4 Summary of Submissions

This section gives a summary of submissions, and where appropriate comments on future work.

4.1 Overview of submissions

In total 130 submissions were received. Of these, 117 dealt with product stewardship and 48 with WELS. To break this down further, 13 submissions dealt only with WELS, 69 only with product stewardship, and 35 commented on both product stewardship and WELS.

Table 1: Origin of submissions

Submissions from	Product stewardship	WELS
Councils	22	15
Industry	39	12
Sector groups	20	10
Personal	25	5
NGO and other	11	6
Total	117	48

4.1.1 General themes of submissions

A number of submissions commented on the lack of information and detail in the discussion paper (27, 28, 29, 50, 56, 104, 116). These submissions outlined areas where they thought additional work is needed before any decisions are made. Submissions 29 and 50 felt more information on the waste situation is needed, and some thought that more cost-benefit information is needed before regulation can be justified (28, 50, 56, 104). There is also a need for a regulatory impact statement (RIS) and business cost compliance statement (BCCS) to be prepared. Submitter 27 thought more study should have been done before consultation.

4.2 Product stewardship

4.2.1 Main issues discussed in submissions

The submissions provided a range of comment. The main threads from the submissions were as follows.

Voluntary mechanisms are clearly preferred by industry, sector groups and councils.
Regulation that assists voluntary schemes and provides a backstop for gaps in voluntary action was supported by just over half of the submissions, including over half of the submissions from industry.
Many submissions highlighted the need for regulation to be well designed and subject to careful analysis before it is implemented.
Many submissions highlighted work in product stewardship they are involved with, covering a number of product areas. From this it became clear that there are different waste issues being faced with different products, and often the market structure differs as well. These differences need to be reflected in any product stewardship policy.

Table 2: Summary of responses on product stewardship

Option	Submitter preferences
Option	Councils	Industry	Sector groups	Personal	NGO and others	Total
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
Total	22	39	20	25	11	117

4.2.2 Ministry comment

The submissions broadly reinforce the Ministry for the Environment's preferred option 4, which would use voluntary mechanisms, with regulation as a safety net to fill the gaps.

The submissions also highlight areas where further policy work is needed. Each product area is different, and in many areas the markets are highly competitive and constantly changing. This means ensuring that any policy can be effectively and efficiently applied in all the areas where there are waste problems. Industry-led and voluntary schemes have the advantage of using industry knowledge and expertise to resolve environmental issues relating to products. In the regulatory area, detail is critical.

Further work is improving the detail in the policy so we can build on and extend voluntary schemes.

4.3 Water efficiency labelling scheme

In general, the submissions saw benefits from adopting WELS in New Zealand, although they raised a number of technical issues that need to be addressed to accommodate differences between New Zealand water supplies and those in most of Australia. These issues are being discussed with New Zealand industry and the Australians.

Once these issues have been addressed, a report will be prepared for the Government so a decision can be made as to whether to put forward WELS legislation.

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