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

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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: 

  • 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 

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. 
  1. The current regulatory framework is clear and does not need to be changed. 
  1. New breeding techniques (NBTs) such as gene editing ARE genetic engineering. The definition must remain as is.  
  1. A change of definition means GE foods would enter our foods with no labels or safety checks.   
  1. Informed choice: We want to know if there is GE in our food. We want labels and transparency.  
  1. 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.  
  1. Consumer choice: We want to eat organic and GE-free foods and need to know with certainty what we are eating.  
  1. Organic food: We do not want GE ingredients ending up unlabelled in organic food.  
  1. Our food is much more than just an ‘end product’ – we want to know how our food is produced and processed. 
  1. We have cultural, ethical, spiritual, religious and philosophical objections to GE foods and need to be able to avoid it.  
  1. Treaty and Māori cultural concerns: We object to this proposal as it does not align with our cultural expression.  
  1. 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.  
  1. We don’t have enough information yet about the long-term health impacts of eating GE foods (including NBTs).  
  1. All GE food needs to be publicly notified, regulated, assessed on a case-by-case basis, and checked for safety by the regulator.  
  1. We reject this proposal. 

GE-free Tasmania a shining example for NZ

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09 August 2019

The Soil & Health Association congratulates the Tasmanian government for extending its ban on genetically engineered organisms for another 10 years, until 2029.
“Tasmanian producers see clear benefits of being GE-free, enjoying a good reputation and access to markets,” said Jodie Bruning, Councillor for Soil & Health.

“We urge the New Zealand government to also implement a ban on the outdoor use of GE, to strengthen our clean and green brand.”

“People here and worldwide are demanding safe, healthy, ethical, GE-free and organic food. We can produce this and benefit economically, environmentally and, socially.”
GE-free organic production will help build healthy soils, and clean up waterways, and it is part of the solution to climate change, according to Soil & Health.

Many local authorities and primary producers around Aotearoa New Zealand recognise the benefits of a GE-free status, and several councils have either outdoor GE bans or precautionary policies.

New Zealand and Tasmania both have the advantage of sea borders which can help us remain GE-free in the environment.

The GE ban in Tasmania has been widely supported, including by primary producers such as orchardists, pastoral farmers and beekeepers.

[ENDS]

MEDIA CONTACT:

Jodie Bruning
National Council, Soil & Health Association
027 505 0808
jodie@organicnz.org.nz

Jodie Bruning
Jodie Bruning

Community Support for a GE-free Coastal Marine Area in Northland

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Media release: Soil & Health Association of NZ

30 October 2018

Usually associated with land-based farming, the Soil & Health Association is now wading into the coastal marine area in its latest bid towards an Organic Aotearoa New Zealand.

A precautionary approach is needed to any genetically engineered (genetically modified) organisms that may be trialed or used commercially in the Coastal Marine Area (CMA), says Soil & Health.

The Association is therefore encouraging the Northland Regional Council to adopt precautionary provisions for GMOs in the Proposed Regional Plan for Northland, and is presenting its case to the Council today. (Soil & Health’s submission can be viewed at https://soilandhealth.org.nz/submissions/submission-on-proposed-regional-plan-for-northland/)

“We want to ensure that the Council adequately protects growers and producers in Northland from the significant adverse effects posed by GMO use,” says Soil & Health co-chair Bailey Peryman.

The Proposed Regional Plan for Northland as currently drafted fails to regulate GMOs in the CMA, despite the Northland Regional Policy Statement placing an obligation on the Council to take a precautionary approach to GMOs in the region.

“We call on the Northland Regional Council to follow the lead of Auckland Council which has already adopted precautionary provisions and banned the outdoor release of GMOs in the CMA via the Auckland Unitary Plan,” says Peryman.

GMOs in the CMA could threaten the economic sustainability of a wide range of activities that benefit from having GE-free status. This includes organic and non-organic primary producers in the Northland Region, including oyster farmers, and any growers who collect seaweed from the coastline for fertiliser.

