Proposed product stewardship regulations for agrichemicals, their containers, and farm plastics

Agrichemical containers and their residual agrichemicals

Many New Zealand farmers regularly use chemicals to control pests, weeds and diseases. These are also used in other sectors (eg, forestry, industry, utilities, infrastructure, recreation), by local and central government, and in households. 

Agrichemicals can become surplus when land management or land ownership changes, chemicals expire, or chemicals are deregistered. Agrichemicals are by intent toxic. They pose a risk to human health and the environment if inappropriately used, stored or disposed of.⁶ Over time, stored waste agrichemicals can enter the surrounding environment from perished containers,⁷ or during natural disasters.⁸ The release of toxic chemicals to air, soil and water can harm crops, livestock, humans and ecosystems.

Some agrichemicals, particularly older ones, can contain persistent organic pollutants (POPs). POPs do not degrade in plants, animals or the physical environment. Rather, they accumulate up the food chain, posing a long-term health risk to humans and ecosystems. Many agrichemicals declared as POPs have been deregistered for use in New Zealand, but they still arise from agrichemical collections, particularly when farming systems or farm ownership change.⁹

Unused or unwanted agrichemicals cannot be recycled. If they cannot be used legally for their intended purpose, they must be safely neutralised or destroyed, to reduce the risk to the environment.¹⁰

The packaging used to supply and mix agrichemicals is also potentially toxic unless adequately cleaned. Some packaging can be recovered and recycled, if triple-rinsed to remove chemical residue (exceptions are oil-based products and POPs, or unknowns).

⁶ Ministry for the Environment. 2019. Proposed priority products and priority product stewardship scheme guidelines: Consultation document (PDF 9.2MB). Wellington: Ministry for the Environment.

⁷ Environment Canterbury Regional Council. 2015. New Zealand Rural Waste Minimisation. Phase 1 Risk Assessment. Summary Report (PDF 1.2MB). Report No. R15/145, prepared for Environment Canterbury by True North Consulting Ltd.

⁸ For example, the 2023 cyclonic floods in Hawke’s Bay, or the landfill spill-over into the Fox River in 2019.

⁹ For example, after decades of waste agrichemical collections co-funded by regional councils and the Government, the Government co-funded a DDT Muster to collect the remainder. This project found many examples of stored DDT which could not be collected for destruction, due to user-pays constraints (Ministry for the Environment. 2019. Proposed priority products and priority product stewardship scheme guidelines: Consultation document (PDF 9.2MB). Wellington: Ministry for the Environment. p 40).

¹⁰ Agrecovery and a number of other commercial companies provide these services. 

Farm plastics

Opinion surveys consistently show majority support for better management of waste, including plastics.¹¹

It is estimated that over 13,000 tonnes of farm plastics were sold in New Zealand in 2019, in the categories of agrichemical containers and drums; bale wrap and silage sheet; and seed, feed and fertiliser bags.¹² For other categories, the quantities are unknown. Sales of farm plastics are projected to increase (appendix 1).

Farm surveys indicate that many farm plastics are burnt, buried or stored indefinitely on-farm.¹³ This may breach the legislation for hazardous substances and their disposal.¹⁴ The open burning of plastics releases air pollutants and toxic substances, such as dioxins, which can contribute to significant health problems.¹⁵

Some farmers pay to send their waste to consented landfills. This poses a lower environmental risk than on-farm burning, burial or storage, since consented Class 1 landfills are engineered to minimise disposal impacts. 

Farm plastics are also recognised internationally as a significant source of microplastics in the environment.¹⁶

In addition, burning, burying or landfilling farm plastics removes the opportunity to recover resources for recycling.

Possible underlying causes of current disposal practices include:

• limited availability of convenient and low- or no-cost alternatives for farmers and other consumers
• limited knowledge of available alternatives
• lack of awareness of the potential impacts of burning and burying waste.

¹¹ See, for example, Ministry for the Environment. Research into attitudes to waste and recycling. Retrieved 21 March 2025.

¹² Agrecovery Foundation. 2022. Green-farms Product Stewardship Scheme Co-Design Report (PDF 9.4MB). pp 15–16.

¹³ Hepburn I, Keeling C. 2013. Non-natural Rural Wastes - Site Survey Data Analysis: Summary Report (PDF 2.6MB). Environment Canterbury Report No. R13/97. Prepared for Environment Canterbury.

       Matthews J. 2014. Rural waste surveys data analysis Waikato & Bay of Plenty (7.9MB). Waikato Regional Council Technical Report 2014/55. Prepared for Waikato Regional Council by GHD Ltd.

       Reynolds, S. 2022. Burning Plastic. Understanding the behavioural patterns of Sheep and Beef farmers related to farm waste streams (PDF 2.3MB). Report prepared as part of the Kellogg Rural Leadership Programme.

¹⁴ That is, the Hazardous Substances (Disposal) Notice 2017 (PDF 264KB) and Health and Safety at Work (Hazardous Substances) Regulations 2017 (New Zealand Legislation).

