Soil & Health submission on the Gene Technology Bill

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17 February 2025

To the Health Select Committee, New Zealand Parliament

Recommendations

  • The Soil & Health Association of New Zealand opposes the Gene Technology Bill in its entirety. 
  • We recommend the Bill be withdrawn.
  • HEARING: We wish to be heard

Introduction: Who we are

The Soil & Health Association of New Zealand is an incorporated society and not-for-profit registered charity founded in 1941, and is one of the oldest organic organisations in the world. We champion society’s collective responsibility to protect the health of our soils for future generations. We do this to promote the development of the best physical health and spiritual well-being of all people.

Our motto is ‘Oranga nuku – oranga kai – oranga tāngata / Healthy soil – healthy food – healthy people’.

We advocate for organic and regenerative production that works with nature and avoids synthetic fertilisers and pesticides. We’re the largest flaxroots membership organisation supporting organic food and farming in Aotearoa New Zealand. Soil & Health is also the owner of BioGro NZ Ltd, the largest organic certification agency in New Zealand.

We represent approximately 17,000 members and supporters around Aotearoa New Zealand, including consumers, home gardeners, farmers, business people, chefs, scientists and more. Soil & Health provides education and information on the benefits of organic growing, healthy eating and healthy lifestyles for Aotearoa New Zealand and the world.

Our members and supporters value food and lifestyles that enhance the environment and nourish people and animals. Organic and regenerative farming offer solutions to the threats we are facing today: climate change, soil and water pollution, loss of biodiversity, topsoil loss, degrading health and fertility both for people and nature.1

The Soil & Health Association (hereafter Soil & Health, or the Association) welcomes the opportunity to submit on this Bill.

Definitions  

We recognise that gene technology encompasses a range of technologies. What we are most concerned about is keeping robust and precautionary regulation for genetic engineering.  

Genetic engineering (GE): in our submission we use this term for all types of genetic engineering, including gene editing techniques (like CRISPR-Cas9), synthetic biology, anything with “novel” DNA and “new breeding techniques”, recombinant DNA techniques and RNAi (“gene silencing”). 

What the Bill calls genetically modified organisms (GMOs) are therefore included in the above definition. 

Submission

Summary and Overview

The Soil & Health Association of New Zealand opposes the Bill in its entirety and asks for it to be immediately withdrawn. 

Our members and supporters are extremely concerned about the Bill, which represents unprecedented deregulation of the use and consumption of genetically modified organisms (GMOs) in Aotearoa New Zealand.

This Bill, if enacted, would mean that New Zealand would have one of the weakest regulatory regimes for GE in the world, leaving us open to being a global outlier and guinea pig. The Bill lacks the rigour, checks, balances and liability provisions that would safeguard people and the environment.

We are highly concerned about the short timeframe allowed for the drafting of the legislation and for public consultation. If the Bill is not withdrawn, we submit that at least six more months be given for adequate public consultation. 

Gene technology is a huge topic with ramifications for food, agriculture, tikanga Māori, te Tiriti o Waitangi, biodiversity, conservation, economics, trade, health and medicines, science and research, animal welfare, ethics and more. New Zealanders deserve a fair, transparent and thorough process, which the Bill and its development fails to offer.

The Regulatory Impact Statement, compiled by the Ministry of Business, Innovation and Employment, acknowledges the gaps in the RIS, including the uncertainty of benefits. It fails to adequately explore the risks, the economic impacts, and the opportunity costs. 

The provisions in the Bill leave New Zealanders and our environment wide open to risk; and the Bill only covers “regulated organisms” – omitting those genetically engineered organisms that the Regulator (a single person) can deem to be safe and therefore not covered by regulation at all. 

The lack of safeguards in the Bill pose a threat to home gardening, farming, forestry and all forms of primary production. The removal of the precautionary principle means farmers and any other primary producers risk increased costs, unwanted GE contamination, devaluation of their products and organic certification loss.

The Bill disregards consumer choice; it would take away our right to know what we are eating, how it’s produced, and the right to choose GE-free foods, seeds and other products.

The Bill is a direct breach of Te Tiriti o Waitangi and marginalises the interests and concerns of Māori. There has been inadequate consultation with Māori. Genetic engineering goes against spiritual beliefs, whakapapa, mana, mauri, wairua and tino rangatiratanga. 

We cannot afford the potential for risks to our unique and fragile indigenous ecosystems. Why spend millions each year on pest control, biosecurity research and infrastructure if we allow GMOs with unknown risks to spread throughout the entire country?

New Zealand’s fortunate GE-free status is the envy of other countries and gives us great economic advantages on the world market. If the Bill proceeds, markets could be lost and farmers and food producers could lose millions of dollars in export income.

While the Bill does not mention climate change, proponents of GE claim that GMOs could help reduce agricultural greenhouse gas emissions – this was referred to in the Regulatory Impact Statement compiled by the Ministry for Business, Innovation and Employment. However this kind of “quick fix” is primarily promoted by vested interests, and based on a reductionist, rather than holistic and interconnected, world view. 

Such an approach also comes with a huge opportunity cost – it takes investment and focus away from regenerative, organic agriculture and research, which provide long-term, sustainable, nature-based environmental and climate mitigation solutions for future generations. 

