7 Lessons Learned and Key Recommendations
The study has provided an opportunity to review product stewardship initiatives currently underway in the New Zealand whiteware sector. At the same time, several key issues have emerged as both challenges and opportunities. The associated recommendations draw on a range of activities undertaken during the course of the project, not excluding:
- interviews and meetings with sector group representatives;
- data and information collected and analysed by the authors;
- knowledge of related policy and industry initiatives worldwide;
- key aims, objectives and issues outlined in the New Zealand Waste Strategy and the product stewardship Discussion Document;
- public submissions related to the Ministry for the Environment product stewardship Discussion Document;
- dialogue and discussion with the Ministry for the Environment.
a) Anecdotal information and evidence indicates that, although the majority of end-of-life whiteware in New Zealand is recovered for metal recycling, significant volumes of shredder floc from the recycling process still end up in landfill, the environmental impacts of which have yet to be documented and/or publicly released.
Associated recommendation: The whiteware sector, together with Government, should establish and document accurate data on the level of whiteware collection and recycling currently underway, including figures on discards and recycling rates, as well volumes of shredder floc going to landfill.
b) DfE features and characteristics such as design for disassembly and recycling, materials efficiency and RoHS compliance, are well advanced among several of the major whiteware producers including Fisher & Paykel Appliances and Electrolux New Zealand.
Associated recommendation: Encourage producers and retailers to proactively communicate and promote (to consumers) the environmental, economic and consumer benefits resulting from DfE features and characteristics.
c) Detailed quantitative information about 'whiteware and the environment' (excluding energy and water efficiency) is significantly lacking in New Zealand. This includes limited accurate data and information about actual disposal pathways, recycling rates and the environmental impact of shredder floc going to landfill.
Associated recommendation: Undertake relevant and authoritative research that clearly identifies and documents the nature and scale of any identified environmental problems associated with current disposal and recycling activities in New Zealand.
d) The Fisher & Paykel scheme represents an exemplary initiative within the context of a voluntary response with no Government intervention or regulation.
Associated recommendation: Fisher & Paykel should, as a priority, develop and communicate high quality outreach information which effectively describes how its scheme operates including the overall environmental, economic and social benefits.
e) Driven chiefly by a desire to maximise consumer benefit, it appears that the embryonic Electrolux home delivery service (which includes product/packaging recycling) may expand to most major centres.
Associated recommendation: Government should, as a priority, encourage Electrolux New Zealand to further expand its product and packaging recycling activities currently being offered through the company's home delivery service. As its scheme develops, Electrolux should also document its activities and provide a higher level of public information and reporting.
f) There appears to be general in-principle support for a mix of voluntary and regulatory measures (where required) as a means of further expanding and enhancing the role and outputs of product stewardship in the New Zealand whiteware sector.
Associated recommendation: Government should consider this report with a view to further developing and refining a national policy position on product stewardship as it relates to the whiteware sector. The whiteware sector group should also be retained and substantially widened with a view to continuing a productive dialogue between Government and industry on the specifics of how regulatory and/or non-regulatory measures should be designed, assessed, implemented and administered and/or enforced.
g) There is a general view among members of the whiteware sector group that industry free-riders are a major barrier to greater investment in, and uptake of, whiteware product stewardship in New Zealand. Such free-riders include not only whiteware producers/importers, but also retailers who do not offer any form of systematic recovery and recycling service or programme to consumers.
Associated recommendation: The existing whiteware sector group should be widened to include more diverse representation including other producers, importers/agents, retailers, the waste management industry and local councils. The policy development process should be seen to be inclusive and open to other relevant stakeholders to participate.
h) There is a view that current requirements and procedures for degassing end-of-life refrigerators, freezers and air conditioners, present a barrier to some retailers being more active participants in whiteware recovery and recycling.
Associated recommendation: Government should work collaboratively with the whiteware sector group and the Recovery Trust, to identify specific barriers and opportunities, with a view to modifying current requirements (where legally possible) so that the management of ODS and end-of-life whiteware recycling can be effectively and efficiently undertaken.
i) There are competing views on whether or not a landfill ban covering whiteware would be acceptable to producers, importers and retailers, or not. While Fisher & Paykel Appliances has no immediate objection to the landfill ban concept, Electrolux New Zealand believes such a ban would be onerous.
Associated recommendation: The whiteware sector group should further discuss a landfill ban option with a view to comprehensively identifying and documenting the full range of advantages and disadvantages.
j) There is a relatively strong view that should any regulatory intervention be more seriously pursued, that its direct consequences and side effects be clearly identified, modelled and assessed with a view to ensuring that the envisaged benefits exceed the costs.
Associated recommendation: A comprehensive cost-benefit analysis should be conducted as part of a broader regulatory impact study on any proposed regulatory options.
k) There is a view among some stakeholders that great care should be taken to ensure any potential regulatory intervention does not negatively impact or destabilise existing schemes such as that being run by Fisher & Paykel. Similarly, there is a view that continued policy inaction could undermine the voluntary efforts of the Fisher & Paykel scheme and participating retailers/dealers.
Associated recommendation: Refer to recommendation j).
l) Finally, there is a relatively strong view across the whiteware sector group, that relative to other product categories and waste streams, the environmental impacts and issues associated with end-of-life whiteware are not worthy of any major industry upheaval or radical regulatory intervention.
Associated recommendation: Refer to recommendations a) and c).
