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

Appendices

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Appendix 1: Annual sale quantities of agrichemical containers and other farm plastics Appendix 1: Annual sale quantities of agrichemical containers and other farm plastics

The figures below show the estimated product quantities sold in New Zealand for the categories covered by the accredited scheme.

The 2017–2019 data for small bags, large bags, bale wrap and silage sheet is based on a survey of retailers and producers by PwC for Agrecovery in 2020.³⁹ The results were extrapolated for subsequent years by applying an estimated annual growth rate per product type.⁴⁰

For agrichemical containers, the data are based on actual sales data from companies participating in Agrecovery’s current voluntary scheme, as recorded in their Statement of Service Performance Report 2019. These data were increased by 25 per cent to account for non-participating brands. The quantities were extrapolated for subsequent years by applying an estimated annual growth rate of 6 per cent.

Figure 1: Quantity of bags and agrichemical containers sold annually

Figure 2: Quantity of bale wrap and silage sheet sold annually

³⁹Agrecovery Foundation. 2020. Farm Plastics Priority Product Stewardship Scheme: Materials Flow Analysis (PDF 1.2MB). Prepared for the Agrecovery Foundation by PwC.

⁴⁰ Small feed bags: 6% per year; small seed bags: 5% per year; small fertiliser bags: 0% per year; large bags: 3% per year; bale wrap and silage sheet: 4% per year.

Appendix 2: Amount of farm plastics collected by Agrecovery and Plasback Appendix 2: Amount of farm plastics collected by Agrecovery and Plasback

Table 6: Agrichemical containers and other farm plastic quantities collected by Agrecovery, 2021–23 (tonnes)

Product	Plastic type	2021	2022	2023
Bale wrap	Linear low-density polyethylene (LLDPE)	-	-	826
Small bags	Low-density polyethylene (LDPE)	3	5	27
Small bags	Woven polypropylene (PP)	-	4	18
Containers and drums	High-density polyethylene (HDPE)	473	532	629.5
Bulk bags	PP	125	146	82
Wool fadges	HDPE	-	111	34
Twine	PP	-	-	25
Animal health products	HDPE and LDPE	-	-	0.5
Hail netting	HDPE	-	-	20
Total		601	798	1,662

Source: Agrecovery. 2024. Personal communication.

Table 7: Farm plastic quantities collected by Plasback, 2021–23 (tonnes)

Plastic type	2021	2022	2023
LLDPE	2,100	4,900	5,500
LDPE	22	16	83
Medium density polyethylene (MDPE)	-	120	21
HDPE	150	45	138
PP	329	412	370
Total	2,601	5,493	6,112

Source: Plasback. 2024. Personal communication.

Appendix 3: Co-design of the Green-farms Product Stewardship Scheme Appendix 3: Co-design of the Green-farms Product Stewardship Scheme

The Agrecovery Foundation led two co-design processes with stakeholders (funded by the Waste Minimisation Fund) for product stewardship schemes covering:

agrichemicals and their containers, reporting in 2020
farm plastics (including an update to the co-design for agrichemicals and their containers), reporting in 2022.

The elements of both schemes were combined into the Green-farms scheme and proposed to the Ministry in June 2022.

Table 8 lists the stakeholders consulted in the two co-design processes.

