key factor in any regulatory framework.  Particularly: parallel imports represented free-rider potential and schemes “should not advantage or disadvantage domestic producers”.
  • Legacy/orphan products were seen by many as providing a strong case for sector-wide schemes or government funding.
  • Some submitters cautioned against the use of overseas models as there are some unique aspects here – including large distances, small waste volumes and limited recycle markets.

Process for implementation

  • Many submitters called for more analysis before legislation is developed, including defining the problem further and assessing the costs and benefits of PS approaches compared to other options.
  • If legislation was enacted, many submitters felt that priority areas should be identified and published, to allow industry time to address the issue with voluntary schemes before regulation was triggered.
  • The trigger point for regulations differed – some submitters felt that it should only be “where there is a serious threat to health/life”, some felt that regulations should only occur when it was requested by industry, some felt they should be triggered when costs were still being borne by council.

Priority products

  • Large numbers of submitters mentioned: used oil, vehicles, tyres, electronic wastes, chemicals, packaging, construction and demolition waste and shopping bags.
  • A few submitters mentioned: gas cylinders, refrigerants, household hazardous wastes and smoke alarms.

Tools

  • Some submitters felt that it was most effective to regulate outcomes, rather than the mechanisms for getting there.
  • A range of mandatory tools were suggested: labelling (both for schemes and material identification), material bans, landfill levies, container deposit legislation, standards, registration of products, product takebacks.
    • Levies caused a lot of comment, some in support, others against. While they are relatively simple, they can include high administration costs, cause unintended consequences and can be inflexible.
    • Deposit schemes were considered by some submitters as achieving excellent recovery rates, and by others as being impossibly expensive or cannibalizing other recycling schemes.

Role of the Ministry for the Environment

  • Most submitters suggested the Ministry had a key role in facilitating voluntary schemes, providing start-up or research funds, encouraging labelling initiatives, and the education of consumers as to why they should recycle, and what schemes were operating.

Role of Local Government

  • Some submissions pointed out the value of existing local government collection, provision of drop-off points and recycling networks.
  • Some submitters suggested that councils should enforce existing regulations more, and harmonise their waste treatment with each other.
  • A few submitters gave the view that PS agreements negotiated with the government should not be able to be changed by local bodies.

Last updated: 8 August 2006