We must keep striving for a real “clean and green” Aotearoa New Zealand, for the benefit of all. We cannot allow companies and institutions to release GE products with little or no regulatory oversight, while the liability for, and impacts of, any adverse effects would fall to GE-free producers, the public and the wider environment.

Specific Points

Regulation of Risk and the Precautionary Principle

The Gene Technology Bill’s stated purpose is “to enable the safe use of gene technologies and regulated organisms by managing their risks to—

  1. the health and safety of people; and
  2. the environment.”
  • This wording is not strong enough for robust regulation, and weakens the protections we currently have. 
  • Soil & Health advocates for the retention of our existing robust and precautionary legislation (the Hazardous Substances and New Organisms Act – HSNO Act), which has served us well and protected us against adverse effects of GMOs that have been experienced overseas.
  • The HSNO Act states its purpose to be: “to protect the environment, and the health and safety of people and communities, by preventing or managing the adverse effects of hazardous substances and new organisms.” 
  • This wording acknowledges there are or can be adverse effects, and preventing them – not only managing them – is the purpose of the legislation. Soil & Health wishes first and foremost to prevent adverse effects of GMOs. 
  • The current Bill has no mention of the precautionary principle, while the HSNO Act states “the need for caution in managing adverse effects where there is scientific and technical uncertainty about those effects.” 
  • While scientific knowledge is increasing, there continues to be much uncertainty about the effects of GE, so it’s vital to keep the precautionary principle. 
  • One of the objectives of the Bill is to create “risk-proportionate regulation”. However it fails in this purpose. 
  • The four risk tiers include exempt activities: “minimal-risk products of gene editing, for example, products of editing techniques that result in organisms that cannot be distinguished from those produced by conventional processes”. 
  • Given the lack of long-term use of gene editing globally, especially outside the laboratory, Soil & Health contends we need a robust and precautionary approach. ALL GMOs must be regulated, with NO exemptions, as per the HSNO Act.  

Removal of Choice for Consumers

  • The Bill takes away choice from consumers about the food we eat and grow, and the products we buy. 
  • Our members and supporters, and the wider public, want to know not just what is in our food (and other products), but also how it is produced. We want food that is natural and unadulterated, ethically produced, free from harmful chemicals and toxins, free from GMOs, and produced in ways that enhance our soils, environments and communities. 
  • We want to know how products are produced – for example whether child labour is involved, or GE or herbicides. This is because we are concerned not solely with our own and family health, but also with the health of the wider environment and of the people who produce our food. 
  • We want transparency, traceability and labelling on food and all other consumer products. Regulation must ensure that any products using GE at any stage of production are clearly labelled as such, to allow for consumer choice and transparency. 
  • Therefore, regulation of GMOs must be both process-based and product-based (not either/or). 
  • At present, many products carry either an organic certification label, and/or a GE-free or non-GMO label. Woolworths and Foodstuffs supermarket chains both have non-GMO brand policies. 
  • However this Bill would put this kind of labelling at risk, and consumers would be left in the dark. 
  • It would also probably make organic and non-GMO products more expensive for the consumer as it would be more onerous for producers to ensure their production is GE-free.  
  • GE products are NOT the same as natural products and therefore must not be allowed to be exempt from regulation. Unintended changes in gene edited organisms occur, and are different from random mutations in nature.2 
  • The Bill allows one person – the Regulator – to decide whether a GE process or product is to be regulated or not. If not regulated, GMOs would be invisible and could enter our food chain and environment with no safety assessment, no public notification, no labelling, no traceability, and not be subject to any controls or monitoring. 
  • This creates unacceptable levels of risk and lack of choice. 
  • Lack of adequate labelling poses a health risk, as allergens and toxins can be produced as a result of gene technologies.
  • Even though humans have been eating GE ingredients for some years, we don’t know enough yet about the effects of GE foods on the human body, or on epigenetic effects, as there has been very little research on this. GE foods and ingredients may contain combinations and components never seen before by our gut bacteria and other bodily systems.  
  • We are concerned not just about the potential for adverse effects directly as a result of genetic engineering, but also any adverse effects of other technologies used in combination with GMOs. This includes herbicide residues in herbicide-resistant crops. 
  • Other emerging technologies – such as synthetic biology, generative artificial intelligence (AI), and nanotechnology – are beginning to be used in combination with GE. An example is the use of generative artificial intelligence (AI) in the creation of GE plants.3 
  • Given the known and unknown risks of GE and AI, and the increasing ease and speed of developing gene-edited products, such combinations of risky technologies must be strictly regulated. 
  • Therefore the precautionary principle needs to be retained in our legislation of GE.

Risks for Farming, Forestry and Other Primary Production

  • The Bill gives the Regulator the ability to allow some gene technologies to go completely unregulated. This means some GMOs could be released into the outdoor environment, and/or into agricultural and veterinary inputs, with no controls or monitoring. This puts at risk all forms of primary production in Aotearoa New Zealand.
  • Farmers, growers, beekeepers, foresters, aquaculture operators and other primary producers would risk losing markets, organic or non-GMO certification if they have it, income and time, and potentially face legal costs, as has happened already in a number of other countries.4 
  • In particular the Bill puts at risk primary producers who want to remain GE-free, including organic production. GE agriculture is completely incompatible with organic and regenerative agriculture. Organic standards around the world specify that GE techniques and organisms are not to be used in certified organic systems. 
  • Co-existence of GE and non-GE crops is virtually impossible due to the many vectors of DNA. In the case of plants for example GE contamination can be spread by pollen, and by seed spread via wind, water, animals, human activity. 
  • GE ryegrass for example, if introduced, would inevitably spread across boundaries and contaminate farms, gardens and natural ecosystems, with unknown effects. In the USA, GE bentgrass spread from supposedly controlled plots.5
  • Farmers across the board are concerned about contamination because of potential impacts on productivity, market resistance, livelihood and ecological concerns, and want strong legislation to prevent GE contamination. 
  • Forestry must not be put at risk by any form of GE. Both main sustainable forestry certification schemes in New Zealand – Forest Stewardship Council (FSC) and Programme for the Endorsement of Forestry Certification (PEFC) maintain GE-free policies for all forests certified to their standards.

