Collaborative Submission to the Climate Change Commission

On the 31t of January this year (2021) the Climate Change Commission / He Pou a Rangi (CCC) released its draft advice to the New Zealand government on how to reach its commitment of net zero emissions of long-lived gases by
2050, and to reducing biogenic methane emissions by between 24-47% by 2050.

The CCC asked New Zealand businesses, community groups, NGO’s and individuals to submit feedback on this draft advice for them to review before submitting their final advice to the government on 31 May 2021.

We reached out to our clients to see who wanted to collaborate on a submission and Otis Oat Milk, Maggie Marilyn, and Emma Lewisham all put their hands up.

Below is our shared submission.

Climate Change Commission Submission

Kia ora koutou,

We are a group of leading New Zealand businesses who have big ambitions for the future of this country and the global industries we operate in. We are from an emerging era of businesses who have been founded while experiencing the impacts of our climate crisis – an existential threat to our very existence. 

We are in this position due to decisions that were made by those who came before us and a historic attitude that the purpose of business is to make profit at the costs of everything else. We started our respective companies to disrupt this, and to lead rapid and far-reaching change to ensure the future is truly sustainable. 

We are all working to evolve New Zealand from the linear, extractive, and exclusive economic system we have inherited to one that is circular, regenerative, and inclusive. An economic system that operates in harmony with the laws of the universe and the natural systems of our planet. An economic system that leaves New Zealand better than we found it. 

This challenge is of course not unique to Aotearoa. We believe for New Zealand to thrive in our globalised world we must be a country that leads on this evolution. As Team New Zealand has just done (again), we must punch above our weight through our creativity, self-belief, team-work, bravery, and leadership. 

We completely agree with the Climate Change Commission’s (CCCs) vision of – “a thriving, climate-resilient and low emissions Aotearoa where our children thrive. This future for Aotearoa is equitable and inclusive, protects livelihoods and makes economic sense.”

For the most part we agree with the CCCs first package of advice to the New Zealand government but we do feel there are some significant omissions that need to be included. In summary, we believe that the advice given to the government is an opportunity to not just meet our emissions targets but to solve multiple problems and realise multiple opportunities that are all connected. It is an opportunity for New Zealand to get wind in our sails, up on our foils and speeding towards a circular, regenerated, and inclusive future. 

We have detailed our respective submission responses below.

Emma Lewisham – (Beauty)

A circular beauty model where refills are used first and foremost over recycling, is core to drastically lowering our carbon emissions in the beauty industry and preventing the billions of units of beauty packaging that ends up in landfill and our oceans every year. At Emma Lewisham, we believe the onus should be on brands to have stewardship for the entire lifecycle of their products – this includes ensuring products are circular designed and packaging is reuseable to minimise carbon emissions.

In response to this issue, we created the Emma Lewisham Beauty Circle, which includes both recycling and refill initiatives. We’ve invested in creating our own refillable moulds – because innovative, refillable solutions are not readily available in the market – to ensure we’re able to offer our customers a circular, regenerative solution.  We will have a full suite of 100% refillable and circular products by mid-2021.   

We are currently mapping our carbon footprint, measuring the carbon emissions of everything from farming the 150 ingredients we use to global transportation and manufacturing.  After establishing what our carbon footprint is, we will reduce our impact against this benchmark by becoming 100% circular, and incorporating more recycled material and ingredients from regenerative farms. We will then offset what small amount is left. 

We would like to see the CCC providing stronger direction to the government on achieving a circular economy for all packaging. Refillable, circular packaging should be the first and foremost solution provided to customers, with recycling being used as a final option when products have been too-well loved. Our hope is that it eventually becomes the norm to have circular packaging that’s better for our planet, but this needs to be strongly communicated and incentivised from the top-down.  

Maggie Marilyn – (Fashion) 

“Our purpose is to use fashion to create a better world. Our mission is to help transition the fashion industry to one that is transparent, circular, regenerative and inclusive. Our vision is for a healthy planet, empowered people and an economy that puts these things first.” – Maggie Hewitt, Founder and Designer

Since our inception, Maggie Marilyn has challenged industry norms and tried to influence change where we could. However, over time we have realised that this wasn’t enough – that we need change that is faster, stronger and bolder.

This realisation culminated in us making a fundamental change to our business model in 2020. We no longer sell to wholesalers and the only place you will be able to buy Maggie Marilyn is from our online store or our new retail ‘Home’ in Britomart and Newmarket, Auckland – these are the first of what we intend to be many around the world.

Our business decisions will no longer be dictated by seasons or ‘traditional’ rules. This grants the luxury of time – to design slowly and mindfully the creation of seasonless offerings that are traceable, organic, recycled or repurposed. We see this values-based decision as the only answer to furthering progress around transparency, circularity, inclusivity and a regenerative industry.

The luxury of time granted by operating entirely direct-to-customer (DTC) plays a key role in reducing carbon emissions. Moving forward, all our fabrics will be sea-freighted in order to significantly decrease carbon emissions. Historically, the majority of fabrics used in seasonal collections were air-freighted due to tight wholesale timelines – another clear example that DTC is essential in shifting the fashion industry to one that has a lighter impact on our planet.

Last year Maggie Marilyn worked with Toitū Envirocare to measure our carbon emissions including travel, freight, electricity and transportation to become Toitū carbonreduce certified and have committed to a 30% absolute reduction in carbon emissions from 2019 (222.45 tCO2e per year). We are currently working through the process to offset the remainder to become Toitu carbonzero certified.

Taking the next step in our circularity journey – we are working to launch a take-back programme to repair garments that have developed ‘love marks’ and the recycling of garments that have reached the end of their life.