“Organic certification standards prohibit the use of any input containing GMO material. A certified organic farm could be contaminated by GMOs in the CMA by using seaweed harvested from the coastline. The composting of seaweed is a popular form of natural fertiliser for crops for many organic farmers. Any GE contamination from seaweed would mean having to stop harvesting seaweed for fertiliser use or otherwise risk losing their organic certification.”

“Aquaculture is a growing industry in New Zealand with exports to nearly 80 countries and our seafood regarded as some of the best in the world. Markets around the world don’t want seafood products that are contaminated with GMOs,” says Peryman.

“All New Zealand fish and shellfish products currently enjoy GE-free status. But contamination of kai moana by GMOs could mean the loss of the premium that the GE-free status and reputation attracts.”

“New Zealand has already seen several GE field trials breach the conditions of approval,” says Peryman. “GMOs in the CMA run additional risks due to the fluid nature of the marine environment, making buffering and containment impossible. We have to also expect that activities in the CMA can cross into terrestrial and freshwater ecosystems.”

If GMOs were released into the Northland CMA it would no longer be regarded as a GE-free region. This could affect the marketing of products within New Zealand and internationally, and premium returns.

The latest OANZ Organic Market Report 2018 reaffirms that the growth in New Zealand organic production and exports is very strong, reflecting global trends. It makes sense economically and environmentally to protect and encourage organic primary production.

ENDS
Media contact
Bailey Peryman
021 1227 638

Community support for a GE-free New Plymouth

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Media release: Soil & Health Association of NZ
14 March 2018
The Soil & Health Association is encouraging the New Plymouth District Council to adopt precautionary provisions in the New Plymouth District Plan for any genetically engineered (genetically modified) organisms that may be trialled or used commercially.
The Proposed Draft New Plymouth District Plan as currently drafted fails to regulate or make any mention at all of GMOs. It is now open for feedback, and Soil & Health is calling on New Plymouth district residents to make submissions by Friday 16 March at 5 pm.
“We want to ensure that the Council adequately protects the district from the significant adverse effects posed by GMO use by including strong precautionary or prohibitive GMO policies and rules into its District Plan,” says Soil & Health National Council member Marion Thomson.
“We call on the New Plymouth District Council to follow the lead of the other councils around New Zealand that have already adopted precautionary provisions and banned the outdoor release of GMOs via their local policy statements and plans,” says Marion Thomson.
Auckland Council, Far North District Council and Whangarei District Council have all prohibited the outdoor release of GMOs and made field trials a discretionary activity with performance standards regarding liability and the posting of bonds.
GMOs threaten the economic sustainability of a wide range of agricultural activities that benefit from having GE-free status. This includes organic and non-organic primary producers in the New Plymouth District, including dairy, honey, forestry, horticulture and other producers.
“Markets around the world don’t want dairy products, honey and so on that are contaminated with GMOs. There are no benefits to farmers or consumers in planting GE ryegrass for example on pastoral farms,” says Thomson.
“New Zealand has already seen several GE field trials breach the conditions of approval. No matter how carefully conditions are crafted, there inevitably remains a risk that they may be breached by poor management, human error, natural events such as severe storms or even sabotage,” says Thomson.
Current laws are inadequate to properly protect communities from the potential adverse effects of GE. There is no provision under the Hazardous Substances and New Organisms (HSNO) Act for financial liability for GMO contamination resulting from the release of an approved GMO, meaning those people or companies responsible for causing harm may not be held liable.
Once GMOs have been released into the environment, they would be very difficult if not impossible to eradicate. In the case of a food product, the GE-free status of a district would likely be lost permanently, along with the market advantages of that status.
Fortunately, under the RMA, requirements for bonds for remediation and to cover the costs of contamination can be included in district plans if local councils choose to implement them.
Soil & Health’s submission can be viewed at organicnz.org.nz/submissions/submission-draft-district-plan-new-plymouth-district-council. Submissions can be made to enquiries@npdc.govt.nz by Friday 16 March 2018, 5 pm.
ENDS
Media contact
Marion Thomson
027 555 4014

Community Support for a GE free Waikato – submissions needed by Monday 22nd January 2018

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The Soil & Health Association is encouraging the Waikato District Council to adopt precautionary provisions in the Waikato District Plan for any genetically engineered organisms that may be trialled or commercially produced.

