I would be very grateful for comments on the following which will form part of a submission to government. The base legislation is here: http://www.legislation.govt.nz/act/public/2008/0089/49.0/whole.html#DLM1154593

and an example for microbeads here:


Just need something that looks absolutely professional.

Thank you for your time and trouble.

Waste Minimization (Tyres) Regulations 20xx

These regulations are made under section 23(1)(d) and (b) of the Waste Minimization Act 2008(a) on the advice and with the consent of the Executive Council; and(b) on the recommendation of the Minister for the Environment made after complying with section 23 (1) of that Act.


1 Title

These regulations are the Waste Minimisation (Tyres) Regulations 20xx.

2 Commencement

These regulations come into force twelve months after the date of their notification in the Gazette.

Part 1 Tyre Recycling Fees

3 Interpretation

In these regulations, unless the context otherwise requires:

tread depth” and “tread pattern” have the same meaning as under Land Transport Rule Tyres and Wheels 2001 Rule 32013/2001

abradable tread depth” means the tread depth minus the legal minimum tread depth.

the Secretary” has the same meaning as under the Waste Minimization Act 2008.

initial marketer” is the packer of the goods if the goods are packed in New Zealand, or where the goods are supplied unpacked, the importer, or if not imported the manufacturer in New Zealand; if the name of the packer, manufacturer or importer is not given, the main distributor or importer for the business whose brand name is mentioned on the product or the packaging is considered to be the initial marketer.

4) Definition of legal minimum tread depth

(1) “Legal minimum tread depth” has the same meaning as under the Land Transport Rule: Tyres and Wheels 2001 where applicable, or

(2) where the tyre is not covered by Land Transport Rules, one and a half millimeters, or where there is no tread, the depth to the interior structure minus one and a half millimeters, or

(3) for slick tyres, the depth to the interior structure minus one and a half millimeters.

5) Definition of abradable synthetic tread weight.

(1) “abradable tread depth” means the tread depth minus the legal minimum tread depth.

(2) “abradable tread” means the outer circumference of the tyre multiplied by the tyre width multiplied by the abradable tread depth.

(3) “synthetic rubber” means any of various artificial elastomers, such as GR-S, neoprene, butyl rubber, or nitrile rubber, that resemble natural rubber more or less closely especially in physical properties and ability to be vulcanized, that are made usually by polymerization of butadiene, isoprene, or similar unsaturated hydrocarbons or by copolymerization of such hydrocarbons with styrene, isobutylene, acrylonitrile, or other polymerizable compounds, and that have uses similar to those of natural rubber, and may be used in combination with natural rubber.

(4) “ abradable synthetic tread weight” means the weight in kilograms of the synthetic rubber and zinc oxide content of the abradable tread.

5 Imposition of fees

(1) A fee, to be known as the Tyre Recycling Fee, is hereby imposed on the sale by any manufacturer or importer of any tyre in or into New Zealand, as the case may be.

(2) The Fee is to be paid upon sale by the manufacturer, or, as the case may be, on entry into New Zealand by the importer.

(3) The Fee applies to tyres manufactured in New Zealand and tyres imported, including those on fully or partly assembled new or used vehicles, aircraft, chassis, or sub-assemblies thereof at the time of entry.

6) Rate of Fee

(1) The rate of the Fee is twenty dollars per kilogram of abradable synthetic tread weight, and

(2) after five years the rate shall double, and

(3) after a further five years the rate shall double again.

7) Purposes to which the fee must be applied.

(1) subsidizing the remanufacture of tyres including processes commonly referred to as retreading or remoulding;

(2) subsidizing the repurposing, recycling, reuse, reprocessing, or disposal of used tyres with the minimum environmental impact;

(3) funding research into processes involved in subsections (1) or (2);(4) administration costs;(5) subsidizing public transport and public transport infrastructure projects, or other projects designed to reduce tyre dust pollution. 7) Administration(1) The Secretary shall determine the timing and manner in which the fees are to be collected.(2) The Secretary may require the New Zealand Customs Service to provide such information as necessary for the collection of the fees, in accordance with Section 24 of the Waste Minimization Act.(3) The Secretary many appoint the New Zealand Customs Service to act as to collect the said fees on their behalf under Section (1)(j). 6 Transitional, savings, and related provisions

The transitional, savings, and related provisions (if any) set out in Schedule 1 have effect according to their terms.

Part II Road Surfacing

8) Ban on use of synthetic rubber in road surfacing.

The use of synthetic rubber in road surfacing is prohibited.

Schedule 1 Transitional, savings, and related provisions.

There are no transitional, savings, or related provisions relating to these regulations as made.

Explanatory note: This note is not part of the regulations, but is intended to indicate their general effect.

These regulations, which come into force 6 months after the date of their notification in the Gazette, are made under the Waste Minimization Act 2008 .

The Waste Minimisation Act 2008 provides that a person who knowingly contravenes these regulations commits an offence and is liable on conviction to a fine not exceeding $100,000.

It is believed that synthetic rubber in tyre dust resulting from contact with and abrasion on the road surface is a major contributor to microplastic pollution in waterways, lakes, and oceans. Synthetic rubber is currently added to natural rubber in tyre treads in order to enhance grip and tyre characteristics; the fees herein are intended to reduce tyre usage in a Pigouvian manner. The amount of the fees is arbitrary, but needs to be high enough to impact on patterns of tyre usage, and lessen demand for tyres; and also provide an incentive for tyre manufacturers to come up with solutions to pollution issues. Used tyres themselves also present recycling and reuse issues, so there are suitable applications for fees collected. If used synthetic rubber is shredded and used to supplement road surfacing, then this opens up the possibility for further fugitive microplastics as the road surface itself is abraded by traffic.

Regulatory impact assessment

The Ministry for the Environment produced a regulatory impact assessment in [month/year] to help inform the decisions taken by the Government relating to the contents of this instrument.

A copy of this regulatory impact assessment can be found at—



Could you provide a little more information and tell me which part of the documents you've presented need to be reviewed?

You would be wise to ask a lawyer to review this rather than an English teacher.


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The "Waste Minimization (Tyres) Regulations" are a new draft proposal for consideration. It has been cobbled together by copying bits of existing regulations, the definition of synthetic rubber from the web, and adding entirely new definitions, such as "abradable tread depth", and some new writing. The formatting, layout, and paragraphing seems to have gone astray around the administration section.

I would welcome any comment, whether as to the English and whether it all hangs together, or the content. If the idea is taken up, it would go through a professional legal drafting phase: at this stage it is enough to demonstrate that the proposal is serious, and clear legal definitions and wording are possible.

I am hoping that by presenting a professional looking proposal, it will be given due consideration and not just tossing in the bin.

Thank you for your response. Any further comments would be much appreciated. Cheers

I agree with Clive if you are looking for legal advice/review. If you simply want someone to edit or proofread the document, I'm more than happy to help.

Editing/proofreading would be most helpful: however, there are no funds for this.

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