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6. Performance of Programmes Against Government Policy Objectives

The Government has laid out its policy objectives for product stewardship in New Zealand. These objectives are contained within the Product Stewardship and Water Efficiency Labelling Discussion Document.

The purpose of this study is to examine the performance of current paint stewardship approaches and to look at ways in which government policy might help or hinder paint recovery from an industry perspective. Existing product stewardship paint initiatives have been examined against key questions and overall policy objectives in the table below. In the sections following the table we have examined potential tools for increasing product stewardship, including regulatory and non-regulatory.

 

VOLUNTARY INDIVIDUAL PRODUCER STEWARDSHIP

(Paintwise example)

Brief description

 

 

Key Questions

Producers are encouraged and assisted to establish paint take-back and recycling programmes.

No regulation

Paintwise is only current example of individual product stewardship.

Is there clear evidence of Product Stewardship approach/principles?

Yes. Closes the loop between producer and end-of-life product. Individual approaches may have varying degrees of involvement from other stakeholders.

Paintwise involves brand owner and its retail arm. Government involvement is limited to education and promotion of the scheme and assistance with start-up costs.

Level of environmental performance & impact reduction?

The individual voluntary approach allows individual producers to set the performance criteria for their products. Paintwise has taken an approach that maximises recovery and reduces disposal and has clearly stated this in the development of the programme. Other schemes developed under this voluntary approach may not match these standards, or may exceed them.

How is the scheme funded & at which point?

Flexible, at discretion of individual producers. Can be internalised or a visible fee can be placed at point of purchase. Paintwise is funded through a visible fee placed on every litre of paint sold by Resene (or at point of return for non-Resene). The fee is paid by Resene customers (retail only) every time they purchase paint.

Who primarily operates and/or manages the scheme?

Individual producers operate the scheme. Paintwise is owned by a trust linked to the brand owner and managed under contract by a programme manager.

Is the problem served by a collective or individualistic approach to PS?

An individualistic approach currently exists and has successfully resulted in one producer creating a scheme, and others are becoming interested in a similar approach.

Ability for the scheme to specify & measure targets and Key Performance Indicators (KPIs)

Individual producers have the freedom to set their own targets and KPIs for schemes. Paintwise programme has targets and KPIs agreed with the programme manager.

Ability for the scheme to set standards for collection & materials processing

Standards set by individual producers according to their requirements.

No industry-wide standards exist.

Evidence of data collection, evaluation and monitoring?

There is no regulatory requirement for voluntary producer schemes to collect data or monitor performance. Data collection is for measuring programme performance against key deliverables.

Paintwise has a tracking and reporting system that enables the collection of data from shop take-back to material processing routes.

Reporting to stakeholders? What? How often? Verified? Audited?

Public reporting is optional as a component of a voluntary scheme. Sharing of data and information with councils and the public is seen to be beneficial to the programme.

Paintwise reports to councils on programme performance but is not currently contracted to, or has any obligation, to do so.

Scheme costs for industry/government/consumers?

Burden of costs on individual producers and therefore customers.

  • Industry - costs of set up and implementation for individual companies. Ongoing costs met by levy
  • Consumers - fee on some producers paints
  • Local government/ratepayers - some assistance in set up. No ongoing costs
  • Central government - some assistance in set up. No ongoing costs.

Benefits to participants and/or government, of the scheme?

  • Industry - market differentiation for those offering stewardship, control over end-of-life product
  • Central government - problem is being dealt without significant input from government
  • Local government - reduced burden, and therefore costs, on paint collection programmes
  • Consumers - simple solution to paint disposal available all the time.

Does the scheme acknowledge and/or reward an LCA approach to product development and end-of-life management? How?

Individual producers with schemes reap immediate benefits of any changes in design of product that makes those products more recyclable. For example, the Paintwise scheme would be able to pass savings on to consumers in the form of a reduced levy if recycling costs were to reduce due to changes in packaging design or paint recoverability.

Does the scheme constrain or encourage innovation amongst producers, retailers, recyclers, government and/or consumers? How?

The Paintwise scheme has had the flexibility to adapt to changing circumstances and to develop innovative solutions because it is not constrained by standard models.

Is the handling of recovered materials and/or residual waste a safety or export issue? How significant?

An estimated mix of materials coming from waste paint collections is:

  • Good quality, reusable paint 13.5%
  • Water-borne paint 31.5%
  • Solvent-borne paint 18%
  • Plastic 6%
  • Steel 25%
  • Residual 6%

Handling of solvent-borne paint is the only safety concern. The majority of materials are easy to handle.

Extent of residual wastes generated? What types? How significant?

Residual waste streams (wastes that end up in landfill) from waste paint are:

  • sludge from the solvent recovery process (recovery of solvents ranges between 25 and 80% depending on the mix of the paint batch [Paul Kennel, Transpacific Technical Services Ltd, pers. comm.] )
  • plastics - currently no recycling option exists, but this is being explored

Contaminated material - material that is too contaminated to be recoverable.

Do the public and/or other participants understand the scheme?