The plan as currently drafted fails to regulate, or make any mention at all of GMOs.

“We want to ensure that the Council adequately protects the district from the significant adverse effects posed by GMO use by including strong precautionary GMO policies and rules into its District Plan,” says Soil & Health National Council member Marion Thomson.

“We call on the Waikato District Council to follow the lead of the other councils around New Zealand that have already adopted precautionary provisions and banned the outdoor release of GMOs via their local policy statements and plans,” says Marion Thomson.

“Provisions in the Waikato District Plan should be the same or similar to those in the Auckland Unitary Plan to ensure a consistent approach across Auckland and the Waikato and eliminate cross boundary issues,” says Thomson.

Auckland Council, Far North District Council and Whangarei District Council have all prohibited the outdoor release of GMOs and made field trials a discretionary activity with performance standards regarding liability and the posting of bonds.

GMOs threaten the economic sustainability of a wide range of agricultural activities that benefit from having GE-free status. This includes the many organic operations in the Waikato District, as well as non-organic dairy, forestry, honey, horticulture and other producers.

GE animal trials have been undertaken at AgResearch’s Ruakura research centre for several years, making the potential for GE escape or contamination of ongoing concern to Waikato residents.

“New Zealand has already seen several GE field trials breach the conditions of approval. No matter how carefully conditions are crafted, there inevitably remains a risk that they may be breached by poor management, human error, natural events such as severe storms or even sabotage,” says Thomson.

Current laws are inadequate to properly protect communities from the potential adverse effects of GE. There is no provision under the Hazardous Substances and New Organisms (HSNO) Act for financial liability for GMO contamination resulting from the release of an approved GMO, meaning those people or companies responsible for causing harm may not be held liable.

Once GMOs have been released into the environment, they would be very difficult if not impossible to eradicate. In the case of a food product, the GE-free status of a district would likely be lost permanently, along with the market advantages of that status.

Fortunately, under the RMA, requirements for bonds for remediation and to cover the costs of contamination can be included in district plans if local councils choose to implement them.

The Proposed Draft Waikato District Plan is now open for feedback, and Soil & Health is calling on Waikato residents to express support for precautionary and prohibitive GMO provisions, policies, and rules.

Submissions close on Monday 22nd January at 5pm.

Submission Template on Draft Waikato District Plan

Media contact

Marion Thomson, Soil & Health National Council

027 555 4014

A win for clean, green, GE-free New Zealand

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The Soil & Health Association is celebrating the decision by Federated Farmers to abandon its appeal against the right of councils to control the use of genetically modified organisms (GMOs) in their territories. Federated Farmers filed its latest appeal earlier this year in the Court of Appeal, after its appeals to the Environment Court and High Court had been dismissed.

“We congratulate Federated Farmers on this pragmatic and sensible decision,” said Soil & Health Chair Graham Clarke.

“Both the High Court and Environment Court have ruled that regional councils have jurisdiction under the Resource Management Act (RMA) to regulate the use of GMOs through regional policy statements or plans. The recent RMA amendments further entrench the legal rights of councils to do so. Challenging these decisions would only have cost us, the other parties involved and Federated Farmers themselves a lot of unnecessary time and money.”

Federated Farmers had argued that the Environmental Protection Authority had sole responsibility for the regulation of GMOs under the Hazardous Substances and New Organisms Act (HSNO).

The decision to withdraw its appeal comes after recent amendments were made to the RMA, which confirmed the High Court ruling, leading Federated Farmers to believe that they “are likely to have materially reduced the prospects of the appeal being prosecuted successfully.”

The RMA changes, which passed in April this year via the Resource Legislation Amendment Bill, included a controversial section which allows the Minister for the Environment to bypass parliament and make fundamental changes to the law if it is deemed that council plans duplicate or deal with the same subject matter as central Government laws. This would have allowed the Minister to strip councils of their ability to create GE-free food producing zones.

