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Three organisations working to prevent and mitigate plastic pollution - the Aotearoa Plastic Pollution Alliance (APPA), the New Zealand Product Stewardship Council (NZPSC) and Para Kore - welcome the Ministry for the Environment’s recently-released National Plastics Action Plan, but say it could go much further.

The Ministry produced the Plan in response to a recommendation by the Prime Minister’s Chief Science Advisor in the 2019 report Rethinking Plastics in Aotearoa New Zealand.

Those at the frontlines of the plastic pollution crisis recognise the need for a national plan that provides a strategic and ambitious focus to address plastic pollution in Aotearoa and Oceania, which has devastating effects on wildlife and environment, and worrying human health effects.

However, the Plan lacks concrete and measurable targets, actions and investments at the top of the waste hierarchy, acknowledgement of Te Tiriti o Waitangi and mātauranga Māori, and does not address the human and ecological health impacts of chemical additives and microplastics.

“The Plan begins rightfully noting the “opportunity to change behaviours, and redesign products, services and systems to avoid using plastics, and enable plastic reuse and repair,” and notes important work already underway, like phasing-out some single-use and hard-to-recycle plastics.

“What’s critically missing, however, is a comprehensive list of actions and timebound, measurable plastic pollution reduction targets,” says NZPSC trustee, Dr. Trisia Farrelly.

“We want to see a plan with actions to support a shift towards a safe and regenerative economy with reduce, reuse, refill and repair at the forefront, and a regulatory pathway to protect human health and our environment from hazardous plastics,” Dr. Farrelly adds.

“Of utmost importance is that a national plastics pollution prevention plan for Aotearoa engages with mātauranga Māori and partners with iwi and hapū. Māori plastic pollution researchers and experts are leading in this space and should have a key role in developing and implementing a national response,” says Para Kore Kaihautū Matua, Jacqui Forbes.

APPA is concerned that the Ministry favours driving the Plan with industry, rather than working primarily with communities, researchers, local government, and tangata whenua.

“We have to face up to the vested interests of industry. We would rather the Government build strong partnerships with scientists and communities - giving voice to those most affected by plastic pollution, rather than those who benefit. We need stronger signals from the Government to require producers to pay for the pollution they create, including to cover clean-up costs, as is being considered or already implemented in places like Europe,” says APPA Chair, Liam Prince.

The Plan frequently identifies “the way we use plastics” as causing harm while simultaneously calling for the “sustainable use of plastic”.

“This focus on the consumer’s ‘use of plastics’ and more ‘sustainable use’ risks maintaining the current (destructive) linear system of take (natural resources), make (stuff) and throw away. In the face of climate change and the collapse of ecosystems, leaders globally are calling for urgent and transformational change,” says Forbes.

Almost all plastics are made from non-renewable fossil carbon. Many hazards stem from the way plastic resins and products are produced, manufactured and designed. Plastic products shed microplastics while in use, and many emit methane and leach toxins as they degrade.

Toxicity of consumer plastics is a growing area of international research, and the Plan should address these safety concerns, particularly as a food and beverage contact material. This would require measures to control the toxic additives and building blocks (monomers) that go into plastic products. The Plan should also inform manufacturers, consumers, and waste managers of the toxic content of products and packaging and how to most safely use and dispose of them.

Many of the Plan’s proposed actions are worthwhile, but they are heavily focused on end-of-pipe solutions, rather than reducing problematic plastics at source before they become persistent pollutants. Reuse and repair systems will help reduce plastics consumption, and the Plan should contain concrete actions to increase them. Prevention is safer for people and the environment, and far more cost-effective than cure.

“The Plan’s focus on behaviour change leaves little room for details on regulation. For example, while consumer confusion about what can and can’t be recycled is an issue, overseas evidence shows that setting goals for mandatory collection is the best way to increase return rates for recycling or reuse. Container deposit return systems are a good example,” says Dr. Farrelly.

“The plan also needs to elaborate on how proposed product stewardship schemes can ensure that plastic supply is restricted only to types of plastics that are essential and that can be safely and responsibly managed, that ensure greater reuse, and a shift of the cost burden away from local authorities and taxpayers and onto producers.”

“Aotearoa has leading researchers in the area of plastic pollution. What is clear is that we do not have time to waste and the level of transformation required is vast,” says Prince.

The three organisations welcome the opportunity to support the development of a revised plan that reflects the scale of the crisis and the urgency with which we need to act.

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