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. 

Our submission on the National Organic Standard

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Following our public webinar on Tuesday 30 May 2023, we have finalised a submission on the National Organic Standard (NOS).  This standard will form the future rules that organic farmers, growers, processors and retailers will be held to.

Submissions to MPI were due on Friday 16 June 2023. Here is the latest MPI update on the proposal: https://mpi.govt.nz/…/proposals-for-the-national…/

Soil & Health’s initial take on the draft standards document:

  • The organic principles section still needs a lot of work.  It is important that this section is rewritten within the framework of Te Tiriti o Waitangi using the IFOAM principles of Health, Ecology, Fairness and Care to ensure international coherence.  This needs to be done in partnership with iwi.
  • It lacks a glossary of terms, which it needs for clarity.
  • There are still gaps, inconsistencies and inaccuracies. 
  • More work needs to be done on it and shared with the public (especially what’s in the supplementary notices).
  • We need to make a proper international comparison of our organic standard with those from our key trading partners.
  • We believe that it is not equivalent to EU organic regulations in allowing container growing of perennials for their whole life cycle (e.g. container blueberry farms).
  • Seed treated with prohibited chemicals should not be allowed under our organic standard. 
  • The shortening of livestock conversion times in this draft is concerning.
  • It should be made clear that processed organic products cannot contain GMOs.

Letter to Ministers and MPs: Seizing the opportunities of organic regenerative farming

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A remit passed at the 2022 Soil & Health AGM calling for advocacy on climate change action through organic regenerative farming.

The following letter was sent to Ministers and MPs on 18th April 2023.

To:
Hon Damian O’Connor MP, Minister for Primary Industries;
Hon James Shaw MP, Minister of Climate Change
Chris Luxon MP, Leader of the Opposition
Todd McClay MP, Opposition spokesperson for agriculture
Simon Watts MP, Opposition spokesperson for climate change
Debbie Ngarewa-Packer MP, Co-leader Te Pāti Māori
Mark Cameron MP, ACT Party agriculture spokesperson
Simon Court MP, ACT Party climate change spokesperson
Teanau Tuiono MP, Green Party agriculture spokesperson

Dear Ministers, and Members of Parliament,

Re. Seizing the Opportunities of Organic Regenerative Farming

We write to you in the aftermath of cyclone Gabrielle, as the country continues to grapple with the challenges of a changing climate and the need to reduce our emissions in line with international agreements. The Organic Products and Production Act has also now received Royal Assent. The passing of this legislation is a major opportunity for our country.

Organic regenerative farmers around New Zealand are leading the way. They are doing this by lowering their environmental footprint through organic regenerative farm practice, whilst also commanding a premium price in domestic and international markets through organic certification. We believe that greater political support for the transition to organic food and farming, while embracing regenerative practices, can deliver the best of both worlds. This means lower gross emissions and environmental impact, whilst upholding the best possible price for farm produce.

As political parties prepare for this year’s general election, we implore you to champion support for the organic regenerative transition. Trading partners such as the European Union and United States are already moving in this direction. They have clear targets and incentives from the government.

The Global Shift to Environmental Leadership Through Organics

The return on organic produce is higher than for conventional. This premium is based on consumer concern for environmentally sustainable food, and trust in organic certification which is a globally recognised and regulated system.

The EU provides funding for organic transition, with a goal to have 25% of the EU’s agricultural land area under organic management by 2030. The United States recently announced $300m for organic transition.

Organic regenerative farms across New Zealand are a largely untapped resource when it comes to climate change and the environment. It is time to create a more open and meaningful exchange of knowledge between the organic and conventional sectors for the benefit of the environment and society. This work requires leadership and resourcing from all sides, including politicians and the government.

Lowering Our Carbon Intensity

The prohibition of synthetic nitrogen fertilizer on organic farms alone makes their carbon footprint significantly different from conventional counterparts.

Between 1991 and 2019, the amount of nitrogen applied to New Zealand soil increased by 629%. When soil microbes consume nitrogen, they also consume a proportional amount of carbon, potentially emitting more GHGs. Synthetic nitrogen fertilizers also cause more nitrous oxide (a greenhouse gas 300 times more potent than CO2) to be emitted from soil.

Although nitrous oxide emissions occur on nearly all farms to some degree, organic farms in Europe were found to emit 40% less than comparable conventional farms. Techniques commonly used by organic farmers, including manure composting, have been shown in Europe to reduce emissions of nitrous oxide by 50% and methane by 70%.