GE is Not a Solution to Climate Change and Pollution

  • A permissive GE regime is not a coherent response to the interconnected issues of climate change, loss of biodiversity, global warming, greenhouse gas emissions, topsoil loss and nitrate leaching from farming into waterways. 
  • New Zealand is in a prime position to implement coherent climate, environmental and agriculture policies. A huge part of that advantage is this country’s existing robust and precautionary policy on GMOs. 
  • GE ryegrass and clover have been mooted as part of the solution to reducing New Zealand’s methane emissions from ruminant animals. However this is far from proven, they may have adverse effects, and are not part of the holistic approach that is needed.
  • Many GE crops are designed to be used with harmful herbicides which are contributing to environmental degradation, biodiversity loss, and herbicide resistance. 
  • Farmers and the New Zealand public need time to assess the risks and benefits of continuing research into GE, who would benefit from it, and how it compares with other strategies to reduce agricultural greenhouse gas emissions.

Te Tiriti o Waitangi and Tikanga Māori

  • Soil & Health is a Treaty partner with Te Waka Kai Ora,6 the Kaitiaki of the Hua Parakore verification system, the world’s first indigenous verification system for food and primary products.7 
  • Te Waka Kai Ora has expressed complete opposition to the Bill for several reasons. We fully support their submission. 
  • The Crown has not engaged with Māori adequately or sufficiently in the development of the Bill. Māori are rights holders, not stakeholders, and should be treated as such. This is stated in the Universal Declaration of Human Rights and the United Nations Declaration of Indigenous Peoples.
  • The Bill gives the Regulator the power to exempt specific gene technologies from regulation, allowing Aotearoa New Zealand to be subject to assessments made by overseas regulators. 
  • This constitutes a breach of Te Tiriti o Waitangi, as it grants sovereignty to external entities, rather than to iwi and hapū, who never ceded sovereignty over their lands. Article 2 of Te Tiriti recognises Māori rangatiratanga over their lands and taonga.
  • The Bill has the potential to devastate the Hua Parakore verification system, which is recognised globally for its holistic approach to food and primary products. This system is grounded in Te Ao Māori, derived from the wisdom of Māori tūpuna (ancestors) and supported by both tangata whenua and tangata Tiriti, who are seeking indigenous growing kaupapa led by indigenous knowledge reclamation. Hua Parakore offers pure products based on integrity and whakapapa. However, the introduction of gene technology, particularly in outdoor applications, risks compromising traceability within this verification system.
  • One of the Bill’s stated objectives is “to provide for ways to recognise and give effect to the Crown’s obligations under the Treaty of Waitangi”. There is already one claim before the Waitangi Tribunal that involves genetic engineering, namely Claim WAI262.8 Until this claim is settled to the satisfaction of Māori, no changes to legislation involving GE should proceed. 
  • Furthermore, the Bill provides for the establishment of a Māori Advisory Committee, while ensuring that the power of this Committee remains weak. The Bill states only that the Regulator should “have regard to advice” from the Committee, which will have no decision-making authority, nor the power of veto.
  • The Bill marginalises Māori as it does the public and wider community. It limits the scope of the Māori Advisory Committee to gene technology issues involving indigenous species or “material adverse effects on kaitiaki relationships”. Therefore the Bill does not take into account whakapapa and a range of cultural and ethical considerations, including mana, mauri, whakapapa and wairua, while also recognising that Māori concerns extend beyond indigenous species.

Risk to Ecosystems, in Particular Native Ecosystems

  • Aotearoa New Zealand has a unique environment with 80% of its native species being endemic. 
  • Many native species are already threatened, endangered, or at risk of extinction. Because we don’t know the impacts of GMOs within ecosystems, introducing GE could put native species even more at risk. 
  • GE plants – and the pesticides frequently used with them as part of the package – are a risk to bees and other pollinators. The flow-on multiplier effect within ecosystems is potentially enormous.
  • While GE has been posited as a solution for pest control, there are risks and we may end up creating more problems.
  • Scientists estimate that so far they have only identified a small proportion of the microorganisms in the soil,9 and there are many other species that are yet to be discovered and identified, such as invertebrates and marine organisms. We simply do not know enough about the complex interactions in ecosystems to risk releasing GMOs into the environment. 
  • Once GMOs are released into the environment, there is no turning back. We can’t contain or recall the crops, animals, fish, insects or microorganisms.
  • Examples of unwanted GMO escapes include fluorescent zebrafish (“Glofish”) which are now wild in Brazilian rivers, and reproducing rapidly. Researchers are concerned about adverse impacts on aquatic ecosystems and endemic species.10 
  • The approval of GE salmon in North America was challenged in a federal court in California by Earthjustice and other claimants. GE fish could breed with, or outcompete, their wild counterparts.11 
  • Monarch butterfly numbers in the USA have plummeted over the past couple of decades, and GE crops have been cited as part of this decline. GE maize pollen has been found to harm monarch larvae,12 and other researchers have pointed to glyphosate-resistant GE crops as being a major factor in monarch butterfly decline.13