Paintwise is promoted through a range of internal and external media. The approach has been to bed the scheme in prior to any large-scale advertising campaign. To date, promotion has been limited to in-store promotion, trade magazine advertisements, word of mouth and, recently, bus shelter advertising in the Auckland region.

There is the potential for public confusion if other producers develop parallel schemes.

Is orphaned product an issue? How significant?

Orphaned product is product manufactured or sold by parties that are no longer in the sector. Orphan product is not a significant issue when considering product stewardship of paint. There are only four key market players and there is therefore reduced risk of product becoming orphaned (not able to be assigned to an individual brand owner). Products are also typically bought, used and disposed of within a short timeframe, reducing orphan risk.

Individual schemes can overcome the orphan issue by setting charges for brands of competitor paint. Resene Paintwise has set a fee for non-Resene paint collected at stores.

Is historical product an issue? How significant?

Historical product is product that was on the market before a scheme came into existence. Historical product is not an issue for individual producer schemes because such schemes only undertake to take back own-brand products. Resene Paintwise accepts any Resene paint, no matter how old, and will accept other brands for a fee.

Are free-riders an issue/potential issue? How significant?

It is early in the development of voluntary product stewardship for the paint sector and there appears to be some interest from the key players in the market to participate in, or set up their own, product stewardship scheme.

Is the scheme able to address imports & locally manufactured product effectively/fairly?

Not an issue. Almost all paint put on the market comes from four companies. Most of their paint is manufactured in New Zealand.

Does the scheme represent a barrier to market entry? How?

There is no barrier to market entry as schemes are voluntary.

Collection/Recovery methods? Effective/efficient/Best Practice?

Individual producer initiatives are not required to set in place minimum standards for treatment. Parts of the recycling industry would like to see a level playing field for service providers to ensure minimum environmental and safety standards are met by all players. Paintwise programme has clearly set out its standards for the recovery of paint waste collected by the programme. Future parallel schemes from other brand owners might use different methods for recovery.

Performance of schemes against Government Policy Objectives

Schemes should use a Product Stewardship approach

Individual product stewardship is being encouraged. Brand owners can create their own schemes to take back their own product (or choose to collaborate). This closes the loop between producer and end-of-life management of products.

Paintwise uses a full product stewardship approach because it involves a producer taking physical and financial responsibility for its products.

Schemes should lead to environmental gains

Paint collected by Paintwise is removed from the waste stream and recycled/ recovered. Reduced risk of pollution. Reduced pressure on landfills. Avoided material extraction burden through material recycling. The Paintwise programme is also investing in research for alternative uses of waste paint. This could lead to further environmental gains.

Schemes should be effective and efficient

Flexibility in the design of Paintwise has enabled efficiency to be maximised. The scheme is a commercial operation and therefore designed to be as efficient as possible to avoid undue cost to Resene. Entry to the scheme by other brand owners would improve efficiency through economies of scale.

It is difficult to gauge the effectiveness of Paintwise at this early stage in the scheme. As volumes grow, the scheme is on track to reach its budgeted milestones.

Schemes should contain publicly reported, challenging performance measures, quantifiable where possible

There are no requirements for minimum performance standards, or the reporting of results. Individual schemes have the freedom to measure what they feel is important and what they report on. They are answerable only to shareholders and, to a lesser degree, customers.

Collection and recycling targets for the Paintwise programme had full public disclosure at the outset and are being disclosed to supporting councils and through public media on a regular basis. Paintwise is in the process of obtaining Enviromark certification to ensure systems are in place for standards-based processing and continual improvement.

Schemes should be transparent

An individual, voluntary approach does not require transparency for schemes, beyond compliance with any legal requirements. Although Paintwise is a commercial operation, the development of the programme and its associated standards has been transparent to the parties who assisted in its implementation.

The benefits of any regulatory aspects should exceed their costs

Not regulated.

Schemes should not reduce market competition

No effect on market competition because an individual approach is taken, primarily for companies setting up schemes to gain competitive advantage. Schemes are the same as any other extra customer service.

Paintwise has been set up by an individual company as an initiative to provide added value to customers and to "do the right thing". It does not reduce market competition, rather it stimulates competition. Paintwise so far has not been collaborative, although it does allow for other paint industry players to join in the future.

Schemes should set safe standards for the collection & handling of recovered material

Currently there are no minimum standards for collection and handling of waste paint by schemes set up by individual producers. This is particularly an issue for solvent-borne paint, which requires particular care when handling.

Paintwise will be Enviromark (environmental management system) accredited and will therefore comply with regulatory requirements.

Schemes should provide a forum for communication & to address any issues

Individual schemes in the current regulatory environment do not need to provide a forum for communicating issues from stakeholders.

Paintwise is regularly discussed with the councils who have thus far assisted in its establishment in order to obtain feedback and to address ongoing issues. There is also a Paintwise website address for public feedback on the programme.

Schemes should include public information & education components.

Significant investment in publicising the programme. Resene advertising including website, brochures, leaflets, and point-of-sale material. Councils also promote the service.