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The Gene Tech Bill Tightrope

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What New Zealand’s Proposed Genetic Engineering Rules Could Mean for Organics 

By Charles Hyland, chair of the Soil & Health Association of New Zealand 

When the Government released the Gene Technology Bill in late 2024, it advanced a proposal that could reshape how Aotearoa New Zealand manages genetic technologies for many years to come. We have a short and critical window of opportunity to influence this for the benefit of the organic community, the New Zealand public and the environment.  

For decades, the organic movement has maintained an unambiguous position on genetic engineering: it has no place in organic systems. This position is not solely about the safety or otherwise of specific technologies. It is about protecting ecological integrity, sustaining consumer trust in food systems, and safeguarding the right of communities, growers, and consumers to choose farming systems that remain free from genetic contamination.

The Gene Technology Bill represents the most significant attempt to rewrite Aotearoa’s genetic rules since the Hazardous Substances and New Organisms Act 1996 was passed nearly thirty years ago. It therefore represents a critical juncture in the country’s relationship with biotechnology, food, agriculture, and the environment. 

A legislative reset 

The original version of the bill, introduced in late 2024, was designed to remove gene technology regulation from the Hazardous Substances and New Organisms (HSNO) framework and place it into a dedicated new system. This new framework would create a single Gene Technology Regulator supported by advisory committees and a risk-tiered approval system. Government ministers and officials presented the change as a necessary modernisation. They argued that HSNO was an outdated and overly cumbersome regime that treated all genetic technologies in a single, inflexible way. Some researchers and industry groups had long complained that HSNO imposed slow and costly approval processes, making it difficult to work with techniques such as CRISPR and other forms of gene editing. The stated goal of the reform was to reduce regulatory lag, streamline decision-making, and encourage domestic research and innovation. 

To the organic community, however, this proposal triggered deep concern. The original draft of the bill allowed entire categories of genetic techniques to be declared “not regulated,” which would have created the possibility of genetically engineered organisms entering our food, farming systems and outdoor environment without any public notification, without labelling, and without clear liability mechanisms if contamination occurred. To Soil & Health, the promise of streamlining looked less like efficiency and more like a structural blind spot. 

One of the most consequential elements of the original proposal is the potential redefinition of what legally counts as a “GMO” in New Zealand. By excluding certain forms of gene editing from the GMO umbrella altogether, these technologies could be treated as though they are no different from conventional breeding. This shift would not just simplify regulation; it would fundamentally alter the scope of what falls under genetic oversight, enabling some gene-edited organisms to bypass the regulatory system entirely. For the organic sector, this raises profound concerns about transparency, traceability, and market trust. 

What changed in the Health Committee’s version 

The Health Select Committee, which considered the draft Bill, received a large volume of submissions from environmental organisations, Māori representatives, organic producers, consumer groups, scientists, legal experts, the biotech industry, and concerned members of the public. Its revised text introduces several significant changes intended to address some of the concerns raised. 

One of the most important shifts is that the committee recommends restricting exemptions to specific organisms, not to entire classes of genetic techniques. Exemptions can now only be applied on an organism-by-organism basis, and only if those organisms cannot be distinguished from conventional breeding outcomes. Under the committee’s recommendations, this determination would be made by the Gene Technology Regulator, with advice from the Technical Advisory Committee and the Māori Advisory Committee. Applicants can claim indistinguishability, but the regulator must assess and verify those claims before an exemption is granted. While this represents a shift away from industry self-declaration back to the current case-by-case regulatory decision, concerns remain about how rigorously such claims will be tested in practice and who will bear the cost of verification. 

Another change is the introduction of a public schedule (a register) known as Schedule 3A. This schedule would list organisms that are not regulated GMOs and technologies that are not considered ‘gene technologies’ under the new framework. Exemptions and registration requirements sit alongside, but are separate from, this schedule. These organisms may still be genetically modified or gene edited, or the products thereof, but if they are deemed indistinguishable from conventional breeding, they will not go through the full regulatory process. While inclusion in the schedule does not trigger full oversight, it at least ensures that their status is on the public record, addressing some of the concerns from organic and environmental advocates about a lack of transparency around gene editing decisions. 

The revised bill also attempts to bolster trust by clarifying the scope of ministerial powers and embedding a broader advisory system. While the Regulator would still be accountable to the Minister, the committee’s recommendations clarify and limit how ministerial directions can be issued, including ensuring these powers cannot be delegated. The Regulator would also be required to produce annual reports on its activities.

The advisory structure has been expanded to include environmental scientists, mātauranga Māori experts, and public interest voices, aiming to reduce the risk of decisions being made within a narrow technical circle. However, several submitters have questioned why a new regulatory office is needed at all, suggesting that strengthening the existing Environmental Protection Authority (EPA) might achieve similar outcomes with fewer concerns about accountability and duplication. 