Policy to Support Environmental Leadership on Farms

To advance this vital opportunity we are calling on politicians and the government to:

  1. Fund targeted research on organic farm management and climate emissions,
  2. Give incentives and support for regenerative farmers to obtain organic certification, such as bridging finance or grants to cover certification (typically over three years),
  3. Ensure ongoing structural funding for organic sector organisations to deliver extension and support for organic growers and businesses and conventional farmers wishing to convert to organics.

We would be happy to supply more information on any of the points raised in this letter,

Yours sincerely

Marion Wood

Chairperson, the Soil & Health Association of New Zealand

A PDF version of the letter can be accessed here.

Submission of the Soil & Health Association on the Therapeutic Products Bill

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The Therapeutic Products Bill is intended to replace the Medicines Act 1981 and Dietary Supplements Regulations 1985 and brings natural health products (NHP) into the regulation system for health products within Aotearoa/New Zealand. 

Read our full submission here.

Summary of our submission

This submission from Soil & Health focuses on the regulation of natural health products. 

Soil & Health agrees with the Purpose of the Therapeutic Products in relation to natural health products: 

‘to protect, promote, and improve the health of all New Zealanders by providing for the—… 

acceptable safety and quality of natural health products across their life-cycle. 

but we consider that the Bill is written primarily from a western reductionist viewpoint, considering natural health products rather than natural health systems: 

  1. Much of the Bill is concerned with defining therapeutic products and decisions on this will be made by experts in the field.  Soil & Health is concerned that registered naturopaths, medical herbalists and homeopaths are not included as health practitioners under the Health Practitioners Competence Assurance Act 2003, nor are they recognised as experts in natural health products in this Bill. In contrast pharmacists are recognised in the Bill and sell natural products although they are not trained as experts in this field.  

We recommend that the Naturopaths & Medical Herbalists of NZ (Inc).(NMHNZ)(https://naturopath.org.nz), New Zealand Association of Medical Herbalists (NZAMH) (https://nzamh.org.nz/) and the New Zealand Council of Homeopaths (https://homeopathy.co.nz/) be recognised as responsible authorities under the HPCAA and that those registered by these authorities be included in the Bill as NHP practitioners. 

  1. The Bill allows for the definition of natural health products to include synthetic ingredients and additives. 

We recommend synthetic ingredients and additives be limited to 5% of the product and controlled. 

  1. The Bill also allows for exceptions to the requirement for regulations for low concentration natural health products. 

Soil & Health recommends that the risk assessment of dilute NHPs such as homeopathic remedies apply not to the origin of the remedies (whether plant, mineral or animal), but instead to the final products, which contain no DNA and therefore no disease risk.  

  1. We recognise that large manufacturers of natural health products want and need regulations for export. BUT it is our view that these market regulations should not apply to the domestic market.   

We recommend that a list of prohibited ingredients be developed for the domestic market.   

  1. The Bill currently applies to rongoā.   

We recommend that the Bill not proceed until there is a Tiriti-based process in place for rongoā. 

  1. The Bill does not provide any protection for source ingredients.   

Soil & Health recommends that plant ingredients be harvested in a way that protects their sustainability and avoids depletion of any endangered species. 

Submission of the Soil & Health Association on definitions for gene technology and new breeding techniques

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The Soil & Health Association welcomes the opportunity to submit on this proposal to revise and update the definitions in the Australia New Zealand Food Standards Code (the Code) for ‘food produced using gene technology’ and ‘gene technology’, to make them clearer and to better reflect existing and emerging genetic technologies, including new breeding techniques (NBTs)

Read our full submission here.

Submission of the Soil & Health Association on the Emissions Reduction Plan

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Our submission focuses on agriculture and organic waste and states that more can be done, sooner, by supporting a faster transition to regenerative organic farming. 

Emissions from organic waste and from agriculture can be reduced through conversion of farming to regenerative organic systems alongside better organic waste collection and processing for composting and soil-building.  

To do this the government needs to prioritise support for existing available solutions such as organics rather than focusing on new technologies. We agree that rural extension services, research and better waste regulation are key tools to deliver this change.    

Read our full submission here.

EPA Call for Information on glyphosate, September 2021

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Summary of our submission

A GLYPHOSATE RISK ASSESSMENT IS NEEDED URGENTLY

We welcome the opportunity to respond to this Call for Information on glyphosate.

