Submission on the Proposed Product Stewardship Regulations for Agrichemicals, their Containers, and Farm Plastics

1 June 2025

Ministry for the Environment

Manatū mō te Taiao

PO Box 10362

Wellington 6143, New Zealand

Submitted via MfE Citizen Space consultation hub

Tēnā koutou katoa,

Re: Submission on proposed product stewardship regulations for agrichemicals, their

containers, and farm plastics

The Federation of Business and Professional Women New Zealand (BPW NZ) seeks

solutions to reduce emissions and address climate change, noting it impacts women and

girls disproportionately. We are more vulnerable, constituting the majority of the world’s

poor and are more likely to have roles in agriculture, water management and household

responsibilities, particularly in developing countries. Social, political and economic

barriers compound women and girls' ability to respond to the consequences that climate

change will have on their lives.

We support proposals to enable a national take-back and recycling scheme for agrichemicals, their containers, and farm plastics.

We therefore strongly support option 1 as outlined in the consultation document, so that

regulations are enacted which would address the shortcomings of the current voluntary scheme.

We note however that the proposed regulations only apply to the specific agricultural products listed in the consultation document, and acknowledge that this limited scope allows for quick implementation of the scheme as a first step. We urge that planning immediately begin to enlarge the scheme to include further agricultural materials as soon as possible.

For over twenty-five years, we have called for action in the product stewardship space.

Specifically, we urge the Minister for the Environment to fast track legislation on Product

Stewardship, with the introduction of Product Stewardship principles into the NZ Waste

Management landscape, with all parties concerned from producer, to importer, brand owner,

retailer and others involved in putting a product and its packaging on the market, taking

responsibility for the environmental impacts of that product throughout its life cycle. We call for this to be backed up by appropriate legislation to ensure compliance and equity among industry participants and that the time frame for this be three to a maximum of five years.

We have policy on waste minimisation, asking the government to build on existing initiatives and legislation and implement national waste minimisation and management strategies.

We also have a product stewardship policy specific to plastics, that urges the Government to

include plastic containers as a priority product for product stewardship.

Our Organisation

BPW NZ is an affiliate of BPW International. BPW International is one of the most influential

international networks of business and professional women with affiliates in over 120 countries in five continents. BPW International has General Consultative Status at the United Nations through the UN Economic & Social Council (ECOSOC). This enables BPW International to appoint official representatives to UN agencies worldwide and to accredit members to attend specific UN meetings.

Our submission is informed by our government’s commitments to United Nations mechanisms, including the:

● Beijing Platform for Action

● Convention on the Elimination of All Forms of Discrimination against Women (CEDAW)

● Convention on the Rights of Persons with Disabilities (CRPD)

● Convention on the Rights of the Child (CRC)

● United Nations Global Compact

● Sustainable Development Goals (SDGs)

Thank you for the opportunity to provide our submission and we hope that our comments are of use. BPW NZ would like to be involved in more consultation engagements should they occur and we would appreciate the opportunity to continue to offer a voice for women in your work. We ask that as much notice as possible is provided for invitations, this gives us time to engage with our membership and provide more informed input.

On behalf of New Zealand Federation of Business and Professional Women Inc.

Janet Gibb, President

BPW New Zealand