The parliamentary process: not law yet 

The Gene Technology Bill remains at the parliamentary stage. There was not wide consultation during drafting of the Bill, and no economic impact information sought. After a first reading in December 2024, the Bill was referred to the Health Select Committee, which gave a short public submission period of only two months over the summer holiday period. The Committee received about 14,500 written submissions and approximately 1,500 requests to present oral submissions. Of those, only around 400 were granted, with presenters given just 5–10 minutes each. The Committee produced its revised draft, released on 10 October 2025. The revised Bill will return to the House for its second reading. If the bill is supported at that stage, it will go through the Committee of the Whole House, where MPs debate it line by line and propose further amendments. If it passes a third reading, it will receive Royal assent and become law. 

This timeline is important because it means the content of the legislation is not yet fixed. The coming months will determine whether additional protections for the organic sector, primary producers more generally, Māori communities, and consumers are introduced, whether the bill is enacted largely in its current form, or whether it stalls for lack of sufficient support.  

Regulation and public trust 

New Zealand’s current HSNO regime is intentionally conservative, and many consumers see that conservatism as part of the country’s clean and trusted agricultural identity. Trust is not automatically guaranteed by legislation. It is built when the public can see what decisions are made, understand the reasoning behind them, and believe that independent oversight is in place. 

The revised bill attempts to build trust through structural mechanisms, including increased transparency and clear reporting requirements for the Regulator. Yet public trust is fragile. It takes years to build and can be lost in a single regulatory failure.

A single example could be a gene-edited crop or grass variety spreading beyond its intended trial site, contaminating nearby organic farms and compromising their certification, income, market access, and reputation, an outcome that has occurred overseas when containment measures have failed. Organic producers, Māori communities, and environmentally minded consumers are wary not because they misunderstand gene technologies, but because they have seen how weak oversight has led to adverse irreversible consequences elsewhere. 

Consultation versus shared power 

The Health Committee has strengthened expectations for consultation at various stages of the regulatory process, and it requires a post-implementation review. These steps reflect recognition that gene technology decisions require more than narrow technical consideration. They have cultural, social, and economic implications. 

However, advisory input is not the same thing as actual decision-making power. Māori submitters made clear that gene technology touches whakapapa, mauri, and tino rangatiratanga, and therefore raises issues of sovereignty and responsibility toward taonga species. For many Māori, being consulted after the fact is not sufficient. They are asking for meaningful influence over decisions, not just an advisory seat on the sidelines. 

The organic sector’s concerns have some differences from those of Māori in content but are similar in how they play out. For Māori, gene technology interferes with core cultural values, and the bill does not comply with te Tiriti o Waitangi, which guarantees governance over taiao – the environment. For the organic sector, it is about protecting GMO-free production systems, certification, and market access. In both cases, meaningful safeguards rather than consultation alone are essential. If the regulatory system listens but fails to act, both groups risk having their concerns effectively ignored. 

Monitoring and enforcement: from paper to practice 

The revised bill grants the Regulator broader powers to monitor and enforce compliance. Inspectors would be able to visit both current and former sites of regulated activity. Public registers would provide visibility into what is being approved and where. Licenses could be varied urgently if new risks emerged. Penalties for violations have been streamlined and clarified. 

In practice, its value depends on whether the Regulator is adequately resourced to use these powers effectively. A well-designed legal framework cannot protect the environment or organic farmers if it is not backed by funding, staffing, and operational capacity. Many organic producers have seen this dynamic play out in other regulatory domains, where strong rules are undermined by weak enforcement. 

National control versus local autonomy 

Another contentious element of the bill involves local government. The Government has signalled an intention to move toward a nationally consistent framework, which may limit the ability of local councils to impose their own restrictions on gene technology activities at the behest of their communities. The Government has presented this as a matter of consistency and efficiency. Industry groups argue that a single national standard will reduce duplication and confusion. 

For communities, however, this represents the removal of an important tool. Several regions have precautionary and/or prohibitive plans and policies. Under the new framework, these preferences would carry little or no legal weight. This is not merely a procedural question. It touches on democratic control, regional autonomy, and the ability of communities to shape the future of their land. 

For the organic movement, both globally and in Aotearoa, this is especially significant. Around the world, local or regional authorities have often acted as protective backstops when national governments have moved toward more permissive gene technology regulation. New Zealand has followed this pattern, with councils such as Hawke’s Bay, Auckland, and councils into Northland declaring GE-free, precautionary or prohibitive positions. Centralisation would mean that if the national regulator approves the release of a genetically engineered crop, animal, insect, or microbe, local communities would have limited ability to maintain GE-free landscapes. 

