May 2022
Part 1: Container return scheme
9. Do you agree with the proposal to exempt fresh milk in all packaging types from the NZ CRS?
a. Yes. Provided that, given ineligibility for a refundable deposit, increased prices are not imposed by producers and this is monitored to ensure price hikes are not introduced.
10. Do you support the Ministry investigating how to target the commercial recovery of fresh milk beverage containers through other means?
a. Yes. We are particularly supportive of the stakeholder engagement mentioned and the Restaurant Association is willing and able to be a part of this conversation to ensure any future recovery scheme is fit for purpose for both the Hospitality sector and in achieving the government’s goals.
19. Do you agree that a NZ CRS should use a ‘mixed-return model’ with a high degree of mandated retail participation to ensure consumers have easy access to container return/refund points, as well as the opportunity for voluntary participation in the network by interested parties?
a. Yes. For ease of participation in the scheme, easy access to return / refund points will be essential. We particularly agree with the proposal for supermarkets to act as return points given their large sites and business models, coupled with the possibility for other organisations and businesses to opt-in as a return point where it is feasible for them to do so.
21. Retailers that sell beverages are proposed to be regulated as part of the network (mandatory return-to-retail requirements). Should a minimum store size threshold apply?
a. Yes. Over 200m^2. Many smaller retailers simply do not have the space to provide return point services and given that those in smaller venues will be small businesses, the added responsibility of providing such a service will inevitably impact daily operations.
Part 3: Separation of business food waste
68. Should commercial businesses be expected to divert food waste from landfills as part of reducing their emissions? Y/N – Additional comments
a. Yes. With a caveat that commercial businesses should be supported, rather than expected, to achieve this. For small businesses, in particular those in the Hospitality sector, we are facing a significant amount of change due to government policy and this comes at a time of extreme hardship due to the legacy impacts of Covid-19. The compliance costs that come with these changes will impact our bottom lines, and given the varied (and often insufficient) access to processing services, businesses should be supported to divert food waste from landfill through Government investment in the expansion of such services.
69. Should all commercial businesses be diverting food waste from landfills by 2030? Y/N – Additional comments
a. Yes. On the provision that it is as simple as possible for this to be achieved. We believe that adequate action to address commercial food waste will take a collective effort, so should be implemented for all businesses – not just those who are deemed more wasteful than others.
b. We recommend that consideration be given to the different capabilities of businesses and in particular small businesses when considering the implementation of obligations to separate food waste from other waste.
Consideration of the more limited resources a smaller business may have, including staff availability, space limitations and the ability to have separate facilities.
70. Should separation be phased in, depending on access to suitable processing facilities (eg, composting or anaerobic digestion)? Y/N – Additional comments
a. Yes. As with the approach to the proposed improvements to household kerbside recycling, it should be as easy as possible for businesses to minimise their food waste. Therefore it makes sense to ensure adequate processing facilities for food waste are available before implementing food waste diversion requirements.
b. The suitability of existing facilities will vary and it is expected that significant infrastructure developments will be necessary. The proposals will fall at the first hurdle if suitable infrastructure is not already in place.
71. Should businesses that produce food have a shorter lead-in time than businesses that do not? Y/N – Additional comments
a. No. The Hospitality sector has been significantly impacted by the pandemic, and has only recently been able to begin our recovery. Further, many businesses which produce food already have food waste minimisation strategies in place, and rushing through new requirements for Hospitality businesses will only add to the pressures we are currently experiencing and move our current engagement in minimising food waste from one of voluntary involvement to a regulatory check box exercise.
72. Should any businesses be exempt? Y/N – If so, which ones? Please explain your answer here.
a. No. Again, adequate action to address commercial food waste will take a collective effort, and industries should not be exempted just because their food waste is considered less than others.
b. However, we note again, that consideration needs to be given to the different capabilities of different types and sizes of businesses and recommend an approach that reflects this.
73. What support should be provided to help businesses reduce their food waste? Please explain your answer here.
a. When surveyed on this question, our members said the biggest support that could be provided to business is the expansion of food recovery services and better availability of composting alongside landfill and recyclable waste. Many of our members also have existing relationships with pig farmers who use food scraps which would otherwise be sent to landfill, and supporting easier access to these farmers would be extremely well received. Further work should also be undertaken to educate and change public behaviour in relation to food waste, which we acknowledge is inherent in Part 2 of this proposal, but explicit work outlining to the public the impact of food waste – particularly when it comes to over ordering when eating out, as our members have raised – would be very helpful.
Summary
In summary, we are broadly supportive of the proposals we have commented on. In many cases, operators in our industry already have effective waste minimisation initiatives in place, and we want to ensure that businesses are well supported through the implementation of new standards, have time to refine their current systems to meet future requirements and that increased costs are not imposed on our small business owners as a result of legislation.