2 Definitions (A3) Why is a review required? What is the problem? The Working Group Recommendations this far Next Steps
3 MfE / Industry concerned about effectiveness of the Agrecovery Chemical Programme since withdrawal of Council run collections in understand why Between 1990 and 2012 Central Govt. spent millions on disposal of agrichemicals, particularly focused on legacy – funding ceased in 2012 adding to the User Pays problem Agrecovery Foundation, Local Councils, waste contractors and others concerned about free rider issue / approached MfE about the process for declaring agrichemicals as priority product – reiterated ongoing support from Agrecovery Brand Owners potentially at risk from free riders Why is a review required?
4 Undertake a review that is an industry approach supported by government Not ‘just another academic exercise’ - the expectation is that outcomes and recommendations should be realistic rather than theoretical, with fewer barriers to implementation. The Ministry for the Environment observer attended the Working Group meetings with the aim of facilitating the next phase through Government WMF Deed 20102: The Project
5 25 member Industry Working Group formed Clearly identify effective and preferred product stewardship option(s) for agrichemicals and their associated containers (packaging) Provide advice to Government (via MfE Observer & final report). A Working Group was formed All stakeholders represented
6 Development of guiding principles for future agrichemical and associated container “stewardship programme(s)”, and Desired outcomes of the review Note: As at Feb 2013 the Plasback Scheme for HDPE Plastic Containers were out of scope; however we understand that work is being undertaken to bring them back into scope into the near future. A range of options tabled including how to maximise the effectiveness of current accredited product stewardship programmes (chemicals and containers/packaging).
7 Two significant questions were posed to the Working Group: Do we require priority product declaration for agrichemicals and their associated containers (packaging) because voluntary product stewardship is not working; and Do we need another amnesty? Starting point
8 Issues were: Legacy stockpile growing – how much is out there? Calls for a Last Chance Amnesty Desire to go back to what we had before – all agrichemicals collected, endless pots of money Lack /complexity of funding POPs being left behind because of User Pays Impact on viability of collectors business No provision for urgent chemical collections / in some regions complete withdrawal of service by Local Govt. even for household/garden chems. More broadly
9 Exploring opportunities to maximise the effectiveness of current schemes Issues the Working Group considered
10 Separating fact from fiction biggest challenge How much is out there – no one really knows Regions previously thought cleared still produce significant quantities of agrichemicals year on year Estimates range from 60T to 300T+ – this can be the difference between $1M - $9M – no-one willing to provide enduring funding on such little data Need for clear and auditable data on the volume of intractable agrichemicals remaining in each region including supportive evidence. Legacy - What is the problem?
11 “Ring fence” legacy before we look at future funding No Free Riders: All manufacturers / distributors must have a product stewardship solution for their agrichemicals Investigate removing the rule that moves agrichemicals from funded (Agrecovery) to user pays (Legacy) when they have not have an ACVM registration for two years or more Education: Continue to work on changing farmer/grower behaviour so unused/unwanted agrichemicals are disposed of in a regular cycle and not left until they become legacy Emphasis on pastoral where Supply Chain often fills the GAP requirements applicable to Horticulture Legacy - Solutions
12 A final or Last Chance! amnesty not generally favoured by the working group Does not tend to change behaviour Past amnesties not been successful in “clearing” regions Recognition that some elements of a last chance amnesty are successful though (fully funded with NIL user pays) Alternatively, funding needs to be set aside to clear stockpiles when they are discovered and when natural disasters occur Last Chance Amnesty – yes or no?
13 However, complexity leads to confusion Complex eligibility criteria and funding models creates confusion and potential barriers to interaction User pays for chemical recovery reduces effective volume collected Need all brand owners in a scheme(s) to cease free riding and to simplify the process for all products to minimize confusion for farmers & growers There needs to be strong demonstrable correlation between financial investment in a scheme (in whatever form this occurs) and uplift in take-back activity and quality assurance (best agricultural practice). Mandatory for Brand Owners coupled with Mandatory participation at the user end Funding issues...we can’t go back
14 An agrichemical container (read “packaging”)is regarded as hazardous until such time as it has been satisfactorily “rinsed” and deemed to be non-hazardous. If agrichemicals are to move from a voluntary stewardship programme to a compulsory framework then stewardship of containers will also become compulsory. Presently, only HDPE packaging is “stewarded” in NZ. Packaging
15 No matter how “good” the scheme is it will require farmers to engage with it if it is to achieve the twin hopes of substantial clearance of legacy materials (chemical and packaging) and ongoing minimisation of future stocks on farm; Council financial role in the disposal of agrichemicals potentially diminishing; changes as a result of the review of the Local Government Act 2002 Public / Private Partnerships
16 Evidencing sound disposal of chemicals and containers is critical to meeting supply chain expectations for our export markets; Supply chain and their auditors provide an integral link in the success of a “good” scheme (e.g. GAP, AsureQuality, QCONS); Significant gap between standards required/set by supply chain and those required/set by local councils and all parties in-between – has an impact on future programme design, particularly the need to model a programme that meets our current and future evidencing of good agricultural practice for trade. Use of packaging and packaging types (recyclable, disposable, bulk, reusable) Supply Chain involvement
17 Final report delivered 30/4/13 Working Group preferred option: Declare agrichemicals and their associated packaging as priority products under the WMA2008 Support this with regulatory and legislative action so that participation in the scheme is mandatory for the brand owner, the farmer/grower and all parts of the supply chain in-between. That products are levied at the front end for both the contents and the packaging and that the scheme(s) is flexible and fit for purpose.
18 Working Group made over 14 recommendations including setting targets for future scheme(s): Increasing volume of packaging take back year on year over accreditation period (8 years) Decreasing quantity of legacy chemicals over long term years (noting expect an increase initially as scheme becomes more accessible as funding barriers removed) and use of indicator chemicals as a marker (e.g. DDT) Increase in scheme participants year on year Evidence of wise purchasing (brand owner initiatives supported by rural retailer/distributors) Evidence of education (public / private partnerships) Evidence of collaboration with councils (public/private partnerships) 14 Recommendations
19 Un-trodden pathway Need regulatory/legislative support – how do you “make” farmers / growers participate in a scheme? Data confidentiality issues for Government departments Need to maintain momentum as a result of the stakeholder working group Funding shortfall beyond 2013 for the collection/disposal of legacy agrichemicals “Wait and see what happens” for non-participating brand owners Recognise this won’t be easy!