Reducing the Impact of Plastic on our Environment, November 2020 consultation

Marine plastic pollution is a problem we can’t afford to ignore. Every year, whales, dolphins and other marine animals around the world die in their millions as a result of ingestion and/or entanglement in plastic.

New Zealand is no exception.

In 2019, marine experts surveyed by Project Jonah named oceanic plastic debris as the second greatest threat to marine mammals in our waters.

We are, therefore, excited that the Government has opened a consultation on legislation seeking to move the country away from hard-to-recycle and single-use plastics. This is a chance we must take to protect marine species that both reside in and visit New Zealand.

The Government has created an online submission tool, which is their preferred way to receive responses.  The consultation closes on 4th December, 2020.

The submission itself is quite long, but we want to make this as easy as possible for you - our supporters. Below this paragraph, we have outlined Project Jonah’s position on the consultation’s main points. At the end, you’ll find some answers you can copy and paste into the consultation to ensure your use if you’re tight on time but keen to make your voice heard in support of marine mammals.


1. To phase out the following types of unrecyclable plastic:

  • Some polyvinyl chloride (PVC) and polystyrene packaging.
  • All oxo-degradable plastic products.

2. To phase-out seven types of single-use plastic items.

The policy objectives and approach (submission questions 1-5)

Overall, we agree with the proposed objectives, and the prioritisation of unrecyclable and single use plastics as the products that need to go first. Given the time it takes for plastic to break down, and the amount of plastic debris already in the oceans, we can’t allow continued production of plastics that are hard to recycle and only provide a short use-life.

We also agree with the weightings given to the different options for achieving these objectives, and the resulting preference towards a mandatory phase out. We can’t rely on voluntary schemes and targets to achieve the important aims of reducing plastic use, as has been shown by the limited number of businesses currently signed up to the New Zealand Plastic Packaging Declaration.

Proposal 1: (submission questions 6-15)

We agree with the move to phase-out PVC and polystyrene packaging. However, this shouldn’t be delayed across two stages (2023 and 2025). The environmental threats posed by these types of plastics mean we need to move as quickly as possible to remove them from public use.

We also believe a greater effort could be made to increase the scope of the phase-outs to include a wider range of items. We would like to see all applications of PVC and polystyrene included in the ban. Similarly, stage 2 of the phase-out should include all PVC and hard polystyrene packaging.

We’re pleased with the current analysis of costs and benefits, and the fact that the Government is working to ensure that banning these items won’t shift consumption to other hard to recycle materials.

Finally for this section, we want the Government to ensure that alternatives to the products included in the ban won’t be prohibitively expensive for consumers.

Proposal 2: (submission questions 16-22)

We agree with the proposed phase out of single-use plastics. However, the list should be expanded to include all single-use plastics, with some limited, controlled exceptions for essential items - e.g. medical supplies. If a plastic product can only be used once, it shouldn’t be produced at all - the negative impacts on wildlife and the planet are too great.

We also don’t understand why disposable coffee cups and their lids, and wet wipes that include plastic, aren’t included in the proposed ban. Viable alternatives to these commonly used and hard to recycle items already exist. 

In all cases, the timeframe for phasing out should be as soon as possible, with an emphasis on speed over business convenience. A blanket timeframe for everything is counterproductive if it slows up the removal of some items in order to wait for others.

The Government should engage with, and assist, businesses manufacturing, supplying and/or using products included on the proposed phase-out list (and those involved with the manufacture, supply, or use of single-use plastic coffee cups or wet wipes). This assistance could include reducing the costs of manufacturing or importing alternative raw materials, and supporting new businesses to produce alternative, biodegradable substitutes.

Question 23: Monitoring compliance

To reap the benefits of a mandatory, rather than voluntary, removal of plastics, compliance monitoring is key. We believe that fines are an effective way to ensure that businesses abide by these new rules.

We agree that the compliance and enforcement strategy should be "transparent, evidence-informed, risk-based, responsive and proportionate to the risks or harms being managed."


We hope this summary of our position on these issues is helpful to you, and that you make a submission of your own.

This is a crucial chance for us to advance the cause of marine mammal protection in New Zealand, in the face of one of the greatest challenges these animals face.

1. Do you agree with the description in this document of the problems with hard-to-recycle plastic packaging and single-use plastic items? If not, why?

  • Yes.

2. Have we identified the correct objectives? If not, why?

  • Yes.

3. Do you agree that these are the correct options to consider? If not, why?

  • Yes.

4. Have we identified the right criteria (including weightings) for evaluating options to shift away from PVC and polystyrene packaging, oxo-degradable plastics and some single-use items? If not, why?

  • Yes.

5.  Do you agree with our assessment of the options, and our decision to take forward only one option (a mandatory phase-out)? If not, why?

  • Yes.

6. Do you agree with the proposed phase-out of PVC and polystyrene packaging as set out in two stages (by 2023 and by 2025)? If not, why?

  • Yes, but do not agree with the proposed stages (please comment below).