¹⁵ Verma R, Vinoda KS, Papireddy M, Gowda ANS. 2016. Toxic Pollutants from Plastic Waste - A Review (ScienceDirect). Procedia Environmental Sciences 35: 701–708.

¹⁶ Food and Agriculture Organization of the United Nations (FAO). 2021. Assessment of agricultural plastics and their sustainability: A call for action. Rome: FAO.

Regional rules for on-farm waste disposal

Regional councils have used their powers under the Resource Management Act 1991 (RMA) to control on-farm waste disposal, which is typically a permitted activity. All regional councils have rules for disposal sites (also known as farm dumps, waste pits, etc). The rules vary across councils, but generally aim to avoid the negative effects.

Some councils prohibit outdoor burning of all plastics, while others prohibit it for certain types (eg, chlorinated, polyvinyl chloride, or halogenated plastics). Enforcing these rules can be a challenge.

Voluntary initiatives have plateaued

Since 2006, two voluntary product stewardship schemes have offered take-back services to the rural community for agrichemical containers and residual agrichemicals, and for some farm plastics. Each scheme has made steady progress within a voluntary framework (appendix 2), but engagement by producers and farmers has plateaued. Moreover, a wide range of farm plastics are currently not covered by any scheme.

Agrecovery operates a scheme for agrichemical containers and drums, including their residual agrichemicals. Farmers can drop them off at any of the 160 collection sites throughout the country, mostly at agrichemical retailers or council sites. The scheme is funded through fees paid by participating producers. It collects around 50 per cent of containers and drums sold by member companies (around 629.5 tonnes were collected in 2023).¹⁷ Currently, 120 agrichemical brands (estimated to represent the majority of the market) are Agrecovery members. 

Plasback operates a user-pays scheme for collecting some farm plastics, mainly bale wrap and silage sheet. Farmers can drop off their plastics for a fee at a Plasback collection point. Alternatively, farmers can buy Plasback bins or liners, which Plasback then collects for a fee from the farm once filled. Plasback collected around 5,500 tonnes of bale wrap and silage sheet for recycling in 2022, and around 6,100 tonnes in 2023.¹⁸ This is about half of the total quantity of these products sold in the preceding year. 

Two main factors influence participation in voluntary schemes and, consequently, product recovery rates:

• producers’ incentive to join and fund a scheme
• consumers’ incentive to use a scheme.

Producers may be reluctant to participate in voluntary producer-pays schemes when their competitors can opt out and gain market advantage through reduced costs. In turn, this limits the funds available to the scheme to cover the costs of collecting and managing the end-of-life products. As a result, the take-back service may not be convenient enough, or cover the full list of products, and farmers may not be aware of the scheme or its benefits.

In the case of consumer-pays schemes, the fee-for-service model can also discourage farmers from using this option, leading to instances of on-farm burning and burial.

¹⁷ See table 6 in appendix 2.
¹⁸ See table 7 in appendix 2.

Barriers to improving end-of-life management

The current barriers to improving management of end-of-life agrichemicals, their containers, and farm plastics include:

• limited availability of convenient and low- or no-cost alternatives to on-farm disposal
• limited awareness among farmers (and other consumers) of available alternatives
• limited incentives for producers and importers to join voluntary stewardship schemes, which limits the funds available to collect and manage end-of-life products
• lack of farmer awareness of the potential impacts of on-farm disposal such as burning and burial
• difficulty of enforcing any existing regional rules on burning and burying farm waste.

For household pest and weed control products, the main barriers are similar and include:

• limited availability of collection and recycling schemes that are convenient and free or low cost for consumers
• limited awareness of available alternatives to disposal in mixed rubbish
• limited incentives for producers and importers to join voluntary stewardship schemes.

The WMA has various tools for improving the management of waste. One is regulated product stewardship. This is where regulations require producers and importers to take more responsibility for the end-of-life impacts of products they place on the New Zealand market.

Voluntary product stewardship schemes have been accredited under the WMA since 2010. Movement towards regulated schemes started in 2020, when the Government declared six product groups a priority, namely:

• tyres
• electrical and electronic products (e-waste)
• refrigerants and other synthetic gases
• agrichemicals and their containers (this consultation)
• farm plastics (this consultation)
• plastic packaging.¹⁹

The declaration was informed by public consultation, which indicated majority support.²⁰

Once a product is declared a priority, a stewardship scheme for the product must be developed and accredited as soon as practicable. Regulations can also be made for priority products – for example, to require that they are only sold and distributed in accordance with an accredited product stewardship scheme.²¹

There are two stages in developing regulated product stewardship schemes.

1. A product stewardship scheme is developed and accredited.
   1. It is co-designed with stakeholders (eg, industry groups, recyclers, other key stakeholders).
   2. The scheme manager applies for accreditation.
   3. The Minister for the Environment makes a decision on accreditation.
   4. If the new scheme has evolved from an existing accredited voluntary scheme or schemes, a transition period is required until the previous scheme’s accreditation expires or is revoked.
2. The Government may make regulations to support an accredited scheme.
   1. The public is consulted on proposed regulations (this consultation).
   2. The Government makes a decision on proposed regulations, if supported.
   3. Regulations come into effect.