Economic and Financial Impacts, and Opportunity Costs

  • The regulatory impact statement compiled by MBIE focuses strongly on the potential economic benefits of loosening the regulation of GE. However, it includes no assessment of economic losses resulting from this legislation, nor the opportunity costs. 
  • The RIS simply says there would be “Unquantified costs to organic/non-GMO primary producers.”
  • The New Zealand Institute of Economic Research has produced a report detailing the economic risks of this legislation, and has estimated that “environmental release of GMOs in New Zealand could reduce exports from the primary sector by up to $10 billion to $20 billion annually”.14 
  • There are cases where countries have rejected crops and products contaminated by GMOs.15 This would be a significant risk for our export sector. Once GMOs are released in our environment, there is no turning back. Contamination will be inevitable. 
  • New Zealand has enjoyed an image of being clean and green, which has attracted tourists and our overseas export markets. This Bill risks damaging this image, our export and tourism sectors, and our economy. 
  • Organic exports would be particularly at risk because organic standards, driven by consumer demand, allow no GE use. According to the Organic Exporters Association of New Zealand, “in 2022–2023, New Zealand’s organic exports were valued at over $560 million, with $164 million exported with official MPI assurance. The remaining value was exported to markets without organic bilateral arrangements.”16 
  • The European Green Deal17 offers an enormous opportunity for New Zealand to build its GE-free and organic export production. Allowing the introduction of GMOs would take that incredible opportunity away from us. 
  • Opportunity costs would include missed opportunities to focus on research and investment into organic and regenerative farming systems that would mitigate climate, enhance soils, waterways, animal and human health, seeking to understand and work with nature, rather than trying to manipulate it. 
  • An example of this non-GE research and development is a lower methane-emitting sheep developed through selective breeding by AgResearch.18 New Zealand is a world leader in plant and animal breeding that doesn’t use GE, and this is what we need to build on. 
  • The benefits to a few corporations that develop and sell GE technologies must not come before people’s health, farmers’ ability to carry on biological, regenerative, GMO-free and organic farming, our unique environment and our chance to genuinely live up to our clean and green reputation in the global market.

Spiritual, Philosophical and Ethical Considerations

  • Many of our members and supporters feel an intuitive discomfort and a deep spiritual dis-ease about genetic engineering. Many people feel we shouldn’t be engaging in the types of technology that seek to ‘play God’ and change the building blocks of life. 
  • Animal welfare is a high priority for our members, who are concerned about the ethics of GE animal experiments. 
  • We oppose the use of animals as “bioreactors” to produce therapeutic substances. GE experimentation on animals here in New Zealand for such purposes has produced no medical benefit and has resulted in much suffering. A report by GE Free NZ, drawing from AgResearch annual reports, catalogues the deaths, deformities, abortions, sterility and numerous other health problems that the GE research animals have been subjected to.19 
  • We are also opposed to the patenting of all life forms. 
  • This bill would allow international corporations and a small number of shareholders to control and own life in New Zealand. This will never benefit New Zealand and New Zealanders in a long-term and meaningful way.

Liability

  • The Resource Management Act provides the ability for territorial authorities to make provision for liability, including the ability to require a bond from users of GE in the event of any adverse effects. We support this as it provides some financial protection for councils and communities.
  • The Gene Technology Bill however contains no provisions for liability of the users of gene technologies should anything go wrong. The users of any gene technologies must be held legally and financially liable for any adverse effects of their processes, activities and products – including any waste products. 
  • If anyone has gone through a strict assessment process to use GE in the outdoor environment, they must be required to have commercial insurance in case of adverse effects. The Bill fails to require this. 
  • Previous outdoor GE trials in New Zealand have breached their conditions – all users of GE must be legally and financially liable for any breaches and escapes. The Bill fails to ensure this.

Local Democracy

  • All councils from Auckland to Northland, and Hastings District Council, currently have precautionary, protective and/or prohibitive policies and plans.
  • This has been at the behest of their communities, who want an extra level of protection from any adverse effects of GE in the outdoor environment, and/or to enable regions to promote their region and their products as GE-free. 
  • Soil & Health has supported councils in the Environment Court, which confirmed this right under the Resource Management Act to choose GE policies at city, district and regional levels. 
  • The Bill however expressly removes the right and ability of territorial authorities to determine their own GE policies and plans, as they currently enjoy. 
  • We oppose the specific removal of this right, because it is undemocratic, and a heavy-handed overreach of central government into the realm of local government decision-making.

