By Deanne Holdsworth

We talk a lot about circularity in New Zealand. And to be fair, there is real progress. There is intent. There are good people doing good work.

But if we’re honest, the system we have today isn’t truly circular — not at scale, and not consistently, not yet.

The good news is that there is strong intent, and there is real progress. But (and there is always a but) there are still gaps that are painful, persistent and too visible to ignore.

Am I criticizing NZ Product Stewardship? Absolutely not! We need to reflect on the good, the bad and the ugly of product stewardship, learn from both examples in NZ and across the world, reflect where we are today, and ensure that there is a concerted effort to move from ugly to good – that’s why the next step matters so much.

There is genuinely a lot to be optimistic about.

The Good

Across New Zealand, industry-led product stewardship schemes are delivering results. From Agrichem containers to paint pails, plant pots and many other plastics, we are already seeing materials collected, processed and remanufactured into new products – and they are solid programmes, islands of success.  These programmes are because of true desire by brand owners and recyclers alike to make progress in product stewardship.

This drive and impact really matter, proving that circularity is not theoretical in New Zealand, it is already happening.  But… we cannot have just islands of excellence to be impactful.  To have programmes that work consistently at scale, there needs to be proven systems, infrastructure, demand, and regulatory assistance for consistent success.

The Bad: Where Good Intent Meets Reality

The challenge is not intent. We have plenty of that.

The challenge is that intent alone does not make the economics stack up.

Post-consumer materials are rarely clean or consistent. They are contaminated, dispersed across the country, expensive to collect, and even more expensive to process.

At the same time, recycled materials are competing with low-cost virgin alternatives and imported recycled plastics.

Layer on top of that a uniquely New Zealand constraint – we are a small, geographically dispersed market with limited scale, but with world-class ambition.  Because if a system only works when everything goes right — when materials are clean, logistics are perfect, and markets are strong — then it is not a system. It is a best-case scenario.

And best-case scenarios do not hold up in the real world.

The Ugly: When Systems Fail Despite Good Intentions

We have already seen what happens when collection outpaces capability.

Material is collected faster than it can be processed. End markets fail to keep up. Stockpiles grow. And eventually, trust breaks down. Collection alone does not create a circular economy.

Without aligned processing capacity and stable end markets, it simply shifts the problem.

And once material has been collected, there is no easy way back. Social licence is fragile. When systems fail, the reputational damage does not sit with one scheme — it lands across the entire industry.

Consumers don’t distinguish between programmes. Their trust in stewardship is impacted by all systems.

The Obligation

Without a clear and consistent obligation on producers to take responsibility for their products at the end of life, the system remains incomplete.  Extended Producer Responsibility (EPR) is the mechanism that can change this.

EPR shifts accountability away from councils and taxpayers, and back to the companies that place products on the market. That shift matters because it embeds responsibility into the system itself.  I don’t mean to infer that the shift in accountability will provide a rates refund!

When designed well, it creates a level playing field, links cost to design decisions, and enables investment in infrastructure.

This is how we move from voluntary effort to system design.

However, how we implement EPR matters just as much as whether we implement it.

Pact Group New Zealand’s view is clear. A fragmented approach to mandating packaging stewardship piece by piece will not deliver the outcomes we need, will create unintended consequences and unneeded additional cost to the producer and subsequently to the consumer.

The Opportunity

The focus should be on establishing a mandatory, all-of-packaging EPR scheme, supported by the timely passage of waste legislation.

That scheme should be designed to drive the right behaviours and outcomes across the system.

It should prioritise domestic recycling, reprocessing and remanufacturing outcomes, ensuring that materials are managed within New Zealand wherever possible.

And critically, it must provide long-term policy certainty. Without that certainty, it is difficult to unlock the private capital investment needed to build infrastructure at scale.

EPR is not a silver bullet. But it creates the conditions for alignment.

To deliver a system that works, that alignment needs to extend further.

We need:

• Government leadership to set clear direction and durable policy
• Industry responsibility across the full lifecycle
• Infrastructure investment to match collection with processing capability
• Demand for recycled materials, driven by real commitments to recycled content and end-market innovation

Because we only close the loop when all three parts — collection, processing, and demand — are designed to work together.

The good news is that New Zealand already has many of the building blocks in place.

We have capability. We have experience. And we have clear examples of what works.

The need

What we need now is not more effort — it is better alignment:

Between policy and infrastructure
Between packaging design and end-of-life outcomes
Between ambition and investment
If we get that right, we move from a system that depends on goodwill to one that consistently delivers outcomes.

And when that happens, circularity stops being an aspiration — and becomes part of how we do business.