Further to this, it is our goal to transition all fibres in our ‘Somewhere’ line to come from regeneratively farmed sources – having already visited and initiated conversations with

one of New Zealand’s leading regenerative merino farms, we want to help influence the growers behind each textile source to transition to regenerative agriculture.

However, to truly be impactful with this we require greater scale to guarantee our partners a large enough portion of business in order for them to feel supported in investing in the transition to regenerative agriculture.

To achieve New Zealand’s emissions target we will need more NZ businesses to follow our lead in making fundamental changes to their business models to significantly reduce their emissions. We would like to see the CCC provide detail on this in their final advice to the government.  

We’d also like to see more detail around supporting our industry to become circular – in particular the development of infrastructure and technology to recycle garments back into raw fibres to be reused. Currently, this is not available in NZ and we will have to send garments for recycling overseas – emitting GHG’s. 

We believe a large part of New Zealand’s Agriculture future should involve the production of natural fibres for textiles and clothing. We want to see more detailed advice around transitioning New Zealand fibre growers (both animals and plants) to regenerative practices while supporting the rapid growth of existing fibre industries such as wool, hemp, and wood and supporting the transition of taking new material technologies to large scale production. 

Maggie Marilyn believes in the power of community. Together we can create change and influence other businesses to do the same. Maggie Marilyn is dedicated to working with the CCC to enforce change to truly create a better world.

Otis Oat Milk

As a nation, we have been way too good at dairy. More specifically, intensive dairy, which goes beyond the land’s natural capital and resources in the name of maximum outputs.  

Unfortunately, this way of farming is depleting our nation’s soil, polluting our waterways, and contributing significantly to our nation’s greenhouse gas emissions.  As a nation, we must diversify and find another way.  

Otis oat milk was founded bristling with enthusiasm at the prospect of doing good for New Zealand. Our mission is to lead a plant-based revolution that helps our nation steer away from intensive dairy and start moving towards regenerative plant-based alternatives.  

It’s a shift that doesn’t just benefit the environment but makes economic sense: plant-based milk creates a channel to connect New Zealand farmers with one of the fastest-growing consumer groups globally and transitions our economy from low-cost products to value-add products.  

As New Zealand’s first homegrown oat milk, we have met countless walls and T-junctions. The biggest challenge we’ve faced is not having the infrastructure and funding to support this shift.

We’re determined to support New Zealand farmers, so while our oats come from here, there have been no viable manufacturing options for oat milk. This has meant that currently, we ship our oats to Sweden for manufacture, offsetting the emissions we incur by 120%.    

We would like to see the CCC providing stronger direction to the Government on moving our nation towards a more regenerative, plant-based economy not just by recommending a reduction in cow numbers or investing in technology to reduce biogenic methane emissions but by proactively supporting and incentivising our farmers to transition to plant-based alternatives. After all, we don’t need to invest in technology to reduce GHG emissions from plants.

We would also like to see the Government lead public / private partnerships to rapidly increase the infrastructure for the plant-based economy to ensure our nation is equipped and ready to meet the opportunities of the modern world. 

Go Well Consulting Ltd – (Sustainability Consultancy)  

We are a sustainability consultancy that helps businesses develop and implement strategies to become circular and regenerative. We work across multiple industries and are in a unique position to see common challenges and opportunities within our current economic system. These are our key areas of feedback. 

Urban Farming

“Food is the single strongest lever to optimise human health and environmental

sustainability on Earth.” We want to see strong government support for the development of urban networks of regenerative organic farms paired with hot composting sites in every town and city. 

This will connect and rebuild communities, improve public health, rebuild soil and biodiversity in our urban centres, significantly reduce food miles and packaging and the related emissions, eliminate discarded food being sent to landfills and related emissions, and create thousands of meaningful jobs. This model is already being proven by dozens of community groups and social enterprises all across Aotearoa. However to achieve rapid and far-reaching impacts this must be scaled up significantly. 

This would require substantial investment in training people and providing the necessary land and infrastructure. However, an investment with far more positive impacts and with a far lower cost than the building of new renewable energy generation or the transitioning of our national vehicle fleet to electric. 

We believe all new housing developments must include access to local composting facilities and an urban farm. 

The end of “waste”

Language matters. Especially when we need to inspire and support a level of behaviour change that has arguably never been seen before in human history. “Waste” is a concept that has been invented by humans, and more specifically, by outdated linear economic thinking. There is no such thing as “waste” in the real world. It is the “circle” of life. Waste” in our economy is just materials in the wrong place.

We want to see the CCC cease the use of the term “waste” in their communications, and advise the government to do the same. 

Further to the language, we also want to see the advice include recommended dates on when all New Zealand landfills will be closed (Auckland Council committed to being zero-waste by 2040), and for every product that enters the New Zealand market to be part of a product stewardship scheme to ensure their products and / or materials are circulated around our economy. In addition to this we want every product that enters the NZ market to be designed and manufactured to last and be repaired, with planned obsolescence outlawed. 

We also want to see recommendations provided on the investment in onshore recycling for textiles, and expanded composting infrastructure for recycling organic materials. 

Behaviour change

Ultimately to achieve the goal of a zero carbon economy requires behaviour change on a scale we have never seen before. We need to change our diets, our modes of transport, how we trade, our business models, and how much and what we consume. And we need to do all that really quickly.

This is perhaps the biggest challenge of all. We have the solutions at our disposal and we know what to do, but engaging, educating and supporting the New Zealand public to make the necessary changes in the time frame required is going to be hugely difficult. Especially while facing well resourced opposition from those who benefit from the status quo. 

There needs to be well thought out and well resourced incentive schemes (both negative and positive), and communication campaigns that educate and engage all New Zealanders on this seismic evolution of our economy, and our way of life.