S&H Submission on P1055: Definitions for gene technology and new breeding techniques

The Soil & Health Association has submitted on the proposal to revise and update the definitions in the Australia New Zealand Food Standards Code for ‘food produced using gene technology’ and ‘gene technology’. This is our second submission on P1055, having first submitted in 2021.

Read our full submission here.

We strongly encourage our members and supporters to make their own submission. The deadline for submissions is Tuesday 10th September, at 8pm New Zealand time.

The following guidelines are provided to assist you to make a submission. Please contact us if you have any questions or require further assistance at editor@organicnz.org.nz.

SUMBISSION TEMPLATE AND GUIDELINES  

The proposal 

Second call for submissions: Proposal P1055 ‘Definitions for gene technology and new breeding techniques’ – Food Standards Australia New Zealand (FSANZ). 

Submission closing deadline 

10 September 2024, 8pm New Zealand time. 

How to submit 

Make your submission EITHER: 

• By email to submissions@foodstandards.gov.au – we encourage you to also BCC jenny.lux@soilandhealth.org.nz if you would like to share your submission with us.  

• Via the FSANZ consultation hub: https://consultations.foodstandards.gov.au/fsanz/p1055/ – we recommend some hours before the deadline. There are set questions asked in this portal.

• We also encourage you to send your submission – and your opinions – to your MP, Ministers, letters to the editor, ring talkback radio etc.

Background documents 

• The full FSANZ proposal

• Soil & Health’s submission

• Soil & Health’s 2021 submission

• BioGro’s submission guide

• Organics Aotearoa New Zealand’s submission guide

• GE Free NZ’s submission guide

Ideas for points to make in your submission 

IMPORTANT: Please use your own words.  

If you simply copy and paste text from below or from Soil & Health’s submission, your submission may not be counted as an individual submission.  

Write about how this proposal will affect you, your family, business and community.  

1. Extension of time: urge FSANZ to extend the consultation period by at least a month to allow for sufficient time to make submissions. 

2. The current regulatory framework is clear and does not need to be changed. 

3. New breeding techniques (NBTs) such as gene editing ARE genetic engineering. The definition must remain as is.  

4. A change of definition means GE foods would enter our foods with no labels or safety checks.   

5. Informed choice: We want to know if there is GE in our food. We want labels and transparency.  

6. Health and safety: We are concerned about the health and safety of our food and want to avoid GE because of the possible health risks to us and our family.  

7. Consumer choice: We want to eat organic and GE-free foods and need to know with certainty what we are eating.  

8. Organic food: We do not want GE ingredients ending up unlabelled in organic food.  

9. Our food is much more than just an ‘end product’ – we want to know how our food is produced and processed. 

10. We have cultural, ethical, spiritual, religious and philosophical objections to GE foods and need to be able to avoid it.  

11. Treaty and Māori cultural concerns: We object to this proposal as it does not align with our cultural expression.  

12. Not equivalent: Foods produced using NBTs are not the same as natural foods. NBTs have unexpected changes so any foods produced using these technologies must be regulated.  

13. We don’t have enough information yet about the long-term health impacts of eating GE foods (including NBTs).  

14. All GE food needs to be publicly notified, regulated, assessed on a case-by-case basis, and checked for safety by the regulator.  

15. We reject this proposal.