Table 8: Stakeholder engagement in the Green-farms co-design⁴¹

Dates	Activity	Participating stakeholders
1 April 2019 / 17 June 2019 / 26 August 2019	Three stakeholder meetings, as part of the co-design process for a scheme covering only agrichemicals and their containers.	3R Group Agcarm Agrecovery Ballance Agri-Nutrients Chemwaste Industries Ecolab Federated Farmers GEA FIL Fonterra Gisborne District Council Horticulture New Zealand MSD PGG Wrightson Ravensdown Rural Contractors Sustainable Winegrowing NZ Syngenta Synlait Milk Timaru District Council True North Consulting Wairarapa Weedsprayers Waste Management Technical Services WasteMINZ
November–December 2019	Survey of agrichemical brand owners on proposed fee rates for different categories of agrichemicals, to understand financial impact.	Survey circulated to 61 brand owners, of which about 50% responded.
22 June 2020	Webinar: Farm Plastics Product Stewardship.	Attended by 56 stakeholders.
June–July 2020	Survey (by PwC) to quantify farm plastics used in 2017, 2018 and 2019, and gather perceptions of existing services for farmers and growers to manage disposal of farm plastics.	Survey sent to 42 retailers and producers of seed, feed and fertiliser bags and crop packaging films, who together represented the largest participants in the sector – response rate was 71%, including all major sector participants.
19 August 2020 / 4 May 2021 / 15 December 2021	Farm Plastics Advisory Group meetings.	Producers, industry associations in the agricultural sector.
2 November 2020	Farmer Reference Group Meeting, discussing scheme options.	Six representatives from farmer and grower groups.
November 2020	Nine one-stop shop events in Canterbury, trialling drop-off centres for farm plastic waste. Interviews with farmers and growers to understand their preferences and determine if the centres would work.	Farmers and growers.
January 2021	Farmer and grower survey, gathering feedback on preferences for farm plastics recycling schemes.	Survey sent to all members of Federated Farmers and Horticulture NZ – 132 responses received.
24–25 March 2021	Sixteen interviews with farmers and growers during the South Island Agricultural Field Day in Kirwee, Canterbury.	Farmers and growers.
14 May 2021	Meeting with Plasback, discussing scheme options and Ministry guidelines for product stewardship schemes.	Plasback.
14 June 2021 / 17 November 2021	Bale Wrap and Silage Film Reference Group meetings.	Six producers of bale wrap and silage film.
25 August 2021	WasteMINZ webinar, presenting an update on the Farm Plastics Project.	WasteMINZ Product Stewardship Sector Group.
15 September 2021	WasteMINZ webinar to the Territorial Authorities Officers Forum, updating on the Farm Plastics Project, followed by one-on-one engagement with several territorial authorities.	Territorial Authorities Officers Forum.
4 November 2021	Visit of farm retail stores in Fielding to understand the small seed, feed and fertiliser bag market.	Farm retailers (Farm Source, PGG Wrightson, Farmlands).
11 November 2021	Presentation to Between the Domes Catchment Group, giving an overview of the Farm Plastics Project, with a pitch to run a trial in Southland to test the design thinking.	Between the Domes Catchment Group.
17 March 2022	Presentation to the NZ Feed Manufacturers Association.	NZ Feed Manufacturers Association.

⁴¹Agrecovery Foundation. 2022. Green-farms Product Stewardship Scheme Co-Design Report (PDF 9.4MB). pp 110–114.

Appendix 4: Preliminary assessment of the policy options Appendix 4: Preliminary assessment of the policy options

Through the proposed policy measures, our aim is to significantly reduce harm to people and the environment arising from agrichemicals, their containers, and farm plastics when they become waste.

We have assessed the options under consideration based on three criteria, which are outlined in table 9.

Table 9: Criteria for assessing the options

Criterion	Description
Effectiveness	Is the option likely to support achievement of the policy objective (ie, significantly reduce harm to people and the environment arising from agrichemicals, their containers, and farm plastics when they become waste)?
Supply chain responsibility	Is the option likely to: move a fair share of costs and responsibilities for product impacts from the public and councils to the producers and consumers encourage full sector participation and shared responsibility for achieving the policy objective?
Efficiency (costs and benefits)	Does the option add costs to affected parties? Do the expected additional benefits of the option (relative to the status quo) outweigh the expected additional costs?

Criterion

Description

Effectiveness

Is the option likely to support achievement of the policy objective (ie, significantly reduce harm to people and the environment arising from agrichemicals, their containers, and farm plastics when they become waste)?

Supply chain responsibility

Is the option likely to:

move a fair share of costs and responsibilities for product impacts from the public and councils to the producers and consumers
encourage full sector participation and shared responsibility for achieving the policy objective?