The National Government at the time needed the Maori Party votes to pass the changes. However, the Maori Party stated in December last year that it would not support changes to the RMA if they extended to allowing the Minister to overrule planning provisions controlling the use of GMOs.

Before the final reading of the Bill, an exemption was introduced under section 360D specifically for GE crops, effectively preventing the minister from permitting GMO crops in regions that had elected to remain GMO free or impose controls on the use of GMOs.

“We are so grateful to Maori Party for their determination to ensure that appropriate clauses in the RMA were included to protect regions from uncontrolled GMO use. Had they not stood firm against the changes, then we might not have had this decision from Federated Farmers to withdraw their appeal,” says Soil & Health National Council member Marion Thomson.

“The RMA amendment further confirms the ability of all local councils to determine GMO policies in their regions. Local communities can now have confidence that their values and concerns about the use of GMOs in their regions can be considered when drafting policy statements and plans.” says Thomson.

The economic sustainability of a wide range of agricultural export activities reliant on GMO-free status is also protected by this ruling. The global non-GMO food market is currently valued at US$250 billion, and trends show this is only going to grow. New Zealand producers benefit from access to this huge non-GMO market.

Soil & Health has found no economic, health or environmental case for GMOs. There are huge uncertainties around the adverse effects of GMOs on natural resources and ecosystems. The risks are large and consequences irreversible. If GMOs were to be released into the environment, they would be very difficult, if not impossible, to eradicate in circumstances where they adversely affected the environment. There is also potential for serious economic loss to regions marketing their products and tourism under New Zealand’s ‘clean green’ brand, if GMO land use were permitted.

Background:

Significant gaps exist in the law around GMOs in New Zealand. In the HSNO Act there are inadequate liability provisions (e.g. ‘polluter pays’) for any unintended or unforseen adverse impacts resulting from the outdoor release of an approved GE crop or animal, meaning those causing harm may not be held liable. There is no mandatory requirement for the EPA to take a precautionary approach to the outdoor use of GMOs.

Due to these gaps in the law, a number of councils around New Zealand have been moving to protect their primary producers and communities by introducing precautionary or prohibitive policies.

The Northland Regional Council is one such council which, after receiving hundreds of submissions from Northland ratepayers, district councils, Northland Conservation Board, iwi authorities, hapū and community groups, chose to adopt a precautionary approach around the outdoor release of GMOs in the proposed Northland Regional Policy Statement.

Federated Farmers of New Zealand lodged an appeal with the Environment Court in 2015 opposing these precautionary GMO provisions in the Northland Regional Policy statement. Principal Environment Court Judge L. Newhook however found that there is jurisdiction under the Resource Management Act for regional councils to make provision for the outdoor use of GMOs through regional policy statements and plans. Since comprehensively losing the appeal (which it initiated) on all points of law, Federated Farmers filed a second appeal against the Environment Court’s decision with the High Court.

Soil & Health, GE Free Northland, Taitokerau mana whenua, Far North District Council and several other groups and individuals joined the appeal in the High Court as section 274 (interested) parties pursuant to the RMA, in support of respondents Northland Regional Council and Whangarei District Council. Soil & Health was represented by Dr. Royden Somerville QC and Robert Makgill.

Dr Somerville argued that Environment Court Judge L. Newhook was correct in his decision that the RMA and HSNO Act hold complementary and not overlapping roles. The two Acts offer different purposes and functional responses to the regulation of GMOs in New Zealand. Thus, regional planning documents can control the use of GMOs as part of promoting sustainable management under the RMA, taking account of regional needs. This argument has been confirmed by High Court Judge Mary Peters.

Contact: Graham Clarke
Chair, Soil & Health Association
027 226 3103

GE free

GE potatoes set to sneak into our food

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The Soil & Health Association has serious concerns about another GE food line being approved in New Zealand – this time for six food lines derived from potatoes.