If regulations are not made, accredited schemes may operate on a voluntary basis.

The co-design process for agrichemicals, their containers, and farm plastics was completed in 2022. This led to a new scheme, provisionally named the Green-farms Product Stewardship Scheme (Green-farms) according to its accreditation (see section 2.3 below). For details of the co-design see appendix 3.

Information on progress for the other priority products is on our website.

¹⁹ New Zealand Government. 2020. New Zealand Gazette. Declaration of Priority Products Notice 2020 (updated 29 September 2020).

²⁰ Ministry for the Environment. 2020. Proposed priority products and priority product stewardship scheme guidelines: Summary of submissions (PDF 2.7MB). Wellington: Ministry for the Environment.

²¹ For the list of regulations, see section 22 and section 23 of the WMA.

The accreditations of the two voluntary schemes run by Agrecovery and Plasback (described in section 2.1) expired in 2024. The new scheme, provisionally named Green-farms, is intended to combine these schemes.

This scheme was accredited in October 2023 but is not yet operational, pending government decisions on supporting regulations. The product stewardship organisation (PSO) managing the scheme is the Agrecovery Foundation, which is a not-for-profit charitable trust governed by a board of trustees (representatives of the primary production sector).²²

If regulations proceed, it would replace the two voluntary schemes. If regulations are not made, the new scheme could either start operating on a voluntary basis, or not proceed. The latter outcome is more likely, as it was co-designed by industry as a regulated scheme, in line with the broad intent of the priority product declaration.

²² Agrecovery trustees represent Federated Farmers, DairyNZ, Horticulture New Zealand, Animal and Plant Health New Zealand, Rural Contractors New Zealand, distributors of agrichemical and animal health products, and local government.

Scope

The new Green-farms scheme will initially cover the four farm product categories that generate the most plastic waste on-farm, namely:

• plastic agrichemical containers and drums (1,000 litres or less) for recycling and any residual agrichemicals²³ for safe destruction (including household pest and weed control product containers and residual chemicals)
• plastic bale wrap and silage sheet 
• small plastic bags (40 kilograms or less when full) that contained products such as seed, feed, fertiliser, soil and crop inputs, farm and animal supplements
• bulk woven polypropylene bags (over 40 kilograms when full) that contained products such as seed, feed, fertiliser, soil amendments, minerals and bulk nutrition. 

In addition, the scheme may progressively include other plastic waste, based on the schedule in table 1. These categories will not be mandatory, unless further regulations are proposed in the future (this is out of scope for this consultation).

Table 1: Proposed schedule for phase-in of farm plastic waste streams

In the first accreditation period (until 2030), the scheme will not cover plastic products used in farm households (eg, packaging for consumer items), other than household pest and weed control products, which are included in the agrichemicals stream. However, collaboration with other schemes that focus on these products may be an option.

²³ For non-residual/bulk agricultural chemical recovery and disposal, Agrecovery will continue to provide a user-pays service. It will also work with local government to support the agrichemical component of hazardous waste collections, where these are provided.

How it works

As mentioned above, the scheme is not operating yet, pending government decisions on supporting regulations. This section outlines how it will work, according to its accreditation.

As accredited, the scheme will expand a nationwide network of free-to-use take-back sites where farmers and other consumers can drop off their waste in-scope products. The sites will be in or near places that farmers would already be using, such as towns and urban centres, rural supplies merchants, and service providers for the rural sector. More remote farmers and growers, with enough waste, will be offered free on-farm collection. As is the case now, farmers could also contract private waste collectors for more frequent or out-of-scope services.

There will be at least eight regional recovery hubs²⁴ for farm plastics. These would be responsible for sorting, cleaning, and baling and bundling the plastics for domestic recycling or export. They will be managed under contract by the PSO. The scheme will recycle as much of the collected material as possible. It may be necessary to landfill non-recyclable materials or components. 

For recycling, any exports of plastics must comply with the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.²⁵ Although exports are currently necessary, the scheme aims to expand local plastic recycling markets so that exports may not be necessary in the future.

The scheme’s funding model is to recover the cost of collection and management through fees paid by producers or importers. This will provide free-to-use take-back services to farmers and other consumers. The scheme was designed on the assumption that regulations would require producers and importers to sell in-scope products only in accordance with the accredited scheme, and pay a product stewardship fee. In the co-design process the sector supported this approach.

²⁴ The eight regions are: Southland and Otago; Canterbury; Nelson, Marlborough and the West Coast; Wellington, Manawatu and Whanganui; East Coast, North Island; Waikato and Central North Island; Bay of Plenty and Thames Valley; Auckland and Northland.

²⁵ For more information, see Ministry for the Environment. Basel Convention. Retrieved 21 March 2025.