GE in Health and Medicine

  • The precautionary principle must apply to all gene technologies including those for medical purposes. 
  • Any uses of any gene technology for human health must be fully transparent and only used with genuine informed consent. Therefore we oppose the emergency authorisation of medical products using gene technology. 
  • Soil & Health opposes the Bill’s proposed mandatory medical approval of human medicines that have been approved by at least two overseas regulators. This could result in the forced use of a product with insufficient oversight, disregarding specific circumstances in Aotearoa New Zealand, including Te Tiriti o Waitangi and tikanga Māori. It fails to ensure informed consent, and could undermine protections outlined in the Bill of Rights. It fails to address the risk of regulatory capture by pro-GE interests in overseas jurisdictions.
  • We oppose the use of animals as “bioreactors” to produce therapeutic substances, given the unnecessary harm, suffering and failures that have resulted from experiments using animals.

In summary

In summary, the Soil & Health Association rejects the Gene Technology Bill, and supports retaining the precautionary and protective GE legislation of the HSNO Act.

We appreciate the opportunity to submit on this critical issue and are available for further discussion or to provide additional information as needed.

References

  1. https://rodaleinstitute.org/science/ and https://www.cambridge.org/core/journals/renewable-agriculture-and-food-systems/article/organic-agriculture-and-climate-change/74A590FA3F35A79A858336CF341F416C ↩︎
  2. Lazar, NH et al. 2024. High-resolution genome-wide mapping of chromosome-arm-scale truncations induced by CRISPR–Cas9 editing Nature Genetics 56, 1482–1493, https://www.nature.com/articles/s41588-024-01758-y and brief analysis by Test Biotech here: https://www.testbiotech.org/en/unkategorisiert/crispr-the-unintended-genetic-changes-caused-by-gene-scissors-are-different-to-random-mutations/ ↩︎
  3. Save Our Seeds. 2025. When chatbots breed new plant varieties. http://upd-sos.zs-intern.de/fileadmin/files/SOS/ai/SOS_When_chatbots_breed_new_plant_varieties.pdf ↩︎
  4. For example Western Australian organic canola farmer Steve Marsh lost organic certification and income, and faces over A$800,000 in legal costs. https://www.ecowatch.com/organic-farmer-dealt-final-blow-in-landmark-lawsuit-over-monsantos-gmo-1882173163.html ↩︎
  5. Center for Biological Diversity. 2016. “Commercial Approval of Engineered Bentgrass Given Despite Failed Efforts to Stop Its Spread From Old Experiment Plots” https://www.biologicaldiversity.org/news/press_releases/2016/bentgrass-12-07-2016.html ↩︎
  6. Te Waka Kai Ora, the National Māori Organics Authority, https://www.tewakakaiora.co.nz/ ↩︎
  7. Hua Parakore verification system, https://www.tewakakaiora.co.nz/whatishuaparakore ↩︎
  8. Wai 262 Taumata Whakapūmau – claimants and their descendents, Waitangi Tribunal claim 262, https://www.wai262.nz/ ↩︎
  9. Fierer, N. 2017. Embracing the unknown: disentangling the complexities of the soil microbiome. Nature Reviews Microbiology. 15 https://www.nature.com/articles/nrmicro.2017.87 ↩︎
  10. Canadian Biotechnology Action Network briefing. 2022. 
    https://cban.ca/wp-content/uploads/GM-Contamination-Animals-Feb-2022-Update.pdf ↩︎
  11. Earthjustice media release. 5 November 2020. Federal Court Declares Genetically Engineered Salmon Unlawful. https://earthjustice.org/press/2020/federal-court-declares-genetically-engineered-salmon-unlawful ↩︎
  12. Losey, JE et al. 1999. Transgenic pollen harms monarch larvae. Nature 399
    https://www.nature.com/articles/20338 ↩︎
  13. Pleasants, J. 2017. Milkweed restoration in the Midwest for monarch butterfly recovery. Insect Conservation and Diversity 10(1)
    https://resjournals.onlinelibrary.wiley.com/doi/abs/10.1111/icad.12198 and Flockhart DTT et al. 2015. Unravelling the annual cycle in a migratory animal: breeding-season habitat loss drives population declines of monarch butterflies. Journal of Animal Ecology 84(1) https://besjournals.onlinelibrary.wiley.com/doi/full/10.1111/1365-2656.12253 ↩︎
  14. New Zealand Institute of Economic Research. 2024. Potential costs of regulatory changes for gene technology: Economic assessments of an MBIE proposal. https://drive.google.com/file/d/17fC5qTDVscJBfuKGIG1oopjnXI0oib1b/view  ↩︎
  15. EU detects GM rice in Pakistan’s basmati consignment. 7 August 2024. The Hindu. https://www.thehindubusinessline.com/economy/agri-business/eu-detects-gm-rice-in-pakistans-basmati-consignment/article68497159.ece ↩︎
  16. Organic Exporters Association of New Zealand, retrieved from their website 16.2.2025 : https://www.organictradenz.com/who-we-are ↩︎
  17. European Commission. Retrieved from their website 16.2.2025 https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal_en  ↩︎
  18. Low methane sheep: Breeding for the future. AgResearch website, retrieved 17.2.2025. https://www.agresearch.co.nz/our-research/low-methane-sheep/ ↩︎
  19. Claire Bleakley. 2015. GE Animals in New Zealand: The First Fifteen Years. GE Free New Zealand (in food and environment) https://www.gefree.org.nz/assets/pdf/GE-Animals-in-New-Zealand.pdf ↩︎
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Soil & Health submission on the EPA’s chlorpyrifos reassessment – proposed ban

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12 February 2025

The Soil & Health Association of New Zealand, representing a diverse community of organic producers, consumers, and advocates, submits this response to the proposed reassessment of chlorpyrifos under the current Evironmental Protection Authority review.