Efficiency (costs and benefits)

Does the option add costs to affected parties?
Do the expected additional benefits of the option (relative to the status quo) outweigh the expected additional costs?

The objective and assessment criteria directly relate to the problem identified in section 2.1. The criteria also align with the objective of product stewardship in section 8 of the WMA, namely to:

…encourage (and, in certain circumstances, require) the people and organisations involved in the life of a product to share responsibility for—

a) ensuring there is effective reduction, reuse, recycling, or recovery of the product; and

b) managing any environmental harm arising from the product when it becomes waste.

Table 10 presents a preliminary assessment of the two options against these criteria.

Table 10: Preliminary assessment of the options

Criterion	Option 1 – Introduce WMA regulations	Option 2 – No action (maintain the voluntary approach)
Effectiveness Is the option likely to help us achieve the policy objective (ie, significantly reduce harm arising from agrichemicals, their containers, and farm plastics when they become waste)?	Yes The obligation to ‘act in accordance with the scheme’ and pay stewardship fees is likely to increase product collection (since the fees will generate the funding for take-back services, which farmers can use for free). This reduces the incentive for burning or burying on-farm. It also reduces the harm from landfilling and losing recyclable resources, as the product is collected for recycling.	No If the current voluntary approach continues, producers’ and importers’ participation in stewardship schemes is unlikely to increase significantly. Without the higher fee revenue from increased producer/importer participation and efficiencies of scale, take-back and recycling services are unlikely to expand significantly, and some parts of the country would remain poorly serviced. Also, it is not guaranteed that the voluntary schemes would continue to operate. Therefore, on-farm disposal of in-scope products is unlikely to decrease.
Supply chain responsibility Is the option likely to:	Shift a fair share of costs and responsibilities to producers and product consumers?	Yes There would be a fee on imports and domestic manufacture of agrichemicals sold in specified containers, and on the most-used farm plastics (bale wrap and silage sheet, small and large bags). The fee would cover end-of-life management. The fee would likely be passed on to consumers through the price of the products, but take-back services would be free of charge to consumers. The end-of-life costs are therefore shifted from councils and communities to producers and consumers.	No Under the current voluntary approach, only those agrichemical producers / importers who opt in to the Agrecovery scheme and those farmers (and other consumers) who choose to pay for Plasback collections share costs and responsibility for the end-of-life management of their products. It is not always feasible for the Agrecovery collection to exclude non-participating brands. This adds costs, borne by the participating producers.
Encourage full sector participation and shared responsibility for achieving the policy objectives?	Yes All producers and importers of the regulated products must participate in and comply with the accredited scheme. This creates a level playing field for those sectors.	No It is unlikely that sector participation will increase if the current voluntary arrangements continue.
Efficiency (costs and benefits)	Does the option add costs to affected parties?	Yes There would be costs for regulated producers and importers (eg, record-keeping, reporting to the PSO, paying stewardship fees). For agrichemical producers and importers that already participate in the Agrecovery voluntary scheme, these costs would replace (at least partly) the voluntary scheme fees. The stewardship fee will likely be passed on to farmers and other consumers through the price of in-scope products. However, the proposed fees are a small proportion of the overall product cost (typically around 1 per cent or less). For consumers who currently pay for Plasback collections, the regulated fees will replace those costs and, in some cases, may result in savings.	No No regulated stewardship fee would be introduced, hence no new costs for producers, importers and consumers.
Do the expected additional benefits of the option (relative to the status quo) outweigh the expected additional costs?	Yes A provisional cost-benefit analysis by the Ministry for the Environment with support from Agrecovery indicates that the net present value (over 30 years) of expected additional benefits is higher than the net present value of additional costs.	Not applicable This option represents the status quo.

Criterion

Option 1 – Introduce WMA regulations

Option 2 – No action (maintain the voluntary approach)

Effectiveness

Is the option likely to help us achieve the policy objective (ie, significantly reduce harm arising from agrichemicals, their containers, and farm plastics when they become waste)?

