Information for disposal facility operators on their ETS obligations.

Since 2013, disposal facility operators have had an obligation to report their emissions and surrender New Zealand Units (NZUs) under the New Zealand Emissions Trading Scheme (ETS).

A disposal facility is any facility including a landfill that operates (at least in part) as a business to dispose of waste, at which:

  • waste is disposed, and
  • the waste disposed includes waste from a household that is not entirely from construction, renovation, or demolition of a house.

Effectively, if a landfill site is currently subject to the waste disposal levy, then its operator is also a mandatory participant in the ETS. Operators of other types of waste-related facilities, such as cleanfills or sewage treatment facilities, are not currently ETS participants. A facility (or any part of a facility) at which waste is combusted for the purpose of  generating electricity or industrial heat is not considered a disposal facility.

Disposal facility operators are responsible only for methane emitted through the biodegradation of organic waste in their facilities.

Obligations Plus

Participants in the Waste sector are required to record information about the gross tonnage of waste entering their landfill facility in a year and submit this as part of their annual emissions return. This figure is then multiplied by an emissions factor that estimates the emissions per tonne of waste to give a total emissions figure.

Once an emissions return has been completed, a Waste participant will be required to surrender emissions units corresponding to the amount of emissions reported to the ETS.  

Participants can use a default emissions factor set by the government using data from landfills around the country. If a participant believes that the emissions factor for their landfill should be lower than the default one, they may apply to the EPA for a "Unique Emissions Factor" which reflects the actual emissions from their facility.​

Regulations for Waste participants applying for a Unique Emissions Factor

Exemptions Plus

According to the Climate Change (General Exemptions) Order 2009, ETS obligations do not apply to landfills that have been in operation since before 1 January 2012 and either:

  • dispose of less than 1,000 tonnes of waste per year and are located at least 150 km away from the nearest modern landfill by land; or
  • dispose of less than 500 tonnes of waste per year and are located at least 75 km away from the nearest modern landfill by land; or
  • are located at least 25 km away from the mainland for offshore islands

If you believe that your landfill may be exempt under one of these conditions, please contact us for more information.

Climate Change (General Exemptions) Order 2009 - see clause 12A for more detail

Historical emissions

The methodology in the regulations does not require disposal facility operators to estimate emissions from historical waste (waste disposed before 2012). They are only required to calculate potential emissions from the waste disposed in a particular year.

Emission types Plus

Under the ETS waste regulations, disposal facility operators are responsible only for methane emissions from their facilities.  They are not responsible for any other greenhouse gas emissions associated with landfills or other methods of waste disposal.

Although landfills also emit significant amounts of carbon dioxide from waste decomposition, these emissions are not part of New Zealand’s international obligations and do not incur any ETS obligations.

Allocations Plus

The Waste sector does not receive an allocation of NZUs because landfill operators are not internationally trade exposed and are able to pass the costs of their ETS obligations on to their customers.