Our association is committed to advocating for the production and consumption of organic food under the motto ‘Healthy soil – healthy food – healthy people: Oranga nuku – oranga kai – oranga tāngata.’ It is from this foundation that we express our concerns regarding the continued use of chlorpyrifos in agricultural practices in New Zealand.

Recommendation

Soil & Health fully supports the EPA’s proposal to ban the use of chlorpyrifos by revoking its approvals.

Reasons  

1. Environmental and Health Risks

Chlorpyrifos is widely documented as a persistent environmental pollutant with significant detrimental effects on wildlife and human health. Its persistence in ecosystems and its ability to degrade slowly in environmental conditions pose a long-term risk to ecological health and biodiversity. 

Notably, chlorpyrifos has been linked to developmental delays and other health risks in humans, which is particularly concerning for communities in agricultural areas and for consumers globally. Babies in the womb and young children are at greater risk of neurological damage and developmental disorders, even when exposed to very low levels of chlorpyrifos. 

2. Global Regulatory Actions

We note that several international jurisdictions, including the European Union and Canada, have moved towards severe restrictions or outright bans of chlorpyrifos, reflecting growing scientific consensus and public health policy shifts towards more sustainable and safe agricultural practices. This global trend underscores the need for New Zealand to consider similar actions to align with international health and safety standards.

3. Incompatibility with Organic Standards

Chlorpyrifos use is incompatible with organic farming principles, which focus on maintaining ecological balance and avoiding synthetic toxins in agriculture. Continuing its use undermines the integrity of New Zealand’s organic sector and the trust of domestic and international consumers in New Zealand’s organic produce.

4. Advocacy for an Outright Ban

Given the substantial evidence of chlorpyrifos’ adverse impacts, and in support of a precautionary approach to pesticide regulation, Soil & Health advocates for an outright ban on the use of chlorpyrifos in New Zealand. We recommend that the EPA facilitate a transition to safer, sustainable, and equally effective alternatives that are available and increasingly being adopted worldwide.

5. Support for Affected Farmers

We propose that the EPA and relevant agricultural bodies work together to support farmers who may be affected by such a ban, including providing access to training in alternative pest control methods and financial support and/or peer support network facilitation during the transition period.

In conclusion

Soil & Health wishes to reiterate the importance of a proactive regulatory approach that prioritizes public and environmental health. We believe that banning chlorpyrifos will represent a significant step forward in protecting our environment, health, and the integrity of our agricultural sector.

We appreciate the opportunity to submit on this critical issue and are available for further discussion or to provide additional information as needed.

Warm regards,

Charles Hyland

Chair, Soil & Health Association of New Zealand

References

Re-evaluation Note REV2021-04, Cancellation of remaining chlorpyrifos registrations under paragraph 20(1)(a) of the Pest Control Products Act. Health Canada. (2021). Retrieved from Health Canada website: https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/decisions-updates/reevaluation-note/2021/cancellation-remaining-chlorpyrifos-registrations.html

U.S. Environmental Protection Agency (EPA). (2020). Revised human health risk assessment on chlorpyrifos. Retrieved from EPA website: https://www.epa.gov/ingredients-used-pesticide-products/chlorpyrifos

White, Alison (2024). Neurotoxic Pesticide in our Food. Retrieved from Organic NZ magazine: https://organicnz.org.nz/magazine-articles/neurotoxic-pesticide-in-our-food/

European Food Safety Authority (EFSA). (2019). Statement on the available outcomes of the human health assessment in the context of the pesticides peer review of the active substance chlorpyrifos. Retrieved from EFSA website: https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2019.5809

Pesticide Action Network Asia and the Pacific. (2022). Children at risk from toxic pesticide: New Zealand should urgently reassess chlorpyrifos. Retrieved from https://panap.net/2022/06/children-at-risk-from-toxic-pesticide-new-zealand-should-urgently-reassess-chlorpyrifos/

Submission on application APP203660 – To reassess methyl bromide

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29 August 2019

Environmental Protection Authority
Private Bag 63002
Wellington 6140
New Zealand

Submission on application APP203660

To reassess methyl bromide

Introduction

1.   The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organisation supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership comprises home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.

2.   Soil & Health makes this submission on the application by Stakeholders in Methyl Bromide Reduction Inc (STIMBR)  to reassess methyl bromide a fumigant that is among other things is used on export timber and logs.

3.   Soil & Health accepts the need for fumigation to meet the phytosanitary needs of New Zealand and other countries, should safer methods of pest control not be effective, and if communities and the broader environment are protected from any adverse effects from the fumigant.

4.   The EPA in 2018 allowed the possibility of a reassessment application;

‘Grounds to reassess were granted based on data that evidenced New Zealand’s use of the fumigant has increased from over 400 tonnes a year in 2010, to more than 600 tonnes in 2016. One of the criteria required to meet grounds for reassessment under the Hazardous Substances and New Organisms Act, is a significant change in the quantity of a substance imported into or manufactured in New Zealand.’

5.     Soil & Health believes that the reassessment criteria were used inappropriately, as that increased use was predicted at the last reassessment with conditions of use and the recapture deadline made in that knowledge. It is misleading to use increased use to allow another reassessment to effectively excuse the log export industry out of their environmental and public health responsibilities when those responsibilities were clearly defined in 2010.