Yes

The obligation to ‘act in accordance with the scheme’ and pay stewardship fees is likely to increase product collection (since the fees will generate the funding for take-back services, which farmers can use for free).

This reduces the incentive for burning or burying on-farm. It also reduces the harm from landfilling and losing recyclable resources, as the product is collected for recycling.

If the current voluntary approach continues, producers’ and importers’ participation in stewardship schemes is unlikely to increase significantly. Without the higher fee revenue from increased producer/importer participation and efficiencies of scale, take-back and recycling services are unlikely to expand significantly, and some parts of the country would remain poorly serviced. Also, it is not guaranteed that the voluntary schemes would continue to operate.

Therefore, on-farm disposal of in-scope products is unlikely to decrease.

Supply chain responsibility

Is the option likely to:

Shift a fair share of costs and responsibilities to producers and product consumers?

Yes

There would be a fee on imports and domestic manufacture of agrichemicals sold in specified containers, and on the most-used farm plastics (bale wrap and silage sheet, small and large bags). The fee would cover end-of-life management.

The fee would likely be passed on to consumers through the price of the products, but take-back services would be free of charge to consumers. The end-of-life costs are therefore shifted from councils and communities to producers and consumers.

Under the current voluntary approach, only those agrichemical producers / importers who opt in to the Agrecovery scheme and those farmers (and other consumers) who choose to pay for Plasback collections share costs and responsibility for the end-of-life management of their products.

It is not always feasible for the Agrecovery collection to exclude non-participating brands. This adds costs, borne by the participating producers.

Encourage full sector participation and shared responsibility for achieving the policy objectives?

Yes

All producers and importers of the regulated products must participate in and comply with the accredited scheme. This creates a level playing field for those sectors.

It is unlikely that sector participation will increase if the current voluntary arrangements continue.

Efficiency (costs and benefits)

Does the option add costs to affected parties?

Yes

There would be costs for regulated producers and importers (eg, record-keeping, reporting to the PSO, paying stewardship fees). For agrichemical producers and importers that already participate in the Agrecovery voluntary scheme, these costs would replace (at least partly) the voluntary scheme fees.

The stewardship fee will likely be passed on to farmers and other consumers through the price of in-scope products. However, the proposed fees are a small proportion of the overall product cost (typically around 1 per cent or less).

For consumers who currently pay for Plasback collections, the regulated fees will replace those costs and, in some cases, may result in savings.

No regulated stewardship fee would be introduced, hence no new costs for producers, importers and consumers.

Do the expected additional benefits of the option (relative to the status quo) outweigh the expected additional costs?

Yes

A provisional cost-benefit analysis by the Ministry for the Environment with support from Agrecovery indicates that the net present value (over 30 years) of expected additional benefits is higher than the net present value of additional costs.

Not applicable

This option represents the status quo.

Appendices

Appendix 1: Annual sale quantities of agrichemical containers and other farm plastics Appendix 1: Annual sale quantities of agrichemical containers and other farm plastics

Figure 1: Quantity of bags and agrichemical containers sold annually

Figure 2: Quantity of bale wrap and silage sheet sold annually

Appendix 2: Amount of farm plastics collected by Agrecovery and Plasback Appendix 2: Amount of farm plastics collected by Agrecovery and Plasback

Table 6: Agrichemical containers and other farm plastic quantities collected by Agrecovery, 2021–23 (tonnes)

Table 7: Farm plastic quantities collected by Plasback, 2021–23 (tonnes)

Appendix 3: Co-design of the Green-farms Product Stewardship Scheme Appendix 3: Co-design of the Green-farms Product Stewardship Scheme

Table 8: Stakeholder engagement in the Green-farms co-design41

Appendix 4: Preliminary assessment of the policy options Appendix 4: Preliminary assessment of the policy options

Table 9: Criteria for assessing the options

Table 10: Preliminary assessment of the options

Table 8: Stakeholder engagement in the Green-farms co-design⁴¹