Submission on the Agricultural Compounds and Veterinary Medicines Amendment Bill
To: Primary Production Committee
Submitter: The Soil & Health Association of New Zealand
Date: 15 June 2026
Soil & Health wishes to speak to this submission.
1. Summary position
The Soil & Health Association of New Zealand opposes the Agricultural Compounds and Veterinary Medicines Amendment Bill in its current form.
Soil & Health supports efficient, transparent and scientifically robust regulation. We also recognise that farmers, growers and veterinarians need access to safe and effective agricultural compounds and veterinary medicines, including products that support animal welfare, plant health, food safety and sustainable production.
However, efficiency must not come at the expense of careful assessment, public transparency, organic integrity, GE-free production, animal welfare, food safety, trade protection, Te Tiriti obligations, soil health, water quality, biodiversity and consumer trust.
The Bill has been progressed alongside the Hazardous Substances and New Organisms Amendment Bill and the wider Gene Technology reform programme. Together, these reforms could create faster pathways for agricultural products, veterinary medicines, novel or engineered biological products, gene-related technologies, animal treatments, inhibitor substances, fertilisers and crop protection products without sufficient consultation with the organic sector, Māori, certifiers, growers, farmers, veterinarians, exporters and consumers.
Soil & Health asks the Primary Production Committee to recommend that the Bill does not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be substantially amended to ensure that independent New Zealand assessment, precaution, public participation, organic and GE-free integrity, animal welfare, food safety, trade protection and Te Tiriti obligations remain central to the ACVM regulatory system.
2. About Soil & Health
Soil & Health is one of the world’s oldest organic advocacy organisations. Our kaupapa is healthy soil, healthy food and healthy people. We advocate for food and farming systems that protect soil, water, biodiversity, human health, animal welfare and future generations.
Organic production is built on trust. That trust depends on clear standards, strong regulation, careful assessment of risk, and the ability of producers and consumers to rely on products being genuinely organic and GE-free.
Agricultural compounds and veterinary medicines are not abstract regulatory products. They include veterinary medicines, crop protection products, vertebrate toxic agents, animal feeds, fertilisers, environmental inhibitors and other farm inputs. Decisions about these products can affect organic certification, residue status, export assurance, animal welfare, soil biology, water quality, biodiversity, consumer trust and market access.
3. Consultation has been inadequate
Soil & Health is concerned that the Bill has been progressed too quickly and with insufficient consultation with the organic community, Māori, certifiers, environmental organisations, consumers, pet owners, animal breeders, zoos, the Department of Conservation, wildlife hospitals and others working with native species.
The Bill is technically complex. It also sits alongside the HSNO Amendment Bill and the Gene Technology Bill. The combined implications are significant and cannot be properly assessed in isolation.
The organic sector has not had adequate time to analyse the Bill, understand its interactions with other legislation, assess implications for organic certification and GE-free production, and provide fully informed feedback.
Soil & Health asks the Committee to slow the process, consult properly, and require a clear assessment of the combined effects of the ACVM, HSNO and gene technology reforms before proceeding.
4. The protective purpose of the ACVM system must remain central
The purpose of the ACVM Act includes preventing or managing risks to public health, trade in primary produce, animal welfare and agricultural security. Those protective purposes must remain central.
The Bill is presented as a measure to reduce barriers, improve flexibility and provide faster access to new products. Soil & Health does not oppose better regulatory administration.
However, the test should not simply be whether a product can reach the market faster. The test should be whether it is safe, effective, suitable for New Zealand conditions, compatible with organic and GE-free production, and properly controlled.
The ACVM system must protect more than product access. It must protect food safety, animal welfare, trade assurance, organic integrity, environmental health and public trust.
5. Overseas assessments must not replace New Zealand assessment
Soil & Health is concerned about greater reliance on overseas regulators and overseas assessments. International information can be useful. However, overseas approvals must not replace independent New Zealand assessment.
New Zealand has distinct environmental, farming, animal health, trade and market conditions, including:
- unique soils, waterways and biodiversity
- small catchments and high rainfall in many regions
- pastoral farming systems that differ from many overseas jurisdictions
- organic, regenerative and GE-free production systems
- export markets that depend on trust, residue assurance and non-GE integrity
- Māori relationships with whenua, wai, mahinga kai, taonga species and whakapapa
- consumer expectations around natural, organic and GE-free food.
A product approved overseas may not be appropriate for New Zealand conditions. This is especially important where overseas jurisdictions have different approaches to gene technologies, animal treatments, crop inputs, residues, veterinary medicines, environmental inhibitors or novel biological products.
If overseas assessments are used, they should inform New Zealand decision-making only. They should not substitute for New Zealand assessment, New Zealand consultation or New Zealand accountability.
6. Recognised overseas regulators must be clearly defined
The Bill refers to recognised overseas regulators. The Act should not allow reliance on an overseas regulator unless clear statutory criteria explain how recognition is granted, reviewed and, if necessary, revoked.