Food Standards Australia New Zealand (FSANZ), the organisation that controls food approvals for New Zealand and Australia, is calling for submissions on an application to permit GE potatoes for human consumption. The potatoes have been genetically engineered to reduce bruising, to reduce acrylamide formed during cooking, and to protect the potatoes from a type of blight.

Soil & Health is concerned about the growing number of genetically engineered foods approved for sale in New Zealand and the long-term and cumulative health effects of consuming them. While New Zealand does not grow any GE crops or animals, there are many imported GE ingredients in food for sale here.

“Since 2000 FSANZ has approved every single application for GE food lines, and there are now a staggering 71 different GE food lines approved for sale in New Zealand,” says Soil & Health chair Marion Thomson.

“An estimated 70% or more of processed non-organic foods for sale in New Zealand contain genetically engineered ingredients, but consumers have no idea because our labelling laws mean that almost all GE ingredients don’t have to be listed on the packaging.”

“In addition to human food, New Zealand imports large quantities of animal feed that is almost certainly genetically engineered, but again, not labelled as such,” says Marion Thomson.

While a FSANZ safety assessment on the GE potato application has not identified any public health and safety issues, previous FSANZ assessments have been shown to be incomplete, with an absence of biological studies on the impacts of the foods when eaten. Further, assessments have largely been reliant on industry assurances of safety, with no independent science to back up industry assertions.

“One of the main concerns about eating GE foods is that many have been grown with dangerous levels of pesticides,” says Thomson. “Many GE crops are designed to be resistant to pesticides. These crops are designated ‘safe’ for human consumption by FSANZ and the Ministry for Primary Industries, despite not having undergone adequate safety tests independent of the companies developing them.”

The best way to avoid consuming GE foods is to grow, buy and eat certified organic food, says Soil & Health.

The GE potatoes application is open for public submission until 7 July 2017.

GE-FREE ZONES UNDER THREAT FROM RMA AMENDMENT

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The Government seems hell-bent on denying the rights of communities to have GE-free zones, which are under threat from a ‘dictator clause’, says the Soil & Health Association.

“We are continuing to stand by all the communities around New Zealand who, quite rightly, want to have control over what happens with GMOs in their regions,” said Marion Thomson, chair of Soil & Health.

Yesterday Parliament heard the second reading of the Resource Legislation Amendment Bill, which contains proposals that would allow Minister for the Environment Nick Smith to strip councils of their ability to create GE-Free food producing zones.

The Local Government and Environment Select Committee report on the Bill was released last week with the controversial section 360D still in the Bill.

Section 360D – known as ‘the dictator’ or ‘Henry VIII’ clause – would allow the Minister to bypass parliament and make fundamental changes to the law if he deems council plans duplicate or deal with the same subject matter as central Government laws.

Of further concern to the Soil & Health Association is the introduction of a new section – 43A(3A) – that would give the Minister another avenue to strike out local GE-free zones.

This new amendment was introduced at the select committee stage, meaning it wasn’t made available for public consultation.

“This latest move runs firmly against principles of natural justice and the democratic right of the public to have their say on matters that affect them,” said Marion Thomson.

The environment minister is looking to the Maori Party for the votes needed to get these anti-democratic provisions through.

However, during the reading yesterday Maori Party co-leader Marama Fox declared that they support achieving a GE Free New Zealand and that this has always been their policy.

In a letter to the Minister in December last year the Maori Party stated that it does not support changes to the RMA “if they extend to allowing the Minister to overrule a provision in a plan, for example, to have a GMO Free Zone.”

The Far North and Whangarei District Councils as well as Auckland Council have all prohibited the outdoor release of GMOs via their local plans, creating a GE-Free northern peninsula from the Bombay Hills to Cape Reinga.

“These council decisions have been driven by local communities and the mana whenua and iwi authorities in the regions. The Maori Party has made firm promises to stand by communities that want their territories to be GMO Free. We are confident that they will not go back on their word and that they will vote against the 360D and 43A clauses,” says Thomson.