International alignment and trade realities 

The bill brings New Zealand procedurally closer to international frameworks by establishing information-sharing arrangements with overseas regulators and aligning regulatory processes with international practices. The alignment is largely administrative and trade-oriented, aimed at avoiding regulatory isolation and supporting the Government’s broader strategy to position New Zealand as “science-friendly” and “innovation-ready.” 

But trade alignment is a double-edged sword. New Zealand’s competitive advantage in many export markets depends on its reputation for clean, non-GMO production. European markets, in particular, remain sensitive to genetic engineering. Many buyers in Asia also favour products that are certified organic and/or verified as non-GMO. If the new framework enables genetically engineered products to enter the food system quickly and without mandatory labelling, that premium reputation could erode. This would not only be an environmental concern but also a commercial one, and potentially a concern for health. 

Labelling: the silent gap 

One of the most striking aspects of the Gene Technology Bill is what it does not address. It is a regulatory framework for approvals, not a consumer labelling law. The bill creates no requirement for mandatory labelling of gene-edited or genetically modified products. Definitions and labelling of food is determined by the trans-Tasman body Food Standards Australia New Zealand (FSANZ). This body has now exempted some new gene editing techniques from GMO labelling requirements. As a result, products using these technologies could enter the food chain without consumers’ knowledge. 

For organic – and indeed all – consumers, this represents an erosion of informed choice. For any producers who want to remain GE-free, it creates an uneven playing field in which they must continue to bear the cost of proving their products are non-GMO, while those using gene technology face no corresponding requirement to disclose. It also has implications for New Zealand’s export reputation. If overseas buyers cannot reliably distinguish between GE and non-GE products, they may simply choose to source from other countries with stricter standards. 

Contamination and liability 

Another unresolved issue is liability for contamination. If gene-edited pollen or seed drifts into an organic field, the question of who pays for the resulting damage remains unanswered. The Gene Technology Bill contains no liability framework for such events. The only liability provisions relate to protecting the Regulator from legal claims when acting in good faith.

There are no mechanisms assigning responsibility or financial liability to developers, users, or other parties in cases where genetically engineered material contaminates non-GMO or organic crops or ecosystems. This is a major gap compared with more precautionary regimes overseas. Contamination incidents in other countries have been common and costly, with organic farmers losing certification, income, market access, and consumer trust through no fault of their own.

Without a fair liability system, the risk is likely to fall on organic and GE-free farmers themselves, creating a moral hazard where those who use gene technology externalise the costs onto those who do not. For the organic sector, this is not a marginal issue but a central question of survival. 

A well-documented example of such a failure occurred in the United States, where genetically engineered creeping bentgrass escaped containment during field trials and spread across irrigation canals and wildlands, triggering years of expensive and incomplete eradication efforts. Similar issues arose with GM canola in Canada, where widespread contamination effectively eliminated the possibility of growing organic canola in many regions. These incidents illustrate how quickly contamination can spread beyond its intended boundaries, leaving farmers and communities to deal with long-term consequences and costs they did not create. 

Te Tiriti o Waitangi and governance 

The revised bill makes more explicit reference to Te Tiriti o Waitangi by embedding consultation requirements and the inclusion of mātauranga Māori in advisory processes. However, the Māori Advisory Committee remains advisory only, and its role does not carry decision-making authority. This procedural strengthening falls short of genuine co-governance, which is why many Māori submitters have expressed concern.

Gene technology intersects with whakapapa and mauri in profound ways, so decisions in this area are not purely technical. They touch on cultural identity, spiritual responsibility, and sovereignty. For the bill to gain legitimacy with Māori communities, it must demonstrate that these concerns influence real outcomes, not just process. Otherwise, mistrust is likely to deepen. 

Speed and precaution 

The Government has presented speed as one of the central goals of the new regulatory framework. Faster approvals are seen as a way to boost innovation and make New Zealand more competitive internationally. But speed in genetic regulation is not necessarily a good thing. Genetic material cannot be recalled once released into the environment. Drift and escape are well-documented phenomena and, unlike chemical pollutants, genetic material can replicate and spread. 

A faster system without strong monitoring, labelling, and liability provisions creates obvious risks for non-GMO and organic producers, for home gardeners, and for natural ecosystems. It also creates significant risks for conventional farms, which may face unintentional contamination, disrupted market access, and loss of buyer confidence if their products can no longer be reliably distinguished from gene-edited varieties. 

Lessons from abroad 

The experience of other countries provides sobering lessons. In Canada, the widespread planting of herbicide-tolerant GE canola in the late 1990s led to rapid contamination of non-GMO and organic canola fields. Within a few years, growing organic canola became practically impossible in large regions of the Canadian Prairies. In the United States, similar contamination occurred with alfalfa (lucerne). Even strict buffer zones and best-practice guidelines proved insufficient. In contrast, the European Union’s precautionary approach has preserved a clearer market separation and sustained consumer trust. 