Notes: The phase-out shouldn’t be delayed across two stages (2023 and 2025).  The environmental threats posed by these types of plastics mean we need to move as quickly as possible to remove them from public use.

7. Have we identified the right packaging items that would be covered by a phase-out of PVC and polystyrene packaging? If not, what would you include or leave out, and why?

  • No.

Notes: I believe a greater effort could be made to increase the scope of the phase-outs to include a wider range of items. I would like to see all applications of PVC and polystyrene included in the ban.

8. Do you think we should include all PVC and hard polystyrene packaging in stage 2 of the phase-out (eg, not just food and beverage and EPS packaging)? Please explain your answer.

  • Yes.

Notes: If a plastic product can only be used once, or is hard to recycle, it shouldn’t be produced or used at all - the negative impacts on wildlife and the planet are too great.

9. What would be the likely costs or benefits of phasing out all PVC and polystyrene packaging (hard polystyrene and EPS) by 2025?

Benefits:

  • Environmental benefits of less plastic litter.
  • More recycling.
  • Improvements to New Zealand’s towns and cities due to less plastic litter.

Costs:

  • Costs to business as they transition to other products.

10. Do you believe there are practical alternatives to replace hard-to-recycle packaging (PVC, polystyrene and EPS)? If not, why?

  • Yes.

 11. Do you agree with a mandatory phase-out of all oxo-degradable plastics by January 2023? If not, why?

  • Yes.

12. If you manufacture, import or sell oxo-degradable plastics, which items would a phase-out affect? Are there practical alternatives for these items? Please provide details.

N/A.

13. Have we identified the right costs and benefits of a mandatory phase-out of the targeted plastics? If not, why not? Please provide evidence to support your answer.

  • Yes.

14. How likely is it that phasing out the targeted plastics will have greater costs or benefits than those discussed here? Please provide details to explain your answer.

Not mentioned in the document are the benefits the phase-out will have to New Zealand’s marine wildlife.

In 2019, marine experts surveyed by Project Jonah named oceanic plastic debris as the second greatest threat to marine mammals in our waters. And, in 2018, Forest & Bird presented evidence that NZ’s seas are the worst in the world in terms of risk to sea birds from plastic.

The removal of single use, and hard to recycle plastics would help to reduce these risks, and therefore protect marine species, an objective that should be prioritised.

15. What would help to make it easier for you and your family, or your business/organisation to move away from hard-to-recycle plastic packaging and use higher value materials or reusable/refillable alternatives?

This one will depend on what’s relevant to you, but you might want to consider:

  • Reducing the costs of alternatives.
  • Making alternatives easily available.
  • Ensuring alternatives are durable.
  • Gaining a better understanding of what the different alternatives are.

16. What do you think about the proposed mandatory phase-out of some single-use plastic items (see table 7)?

  • Agree in part.

Notes: I agree with the phase-out, but the list needs to be expanded to include all single-use plastics, with some limited, controlled exceptions for essential items - e.g. medical supplies.

17. Do the proposed definitions in table 7 make sense? If not, what would you change?

  • Yes, with changes.

Notes: I believe the scope of banned items should be broadened here. In particular, I don’t understand why disposable coffee cups and their lids, and wet wipes that include plastic, aren’t included. Viable alternatives to these commonly used and hard to recycle items already exist. 

18. What would be an appropriate phase-out period for single-use items? Please consider the impact of a shorter timeframe, versus a longer timeframe, and provide details where possible.

  • Depends on the item.

Notes: The timeframe for phasing out should be as soon as possible, with an emphasis on speed over business convenience. A blanket timeframe for everything is counterproductive if it slows up the removal of some items in order to wait for others.

19. What options could we consider for reducing the use of single-use coffee cups (with any type of plastic lining) and wet wipes that contain plastic? You may wish to consider some of the options discussed in this consultation document or suggest other options.

These should be included in the mandatory phase-out. While all the options noted in the submission document have benefits, as long as the plastic options exist, so do the threats to our planet and its wildlife.

There are reusable alternatives to these products already available, but it will require a mandatory phase out for these alternatives to become the norm.

20. If you are a business involved with the manufacture, supply, or use of single-use plastic coffee cups or wet wipes (that contain plastic), what would enable you to transition away from plastic based materials in the future?

The Government should engage with, and assist, businesses manufacturing, supplying and/or using products included on the proposed phase-out list (and those involved with the manufacture, supply, or use of single-use plastic coffee cups or wet wipes). This assistance could include reducing the costs of manufacturing or importing alternative raw materials, and supporting new businesses to produce alternative, biodegradable substitutes.

21. What do you consider an appropriate timeframe for working toward a future phase out of plastic lined disposable coffee cups and wet wipes containing plastic?

These items should be included in the initial ban.

22. Have we identified the right costs and benefits of a mandatory phase-out of single-use plastic items? If not, why? Please provide evidence to support your answer and clarify whether your answer applies to a particular item, or all items.

Yes.

23. How should the proposals in this document be monitored for compliance?

Fines are an effective way to ensure that businesses abide by these new rules.

 

 

 

 

 

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