6.     Soil & Health submitted to the Environmental Risk Management Authority (ERMA) for the reassessment of methyl bromide in 2010 and has campaigned since to have that fumigant better contained and recaptured or stopped.

7.     Those campaigns along with other community, union, and environmental groups have meant that methyl bromide fumigation without recapture is no longer used at log exporting facilities in several ports, notably Nelson, Picton and Wellington. However the problems of worker exposure and release of the atmospheric ozone depleting gas have mostly just shifted north to the ports of Napier, Tauranga, and Marsden Point-Whangarei.

8.     This submission writer, later in another role as a Section 274 Party, won an Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12. That case, contested for the applicant Envirofume by legal counsel Helen Atkins (Chairperson of the 2010 ERMA methyl bromide re-assessment), exposed further the significant risks of methyl bromide fumigation for the health and safety of workers and nearby communities.

9.     The log exporter industry through STIMBR have variously used public funding as in the Primary Growth Partnership (PGP) funding to look mostly at predictably unlikely alternatives to recapturing residual methyl bromide, while obfuscating attempts at log stack trials of existing recapture technology using carbon filters as available from Nordiko.

10.  STIMBR supported Draslovka who applied for an alternative fumigant ethanedinitrile (EDN) which the Ministry for Primary Industries (MPI) appear to be taking seriously in negotiations with log importing countries as an alternative to methyl bromide, on the premise that recapture will not be necessary should EDN be approved, as it is not subject to the Montreal Protocol.

11.  Soil & Health submitted in opposition to EDN due to the known risks, and the lack of environmental and safety data, and that the applicant and STIMBR’s approach that recapture would not be required, although in Australia, EDN can ONLY be used with scrubbing (a recapture) technology as part of its label use after being assessed by the national regulatory body there, the Australian Pesticides and Veterinary Medicines Authority (APVMA).

12.  Soil & Health is concerned that government agencies such as MPI might be looking at the EPA as a rubber-stamping agency for compounds such as EDN with such confidence that they are putting EDN as an option for fumigation to countries including India and China. Soil & Health is concerned that industry’s economic benefits appear to become paramount over the need of worker, community and environmental health in the decision making around fumigants approval and their use.

13.  However, the EPA has decided to process this application by STIMBR as a modified reassessment rather than forcing the previous reassessment’s requirement of recapture onto the users of methyl bromide fumigation.

The Tauranga example

14.  While economic considerations are included in the benefits analysis by the EPA, the ability to pay for appropriate safeguards must be included in any analysis, not just the significant earnings the industry generates. All stakeholders including port companies should be part of ensuring the ultimate safety of workers, community and environment.

15.  In the Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12, it was noted that Port of Tauranga Limited (POTL) did not attend those proceedings although it was the owner and operator of the port where the log fumigation activity under scrutiny was taking place.

16.  The community and Soil & Health have long called for dedicated fumigation facilities incorporating recapture technology to be constructed and used, yet POTL continue to discount any such possibility there.

17. Soil & Health points out that POTL has just announced its largest profit ever (end of year June 2019). Increasing 6.7% on last year’s profit of $94.3 million to reach $100.6 million, with log export volumes increasing during that time 12.5% to 7.1 million tonnes. http://www.port-tauranga.co.nz/growth-in-cargo-volumes-contributes-to-increased-profit-for-port-of-tauranga-limited/

While that growth is expected to ease in the short term, POTL is still the country’s largest export log exporter, close to twice its nearest rival Whangarei.

18.  Log exports through POTL for the year ending December 2017 were valued at $968,919,331, almost a staggering billion dollars towards a third of New Zealand’s log export value that year of $3,058,737,889 and yet the port company and log exporting interests continue to deny workers, the community and environment the benefits of recapture.

19. Safeguards to protect people and the environment are becoming more important and need greater attention as increasing development and presence of toxins including fumigants in the environment become more common.

20.  Soil & Health submits that the money is there for fast correction of the shortcomings in facilities and responsible management of log and timber fumigation in New Zealand.

Monitoring and modelling

20. Methyl bromide is a risk well beyond fumigation areas due to drift, inversion layers, and the inability by those responsible to adequately monitor its whereabouts. Boundary monitoring is pointless if at head height, when a fumigant plume passes above it and then descends or drifts into other areas.

22.  Air modelling techniques cannot fully give assurances about where and at what concentrations methyl bromide will be once released from containers, log stacks or ships holds. Modelling can at best be a best estimate, but the topography of the fumigation surrounds is continually changing with log or container stacks, ships size and presence, and weather variables, including humidity, temperature of air, objects and ground all obfuscating the best air modelling estimates.

23. There is no sure air monitoring possibility, or method for the safe release of methyl bromide in the port and coastal marine area. A previous Environment Court in Nelson noted the possibility for “monitoring devices to miss the most concentrated area of the plume, or even the plume in its entirety, and in fact on four out of seven attempts to sample air quality in Port Nelson during 2003-2004 this had occurred in varying degrees” (Env Court Interim Decision para 50).

24.  Soil & Health notes STIMBR’s intent that recapture of fumigant from ships holds be delayed significantly, another 10 years, yet ships’ holds are where the most significant volumes of methyl bromide are used. The communities near the ports of Napier, Tauranga and Mt Maunganui, and Marsden Point (Whangarei port), and potentially elsewhere in New Zealand will be further exposed to the toxicity of methyl bromide, and the damage to the ozone layer will continue.