We submit that Aotearoa New Zealand urgently needs a genuine risk assessment of glyphosate and glyphosate-based herbicides (commercial products containing glyphosate and other chemicals) that are being sold and used in this country.

New Zealand has never conducted a risk assessment of glyphosate-based herbicides (GBHs). This Call for Information effectively delays the long overdue risk assessment of GBHs

This delay pushes back appropriate regulatory measures that might be enacted as a response to risk assessment to protect health.

SURVEY OF COUNCIL USE OF GLYPHOSATE

Our submission includes survey information collected from territorial and regional authorities around the country about their current use of GBHs.

This survey demonstrates both the widespread use of GBHs and the increasing community pressure to eliminate GBHs

THERE ARE KNOWN HEALTH RISKS FROM GLYPHOSATE

There are known health risks of GBHs to humans, domesticated animals, and to aquatic and terrestrial wildlife.

We provide evidence of these risks our submission document.

Given its widespread use, producers and consumers cannot be confident they’re avoiding GBH health risks under the current regulations.

We urge the government to take a strict precautionary approach.

GLYPHOSATE USE LEADS TO INCREASING HERBICIDE RESISTANCE

Herbicide resistance – including resistance to GBHs – is a growing problem globally and here in New Zealand.

Herbicide resistance is leading to the use of several different herbicides together or in rotation.

Farmers and growers (conventional as well as organic) are increasingly seeking safe non-chemical weed management options.

Organic producers are able to successfully employ a range of non-toxic methods of weed management, reducing herbicide resistance pressure

ECONOMIC RISKS OF GLYPHOSATE-BASED HERBICIDES

International demand for safe, healthy food is strong and growing. Our international markets are extremely sensitive to pesticide residues.

For example Japan has rejected New Zealand honey imports this year due to glyphosate residues.

SOIL & HEALTH’S GLYPHOSATE PETITION

We need our Government to hear our concerns, and to that end have established a petition. For further information, and to sign the petition, please see here.

Supporters of our petition are calling on the government to:

  1. Ban the use of glyphosate in public places and around waterways;
  2. Ban foliar sprays (pre-harvest) of glyphosate formulations on human and animal feed crops; and
  3. Conduct a first-ever risk assessment of the active ingredient glyphosate, and the retail formulation sold in shops, using independent published and openly available scientific data.

OUR FULL SUBMISSION

Included in our submission are

Climate Commission draft advice to government, Autumn 2021

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Summary of our submission

In general we support the spirit of this first Climate Change Commission (CCC) report, but we want strong and decisive action, and we want it more quickly than the report recommends. We think that the Commission’s proposed budgets need to be substantially enhanced to create greater emissions reductions over the next decade, to better align with efforts to keep global warming to 1.5 degrees.

The solutions lie before us, and we cannot delay any longer.

Our full submission

Download our full submission (PDF)

The Organic Products Bill

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Summary of our submission

The Soil & Health Association is focused on the following 10 points:

  1. ‘Organic’ is not defined in the Bill and is therefore open to misinterpretation. We propose that the full IFOAM definition and principles of organic agriculture be written into the Bill.
  2. Exclusion of GMOs: The use of genetic modification is not in accordance with organic practice, so exclusion of GMOs should be added to the definition of ‘organic’ in this Bill.
  3. The title of the Bill should be ‘Organic Production and Products Bill’ to reflect the importance of the connection between the production system and the product.
  4. The Bill needs to recognise the role that organic production plays in achieving other important public good outcomes for NZ, such as climate change mitigation, improvement of water quality, and protection and enhancement of biodiversity.
  5. The Purpose of the Act should be expanded to reflect the priorities of the organic sector both in NZ and internationally. Facilitation of domestic trade, growth of the domestic organic sector, and maintenance and support for the established principles of organic agriculture should be added in.
  6. NZ’s regulatory system should mirror the best functioning organic regulatory systems in other jurisdictions such as Canada and the EU. The proposed system, which puts the Ministry in charge of final approvals, puts an unnecessary extra level of administration and cost onto the process. We think that third party certifiers should have the power to give final approval to licensees (i.e. to issue certificates), and the relevant Ministry should restrict itself to accrediting third party certifiers, keeping a register of the approved operators (certified licensees) and carrying out enforcement in the case of breaches.
  7. There should be an Organic Authority with both government and organic sector representatives to oversee the organic standards. The organic sector representation on such an authority should include producers, processors, consumers, traders, certifiers, organic scientific representatives and Māori (who must be present as the Crown’s partner in the Treaty of Waitangi). This body should be more than a technical advisory board; it must have the power to decide on, develop and monitor the content of the standards rather than simply recommend it to the Ministry.
  8. The Bill needs to provide for low cost certification options for small to medium sized operators. Participatory Guarantee Systems (PGS), as recognised by IFOAM, such as OrganicFarmNZ are affordable and accessible to small-scale producers who produce solely for the domestic market, such as via farmers’ markets, local organic shops and box schemes. PGS should be provided for in this Bill. Very small producers should be exempt from certification, but should still have to follow the organic standards if they make ‘organic’ claims about their product.
  9. If the cost of certification increases, those costs will be passed onto consumers, and this will have a chilling effect on domestic trade in organic products overall. Domestic consumers should have affordable locally produced organic products of all types available to them.
  10. National organic standards documents should be freely available to the public as a resource for learning about organic practice and to inform consumers.

