Submissions
30
August 2005
Product
Stewardship Submissions
Ministry
for the Environment
PO
Box 10362
Wellington
Rural
Women New Zealand Submission on Product Stewardship
and Water Efficiency Labelling
1
Rural Women New Zealand (RWNZ) appreciates
the opportunity to provide comments on the discussion
document Product Stewardship and Water Efficiency Labelling
– new tools to reduce waste.
2
RWNZ supports the preferred approach for
product stewardship schemes (Option 4) – a mix of voluntary
and regulatory approaches.
3
The following comments have been provided
by members to the questions in section 6 of the Product
Stewardship Section of the document:
• Priority product areas for product stewardship
schemes include cars, electronic products, hazardous
substances, tyres (assuming the tracking system does
not fully address the issue) as these have been highlighted
in the document as having particular management and
disposal problems (high volume and harm). The huge amounts
of packaging currently ending up in landfills is one
issue that everyone can immediately participate in and
progress has already been made with the Packaged Goods
Accord. (High volume and achievable).
2
The criteria included in the NZ Waste Management Strategy
(section 5.2 of
discussion
document) provide clear guidance as to involvement in
particular product stewardship schemes.
• The Ministry can play an important role
in facilitating product stewardship schemes (as in the
Packaged Goods Accord) and can provide the back stop
regulation for high priority wastes where there is a
clear need for intervention. Monitoring the performance
of schemes is a vital role for the Ministry, including
enforcement of any regulation.
• The use of a range of tools such as deposit-refund
schemes are available for
product
stewardship schemes but the use of any particular tools
should not be mandatory. The development of voluntary
schemes needs flexibility.
• In considering costs members think that
disposal costs may fit well with the producer and travel
with the product to disposal. Consumers should be advised
as part of labeling as to the disposal component of
the cost. This could encourage return/refund schemes
and should encourage producers to minimize the costs
of disposal to remain competitive.
• Consumer education regarding packaging,
recycling is important. Many people want to do the right
thing but are not aware of all the implications of their
decisions to purchase certain products. For example
it is understood that there is a better market for recycling
aluminium cans than glass and therefore consumers may
choose to purchase cans where possible if this is known.
In
a country with a small population and large distances
for collection for recycling there are always going
to be cost effectiveness considerations. Therefore the
minimization of waste and good consumer choices is important.
Rural
people face particular problems with disposal of waste
given the large distances involved in transport. In
particular the disposal of unwanted hazardous substances
(chemical sprays etc) is difficult. The safe disposal
of such items off farm will become increasingly important
for overseas markets for produce. A component built
into the product price that covered the collection of
this material may be cost effective. It was noted by
one member that if they were to dispose of everything
correctly they would be transporting dangerous goods
back to town. Their neighbours throw everything into
a rubbish hole and then light a fire. While education
will assist in ensuring people are more aware of the
issues, any scheme has to be easy to comply with and
not onerously expensive.
4
Water Efficiency Labelling
While
labelling of appliances with water efficiency rating
is supported it is not considered necessary to be mandatory.
Many of the New Zealand manufactures sell to Australia
and vice versa. Australia has a much greater need for
water efficiency than New Zealand and therefore it is
considered in the manufacturer's interest to label for
water efficiency as a marketing strategy.
In
response to specific questions:
14
Members are influenced in purchasing whiteware
and plumbing by water efficiency labelling.
• A New Zealand –based administration option
is preferred.
19
Advice to consumers regarding the benefits of water
efficiency without
compromising
the end result (eg washing clothes).
Yours
faithfully,
Maggie
Bayfield
Executive
Officer
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