25.  Other port workers, not involved in fumigation but working nearby, may also be exposed to the methyl bromide, particularly when the methyl bromide is released into the atmosphere following fumigation, but also during accidental and spontaneous release, as happens with methyl bromide most years, at most log stack fumigating ports. Log stack fumigations under tarpaulins are subject to strong wind events and accidental tarpaulin puncturing. Both Genera and Envirofume fumigation operators have had log stack tarpaulins rent with spontaneous release of methyl bromide.  Dedicated permanent fumigation structures would eliminate the risk of tarpaulin failure.

Worker and community safety

  1. In the Environment Court decision Envirofume Limited vs Bay of Plenty Regional Council, [2017] NZEnv 12, the court observed the large range of port users that may be exposed inadvertently to the methyl bromide fumigant. [1]
  2. That Court found significant shortcomings in the current methyl bromide fumigation. EPA and Work Safe requirements are either impractical or are frequently breached.
  3. Whatever toxic fumigant is used for log, timber and other fumigation, it must be in a dedicated facility with recapture of remnant fumigant, such as is used at Port Nelson. Methyl bromide was linked at that port with the deaths of six men from motor neurone disease. Alternative fumigants such as EDN have their own array of serious health risks. Recapture technology exists but industry individually and collectively has mostly avoided its use for economic reasons.

Ozone depletion

  1. Continued methyl bromide release means further atmospheric ozone depletion, and New Zealand’s intentional breach of responsibility to its Montreal Protocol obligations, where although phytosanitary requirements allow some continued use of methyl bromide, there is an obligation to be reducing its use. ERMA allowed a continuance of damaging release into the atmosphere in 2010 with the knowledge that there would be a significant increase in methyl bromide use.
  2. Dr Olaf Morgenstern – Programme leader (Climate Variability and Change) NIWA for the writer at the Environment Court outlined the significance of that release in world terms, with New Zealand being the highest user per capita. That should not continue if we are concerned about climate effects and the health of people and environment, or economically if our international, including trading, clean green branding reputation is to be valued.

Health effects.

  1. Most people acknowledge the very real danger of methyl bromide from both acute and chronic exposures, and both acute and chronic effects. A recent although limited US study recently published in the Journal of Asthma reported a positive association between methyl-bromide concentrations and asthma-related emergency department (ED) visits among youths between the ages of 6 and 18 years in California.
  2. After adjusting for the presence of other pollutants, humidity, and meteorological conditions, each 0.01-ppb increase in methyl-bromide concentration was associated with a 7.1% (95% CI, 2.9%-10.8%) greater likelihood of an asthma-related ED visit.
  3. That science will need more work but further shows the need for recapture if real precaution is to be used.

The solution – dedicated containment and recapture.

  1. Responsibility for dedicated containment and recapture facilities was considered by the Environment Court to require an integrated approach:

[130] Overall, our view is that this matter requires an integrated approach from the Port of Tauranga, the marshalling/stevedoring companies, the forestry industry and the fumigators to adopt an approach for the safe application of methyl bromide and the recapture of all reasonable emissions. This would probably require a dedicated area for fumigation, and may involve a building or other system that seeks to encapsulate and recapture gas. We are not satisfied that the introduction of another company into the Tauranga market is going to bring about those changes. In our view, the advance towards reduction of emissions has seen little progress since the 1990s, and the Court is surprised to see that there is approximately ten times as much methyl bromide being applied in Tauranga as there was in the 1990s.

  1. Regardless of the possibility of an alternative fumigant, industry including port companies and possibly government need to bite the bullet and install dedicated facilities for fumigation and recapture.
  2. The ERMA 2010 methyl bromide re-assessment inappropriately and possibly illegally set a very late 2020 date for recapture of that fumigant to meet Montreal Protocol requirements of phasing out methyl bromide emissions. The EPA must now insist on dedicated fumigation facilities and recapture always, if the EPA is to meet its statutory requirements.
  3. Soil & Health supports the substantive submission of the Combined Trade Unions, and is in general agreement of the fumigation context and need for stronger and certain safety conditions as supplied by the Bay of Plenty Regional Council.
  4. Soil & Health submits that the evidence as attached and provided by expert witnesses for the writer for the Envirofume Environment Court case be considered by the EPA. That included evidence by an epidemiologist Dr Dave McLean from the Centre for Public Health Research, Dr Olaf Morgenstern – Programme leader (Climate Variability and Change) NIWA, and Jayne Metcalfe an air scientist.

Conclusion.

39.  Soil & Health seek that the current application be declined.

40.  Should the application be granted, dedicated fumigation facilities and recapture must be required.

41.  Soil & Health wish to be heard in support of our submission and welcome any questions of the writer for clarification or further information.

Yours sincerely

Steffan Browning

021 804 223

greeny25@xtra.co.nz

Position: National Councillor

The Soil & Health Association

PO Box 9693,

Marion Square,

Wellington, 6141

Email: advocacy@organicnz.org.nz

Website: www.organicnz.org.nz

[1] https://www.environmentcourt.govt.nz/assets/Documents/Decisions/2017-NZEnvC-012-Envirofume-v-Bay-of-Plenty-Regional-Council.pdf

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