Microsoft Word – 2022.05.22 RBHU Submission on Transforming Recycling.docx
Submission of Raise the Bar Hospitality Union Incorporated
- In March 2022, a consultation document entitled Transforming Recycling was released. This document was prepared by the Ministry for the Environment. It sets out three proposals: A kerbside recycling scheme, a container return scheme, and a scheme for the separation of food waste.
- This letter outlines the submission of Raise the Bar Hospitality Union Incorporated (“RBHU”) in response to the consultation document. Contact details for RBHU can be found at the end of this letter.
About Raise the Bar Hospitality Union
- Since 2018, RBHU has operated as a digital grassroots campaign to improve work conditions in the hospitality sector. In 2021, RBHU held an Initial General Meeting and registered as an incorporated society. On 7 March 2022, RBHU was registered as a union under the Employment Relations Act 2000. RBHU has 196 hospitality workers as union members as of 18 May 2022.
- For this submission, our six-person democratically elected committee has contributed their thoughts on the proposals, based on several decades of experience of working in, and advocating for, workers in the hospitality sector.
Our submission on the proposed container return scheme
RBHU generally supports the proposals for a container return scheme. From examining how similar schemes operate in other countries, such as France and Germany, we believe that a scheme of this nature would also be successful in New Zealand. The rollout of these schemes overseas tells us that an effective container return scheme relies on people being able to easily drop off their recycling on their way to or from work in one of the many “return centres” scattered around towns and cities. For this scheme to work, it is important to make it very accessible to all New Zealanders. Current recycling depots are few and far between in New Zealand, so this scheme would need to base its “return centres” in convenient locations, such as malls, supermarkets, and city centres.
RBHU strongly supports the introduction of a refund, as this provides a strong incentive to recycle for private consumers as well as businesses, including hospitality venues. Regarding the nature of the refund, it would be great if refunds were available in a form which enabled or required business owners to pass on the refunds to their workers, who will in many cases be responsible for the added labour of cleaning, sorting, and returning the recycling. The implementation of a voucher system could be problematic unless vouchers are redeemable at a wide range of locations and not simply at a single supermarket chain, for example.
When RBHU considers how a container return scheme could operate in the hospitality sector, we see great potential for change. Without a doubt, sales in the hospitality industry would be a major contributor to the annual 2.57 billion beverages in single-use containers consumed in New Zealand, as identified in the consultation document. One statistic which is indicative of this view is that alcohol beverage containers take up a staggering 49.6% contribution of the beverages in single-use containers consumed in New Zealand. On a high volume night at a bar in New Zealand, a single bartender is opening hundreds of beers, cans, and wine bottles. The hospitality sector is a major contributor to the single-use plastics waste in New Zealand.
A container return scheme needs to be implemented alongside clear and accessible explanatory tools which make it easy for workers to know the necessary information about what a workplace needs to do to comply with the scheme (for example, how a container needs to be cleaned, whether lids need to be retained, and what can be recycled). RBHU understands that many hospitality employers already fail to provide their workers with sufficient workplace inductions around important matters such as health and safety, so we are pessimistic about all employers proactively providing their workers with the correct information on how to adhere to container return rules.
- RBHU is concerned that scheme fees added to recyclable packaging could be passed onto consumers, making it more difficult for low-wage workers, such as hospitality workers, to afford these products. Higher prices could also push consumers away from items with recyclable packaging towards products made with cheaper, non-recyclable packaging. To fund the scheme, RBHU suggests the imposition of fees on manufacturers and suppliers choosing to use non- recyclable materials for their products where viable recyclable alternatives are available on the market. This creates an incentive for those manufacturers and suppliers to convert to viable recyclable alternatives. In the short term, this approach would be beneficial, although in the long term, the scheme would likely need to be funded by all suppliers once enough suppliers choose to convert to recyclable packaging.
- RBHU considers it inappropriate to exclude plastic milk bottles from this scheme. Cafés across New Zealand go through thousands of plastic milk bottles every week. A container return incentive would have a significant impact on incentivising café businesses to recycle their plastic milk bottles. The inclusion of plastic milk bottles would also increase the likelihood that these businesses would go to the trouble of taking their other recyclable containers to a “return centre”. Without the inclusion of plastic milk bottles, RBHU expects that some café businesses simply would not bother to take their other containers to a “return centre”, as the quantities of other containers are likely to be considerably less than the quantities of their plastic milk bottles.
Our submission on the proposed improvements to the kerbside recycling scheme
11. RBHU supports the proposals for the improvements to the kerbside recycling scheme. RBHU is particularly concerned about the 300,000 tonnes of food scraps sent to New Zealand landfills each year and especially endorses the proposals which will reduce the levels of greenhouse gases produced from our landfills. Action on climate change is vital to protect the future workforce in the hospitality sector, as there are no jobs on a dead planet.
Our submission on the proposed scheme for the separation of business food waste
- RBHU strongly supports the proposed scheme for the separation of business food waste. Studies show that composting food waste is one of the most important actions we can take to combat climate change. On average, breaking food down by compost releases 14% of the emissions which it otherwise would have released if the same food was sent to a landfill.1 As one stark example, composting bread would release just 2.2% of the emissions in comparison with the emissions released with putting it in a landfill.2
- While some hospitality businesses already have systems in place to deal with their food waste, many others have no systems at all. Existing systems include stock management (to minimise waste in the first place), donations to local charities and food banks, and using offcuts to make stocks and gravies. Where food cannot be donated or reused, it should ideally be composted, either directly by the business or through a third party. Unfortunately, this is often not the case. Right now, most of the food scraps in many restaurant kitchens go straight into the general trash and directly into landfill. We know that the hospitality sector contributes a large proportion of the food waste in Aotearoa. RBHU does not expect that many of these businesses would change their behaviour voluntarily. For these reasons, a nationwide compulsory scheme should prioritise hospitality businesses, as they are more likely to produce larger amounts of food waste. There should also be strong tools for enforcement and the potential for penalties, to ensure that businesses comply with the scheme.
- RBHU considers it essential that we urgently place pressure on hospitality businesses to sort out their food waste. However, as we outlined above in relation to the container return scheme, a food scrap collection scheme needs to be implemented alongside clear and accessible explanatory tools which make it easy for workers to know the necessary information about what a workplace needs to do to comply with the scheme (for example, what can be collected as “food waste” and what cannot be collected as “food waste”). RBHU understands that many hospitality employers already fail to provide their workers with sufficient workplace inductions around important matters such as health and safety, so we are pessimistic about all employers proactively providing their workers with the correct information on how to adhere to food scrap collection rules.
- You are encouraged to reach out to RBHU to continue our dialogue around the proposals. Contact details for RBHU are as follows:
- Email: [email protected]
- Phone: 022 384 1173
- Registered Address: 193 Busby Road, Rd 3, Tahawai, 3170, New Zealand
- Thank you for taking the time to consider our submission.
Chloe Ann-King and Toby Cooper __________________________________________________________
Toby Cooper, LLB
Secretary / Volunteer Legal Advocate
Raise the Bar Hospitality Union Incorporated
Chloe Ann-King, BVA, PGD (Teaching, secondary) PGC (Human Rights) Leader / Volunteer Media and Communications Strategist
Raise the Bar Hospitality Union Incorporated
1 https://www.bbc.com/future/article/20200224-how-cutting-your-food-waste-can-help-the-climate. 2 https://www.bbc.com/future/article/20200224-how-cutting-your-food-waste-can-help-the-climate.