Note to editors:
Nick Smith’s view that the EPA, not local councils, can control the release of GMOs has been found wrong by both the Environment Court and the High Court which have ruled that there is jurisdiction under the Resource Management Act for local councils to control the outdoor use of GMOs via regional policy instruments. The EPA approves, approves with controls, or turns down applications for genetically engineered organisms under the Hazardous Substances and New Organisms Act. Councils can control, restrict or ban GMOs within their territories, under the RMA.

Contact:  Marion Thomson
Chair, Soil & Health Association
027 555 4014

Photo credit: Nick Holmes

GE/GM

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Genetic engineering (GE), also known as genetic modification (GM), is one of the most controversial technologies of recent times. Soil & Health has found no economic, health or environmental benefits from GE. There is great uncertainty around the adverse effects of GMOs (genetically modified organisms) on natural resources, ecosystems and also on human health. The risks are large and consequences could be irreversible. If GMOs were to be released into the environment, they can be very difficult, if not impossible, to eradicate. The GE-free food producer status of an individual, district or region would likely be permanently lost, along with any marketing advantages that status provides.

Current laws are inadequate to hold GMO users liable for any adverse consequences, intended or even if unintended. Therefore the public is likely to have to pay for anything that might go wrong.

The Soil & Health Association is opposed to the use of GE ingredients and GMOs in human and animal food, and is opposed to the outdoor use of any GE crops, animals and other organisms in Aotearoa New Zealand. We believe that we would do better for our farmers, environment and human health by retaining our market advantage of being GE free.

We support:

  • New Zealand remaining a GE-free country.
  • The establishment of GE-free regions, in the event of there being no Aotearoa New Zealand wide GE-free strategy.
  • Mandatory and comprehensive labelling for any products containing GE ingredients (including products from animals fed GE feed).
  • The precautionary principle and the imposition of strict conditions and severe penalties must be placed on any research and trialling of GE.
  • A ban on field-testing and production of GE crops, animals, trees and other organisms in New Zealand.
  • A ban of all GE food and animal feed imports into Aotearoa New Zealand.
  • Strong precautionary approach to new/novel technologies.

                                            Photo credit: Nick Holmes

GE Free Field NZ

Maori Party says no way to Nick Smith’s power grab

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The Soil & Health Association congratulates the Maori Party for standing up for New Zealanders who want to live in a GE-Free community and saying no to Nick Smith’s attempt to ride roughshod over local democracy.
“Maori Party co-leader Marama Fox has told the Environment Minister they will not support his attempts to regulate genetically modified crops nationally through the Environmental Protection Agency (EPA),” says Soil & Health Association spokesperson Karen Summerhays.
“This spells the end for Nick Smith’s attempts to control what is grown in New Zealander’s neighbourhoods and available at their local markets.
“Local Authorities won the right to regulate the planting of genetically modified crops in their territories after years of legal battles over whether they could introduce GMO-Free zones through district plan rules.
“By standing up to Nick Smith, the Maori Party has protected this hard-fought democratic right. The Government doesn’t have the numbers to make this change without their support.
“The Environment Minister insists that genetic modification should be regulated on a national level by the EPA under the Hazardous Substances and New Organisms Act, not under the Resource Management Act. Nick Smith’s view has now been found wrong by both the Environment Court and the High Court.
“Clause 360D of the Resource Legislation Amendment Bill – also known as the ‘dictator clause’ – would have allowed the Government to step in if it deemed council plans duplicated central Government laws.
“Soil & Health would like a sub clause introduced to the Bill prohibiting this power being used in relation to council plans which contain a GMO-free zone.
“Otherwise local food producers – and economies – face being hit in the pocket when they lose the lucrative advantage of being able to market their products “GE-Free” alongside those from the world’s premier GE-Free territories; Tuscany, Provence and Burgundy.
“It’s time for Nick Smith to concede defeat and acknowledge that communities should continue to decide whether GMO crops are grown in their districts,” Karen Summerhays says.

Contact – Soil & Health spokesperson Karen Summerhays on 021 043 7858
GE Free Field NZ