At a minimum, recognition should consider:
- whether the overseas regulator applies precautionary assessment
- whether it assesses public health, trade, animal welfare, agricultural security, food safety and environmental risks
- whether it regulates gene technologies and novel biological products in a way compatible with New Zealand’s organic and GE-free sectors
- whether it requires public participation and transparency
- whether it monitors post-approval effects
- whether its decisions protect export-market expectations relevant to New Zealand
A regulator should not be treated as recognised merely because it is located in a country with which New Zealand has a close trade relationship.
7. Exemptions must not weaken protection
Soil & Health is concerned about giving the Director-General wider ability to decide product registration exemptions. Some low-risk exemptions may be appropriate. However, exemption pathways must not become a way for higher-risk products to avoid proper assessment, public notification or scrutiny.
Soil & Health is also concerned about any drafting that could validate an exemption despite inadequate consultation. Consultation duties should be meaningful. Failure to consult affected parties should not be treated as a harmless technical issue where organic integrity, animal welfare, trade, residues, Māori interests, environmental health or public confidence may be affected.
Exemptions should not apply to products involving, derived from, or associated with:
- genetically engineered organisms or gene-edited organisms
- RNA-based or gene-silencing technologies
- engineered microorganisms
- novel microbial mixtures
- novel or engineered biological products
- nanotechnology or nano-enabled delivery systems
- veterinary medicines with significant residue, animal welfare, antimicrobial resistance or trade implications
- animal feed additives, methane inhibitors or other inhibitor substances with unresolved safety, residue or trade questions
- agrichemicals or crop protection products with potential soil, water, biodiversity or organic-certification impacts.
The burden should remain on applicants to demonstrate safety, effectiveness and suitability for New Zealand conditions.
8. Organic and GE-free production need explicit protection
Organic and GE-free producers are directly affected by ACVM decisions. A product may raise organic-sector concerns because of its active ingredient, manufacturing process, carrier, adjuvant, excipient, residue profile, genetic technology status, animal-treatment use, feed use, soil impact, environmental persistence or contamination pathway.
For organic and GE-free producers, inappropriate approval or weak traceability can cause:
- loss of certification
- loss of market access
- residue or contamination concerns
- loss of consumer trust
- export-market risk
- additional testing and segregation costs
- reputational damage through no fault of their own.
The Bill should explicitly recognise organic and GE-free production as affected interests in ACVM decision-making.
Decision-makers should be required to consider impacts on organic certification, market access, GE-free status, traceability, labelling, residues, coexistence, liability and compensation.
9. Veterinary medicines and animal welfare
Soil & Health does not oppose access to appropriate veterinary medicines. Organic production requires animals to be treated when treatment is needed. Animal welfare must never be compromised by ideology or by regulatory delay.
However, access to veterinary medicines must be balanced with careful assessment of public health, antimicrobial resistance, residues, trade implications, environmental effects, animal welfare outcomes and organic certification consequences.
The Bill should not allow faster pathways to weaken assessment of veterinary medicines, vaccines, animal treatments, feed additives, methane inhibitors, hormones, antimicrobials or other products used in or around animals.
Where products may affect animal welfare, food safety, residue status, antimicrobial resistance, export assurance or organic certification, they should receive full New Zealand-specific assessment and transparent conditions of use.
10. Inhibitor substances, fertilisers and animal feed additives require care
Soil & Health recognises that new products may be developed to reduce emissions, nutrient losses or other environmental impacts. Some may have genuine benefits.
However, products promoted as climate, productivity or environmental solutions can still create risks. These may include residues, soil biological impacts, animal health effects, food-chain effects, trade issues, contamination of organic systems or unintended ecological consequences.
Inhibitor substances, including methane inhibitors, nitrification inhibitors and urease inhibitors, along with coated fertilisers, feed additives and similar products, should not be fast-tracked or exempted unless their risks are fully assessed in New Zealand conditions.
The Committee should ensure that productivity or climate claims do not override precaution, animal welfare, soil health, food safety, trade integrity or organic certification.
11. Public participation and transparency must be retained
Public notification and consultation should not be treated as administrative barriers. The ACVM system affects food safety, animal welfare, trade, agricultural security, organic production, public trust and the environment. Affected communities and sectors should be able to see and respond to significant proposed changes.
Public notification should be required where an application, exemption, reassessment or approval may affect:
- organic or GE-free producers
- Māori interests
- animal welfare
- antimicrobial resistance
- food safety or residues
- export markets
- soil health, water quality or biodiversity
- novel or engineered biological products
- gene technologies or gene-derived inputs
- inhibitor substances
- significant public interest.
The public should not have to discover risks only after approval or exemption has already occurred.