Our full submission

Download our full submission (PDF)

A1186 Soy Leghemoglobin (Impossible Foods)

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Submission to the FSANZ

Application A1186 Soy Leghemoglobin

February 13, 2020

FSANZ Supporting documents can be found here

A successful approval of A1186 Soy Leghemoglobin by FSANZ will result in the release of Impossible Foods burgers and associated products onto the New Zealand market for consumption by the product. Much of this product would be sold through take-away outlets and restaurants and in this form, would remain unlabelled.

Soil and Health consider that the application for A1186 Soy Leghemoglobin which is a mixture referred to as ‘LegH Prep’ is inadequate to ensure a high standard of public health protection. Much of the documentation and marketing of Impossible Foods products infer that these products are substantially equivalent to unprocessed meat, and represent a safe and healthy vegetarian protein option.

We consider that regulatory activities which fail to consider the implications of release of an ultra-processed, high salt, genetically modified soy protein product on the market – and regulatory treatment of this product as substantially equivalent to healthy, grass raised beef or lamb, or home-made vegetarian burgers made from non-genetically modified vegetable proteins, may be misleading.

Therefore the Soil & Health Association of New Zealand consider that the current application and approval process does not contain sufficient information to ensure activities relevant to the approval will fulfill the Objectives of the Food Standards Australia New Zealand Act 1991. We note:

1.1. The report ignores the health impact of the final product. The LegH Prep has been specifically developed to be an ingredient in an ultra-processed convenience food product.

1.2. Nutrition is cherry-picked despite the product being positioned as a meat substitute. Equivalent iron is not substantially equivalent as other nutritional parameters are ignored in the application.

1.3. The contaminant profile 2 from herbicides contained in the retail product, which unprocessed meat does not contain has been ignored.

1.4. Differing health effects relating to the potential for endocrine disruption at different life stages has been ignored.

1.5. There are no long-term dietary studies – a 28-day study restricts consideration on health effect and the longer dietary studies are reasonable to scientifically risk assess long term (chronic) effects.

1.6. The chronic toxicological parameters relating to immunotoxicity, carcinogenicity, oxidative stress, as well as endocrinological effects are not clearly published.

1.7. 90-days dietary study must be supplied, including endocrinological test results, for the risk assessment to be scientifically appropriate to assess health risk:

– OECD Test Guideline (TG) 408 – repeated dose 90-day oral toxicity study –       (Updated in 2018)

1.8. Due to the scientific knowledge gaps and the deficiencies, and with particularly consideration of the commercial outcome of the approval of LegH Prep – the potential for a commercial product that the applicant intends to be considered a staple dietary product in the New Zealand and Australian diet – the Soil and Health Association of New Zealand propose that the LegH Prep (A1186) application should be declined.

 

In addition, the attached PDF which formed the content of our submission to the FSANZ discussed the following issues:

2.0 Precautionary Principle.

3.0 Soil and Health note that section 18

4.0 Food Standards Australia New Zealand Act Section 18.

5.0 Endocrine gaps and gender specific health effects.

6.0 Ultra-processed convenience food.

7.0 90-day dietary studies should study the formulated retail product.

8.0 Contaminants from dietary exposure.

9.0 Misleading cost-benefit analysis.

10.0 Misleading: Substantial Equivalence.

11.0 Misleading: Greater toxicity of the formulation

12.0 Misleading: Scientific knowledge gaps

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