12. Te Tiriti obligations must not be bypassed
Agricultural compounds and veterinary medicines can affect whenua, wai, mahinga kai, taonga species,
biodiversity, animal health, food systems and intergenerational relationships with the natural world. The Bill should not allow accelerated pathways, overseas assessments or exemptions to bypass meaningful engagement with iwi, hapū and Māori organisations.
Decision-making should give proper weight to mātauranga Māori, tikanga, whakapapa, kaitiakitanga and Te Tiriti obligations.
13. Monitoring, traceability and liability must be strengthened
If the Bill creates faster or more flexible pathways, it must also strengthen monitoring and accountability.
Approvals and exemptions should include:
- clear public registers of approvals, exemptions and recognised overseas regulators
- transparent conditions of use
- residue monitoring where relevant
- animal welfare monitoring where relevant
- antimicrobial resistance monitoring where relevant
- adverse event reporting
- post-approval review and reassessment triggers
- traceability requirements for novel, GE-derived or higher-risk products
- clear labelling where organic, GE-free or export-market integrity may be affected
- applicant-funded monitoring where products are approved through faster pathways
- liability for contamination, certification loss, residue problems, market loss or environmental harm
The costs of uncertainty should not be shifted to organic producers, neighbouring landowners, certifiers, councils, consumers or future generations.
14. Specific recommendations
Soil & Health recommends that the Primary Production Committee:
- Recommend that the Bill does not proceed in its current form.
- Require further consultation with the organic sector, Māori, certifiers, growers, farmers, veterinarians, exporters, environmental organisations and consumers.
- Require a full assessment of the combined effects of the ACVM Amendment Bill, HSNO Amendment Bill and Gene Technology Bill before progressing the Bill.
- Ensure overseas regulator assessments may inform, but not replace, independent New Zealand assessment.
- Define recognised overseas regulator clearly in primary legislation.
- Require all ACVM decisions to consider New Zealand-specific farming systems, environmental conditions, animal welfare, public health, trade, organic certification and GE-free production.
- Prevent exemption pathways from applying to higher-risk products, including gene technologies, engineered microorganisms, RNA-based products, nanotechnology, novel or engineered biological products, inhibitor substances, high-risk veterinary medicines and products with residue, animal welfare or trade implications.
- Ensure any consultation requirements for exemptions or other decisions are meaningful and not undermined by validating provisions that could excuse inadequate consultation.
- Retain meaningful public notification and consultation for applications, approvals, exemptions and reassessments that may affect organic producers, Māori interests, animal welfare, food safety, residues, trade, soil, water, biodiversity or significant public interest.
- Keep key safeguards in primary legislation rather than leaving them to later regulations, notices or discretionary decisions.
- Require traceability and labelling where products may affect organic integrity, GE-free status, residues or export-market assurance.
- Require applicant-funded monitoring and adverse-event reporting for products approved through faster or overseas-reliance pathways.
- Create clear liability for applicants and approval holders where contamination, certification loss, market loss, animal welfare harm, residue problems or environmental harm occurs.
- Ensure the Bill does not weaken Te Tiriti obligations, mātauranga Māori, tikanga, whakapapa or kaitiakitanga.
- Ensure productivity, speed and commercial access do not override animal welfare, public health, food safety, environmental protection, trade integrity, organic certification or GE-free production.
Conclusion
Soil & Health supports access to safe, effective and genuinely beneficial agricultural compounds and veterinary medicines. We do not oppose appropriate veterinary treatment, animal welfare tools, plant health products or organic-compatible biological inputs.
Our concern is with the direction of the Bill: faster access, greater overseas reliance, wider exemption powers and reduced regulatory friction without adequate consultation and without sufficient safeguards for organic integrity, GE-free production, Māori interests, animal welfare, public health, food safety, trade protection and environmental health.
The ACVM system must protect more than product access. It must protect trust. That trust matters to farmers, growers, veterinarians, organic producers, exporters, consumers and future generations.
Soil & Health therefore asks the Primary Production Committee to recommend that the Agricultural Compounds and Veterinary Medicines Amendment Bill does not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be substantially amended to retain independent New Zealand assessment, meaningful consultation, transparent decision-making, strong safeguards for organic and GE-free production, and clear accountability for applicants and approval holders.
Documents and sources considered
This final submission was prepared with reference to the following materials:
- Agricultural Compounds and Veterinary Medicines Amendment Bill submission page, New Zealand
Parliament - Primary Production Committee announcement on the ACVM Amendment Bill
- Agricultural Compounds and Veterinary Medicines Amendment Bill, New Zealand Legislation
- MPI, ACVM improvements to agricultural and horticultural product approvals
- MfE/MPI proactive release on HSNO and ACVM Amendment Bill policy decisions
- OANZ, Four Days to Protect Organic and GE-free farming, Submission Template
- OANZ, Three Bills, One Big Picture
- New Zealand Law Society submission on the ACVM Amendment Bill
- MPI, controlling and preventing antimicrobial resistance