A permissive, fast-moving system carries both environmental and economic risks. A precautionary system may be slower, but it preserves options for farmers and consumers who want to remain GE-free. 

Unresolved questions 

Many critical issues remain unresolved in the Bill, and some issues would only be considered later, during the drafting of regulation that sits under the Bill. Among these are the practical mechanisms for ensuring transparency, the nature of liability protections for organic and GE-free producers, the absence of a clear labelling regime, the scope of local authority powers, the resourcing of the Regulator, and the role of Māori in actual decision-making rather than purely advisory capacities. These are not minor details to be filled in later. They will determine whether the system is trusted and workable. 

A moment of choice 

The Health Committee’s revisions are improvements on the original bill. They increase transparency, tighten exemption criteria, and enhance the independence of the Regulator. But they do not change the overall orientation of the policy, which is designed to facilitate and manage the use of gene technology in New Zealand, rather than putting the health and safety of people and the environment first. Whether that future supports or undermines organics will depend on how these remaining gaps are addressed. One of the most critical of these gaps is the complete absence of a liability framework, leaving farmers and communities exposed to the costs and consequences of contamination events they did not cause. 

For organic producers and consumers, this is a moment of decision. New Zealand’s organic exports command a premium price in part because of the country’s reputation as GMO-cautious and environmentally responsible. That reputation can be eroded far more quickly than it can be rebuilt. The coming months will determine whether the organic and wider GE-free movement can help shape a regulatory framework that protects its interests, or whether it will be forced to adapt to a more permissive environment. 

Looking ahead 

The parliamentary stages that lie ahead provide opportunities for change. Amendments can still be introduced to address the labelling gap, clarify liability rules, secure adequate resourcing for enforcement, and ensure meaningful co-governance with Māori. These issues are not optional extras. They are the core conditions that will shape public trust and determine how different sectors experience the new regime, if indeed it is introduced. 

New Zealand now faces a strategic choice. One path leads toward a regulatory framework that balances innovation with precaution, transparency, and respect for community values. The other path risks weakening trust, undermining organic markets, and eroding local control. For organic growers, consumers, and communities, this is a time to pay close attention, engage constructively, and insist on a system that protects ecological integrity and informed choice. 

The tightrope has been strung high. How we walk it will shape the future of farming, food systems, and public trust for decades to come. 

FURTHER INFORMATION:

TOP IMAGE: iStock/heebyj

Gene Tech Bill threatens Aotearoa’s GE-free status, warns Soil & Health

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MEDIA RELEASE

13 OCTOBER 2025

Aotearoa New Zealand – The Soil & Health Association of New Zealand is calling for the Government to halt the Gene Technology Bill, warning that the proposed law would open the door to genetically engineered organisms in Aotearoa’s environment, food system and farms.

The latest draft of the Bill, which has just been released by the Health Select Committee, has only minor changes from the initial draft.

“New Zealanders have a right to know what we’re growing and eating – and to choose food that aligns with their values,” says Charles Hyland, chair of the Soil & Health Association.

“This Bill would still allow GE into our farms, gardens and food, risking contamination, loss of organic certification, lawsuits and Aotearoa’s GE-free status. Anyone who doesn’t want GE could face difficulties avoiding it.”

“In addition to the risks to food and agriculture, there are also risks to tikanga Māori, Te Tiriti o Waitangi, biodiversity, conservation and natural ecosystems, economics, trade, liability and insurance, animal welfare, ethics and more.”

“Local authorities would have no jurisdiction over GE in their territories.”

“One positive change we have identified is the inclusion of a register of all genetically modified organisms.”

“We’re urging Parliament to pause this Bill and take the time needed to address the wide-ranging environmental, cultural and economic risks,” says Hyland. “This legislation is too important to rush – it must be shaped with meaningful public consultation.”

ENDS

FURTHER INFORMATION: Soil & Health’s submission on the Gene Technology Bill

Media contacts:

Charles Hyland, Chair, Soil & Health Association of New Zealand, 027 707 0747

Philippa Jamieson, Organic NZ editor, Soil & Health Association of New Zealand, 027 547 3929

Email: editor@organicnz.org.nz
Website: www.soilandhealth.org.nz

TOP IMAGE: Organic apples at Commonsense Organics, Wellington

Soil & Health welcomes end to GE animal trials after 25 years of suffering

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MEDIA RELEASE

6 OCTOBER 2025

Aotearoa New Zealand – The Soil & Health Association of New Zealand welcomes the end of animal genetic engineering trials that have taken place at AgResearch’s Ruakura facility for more than two decades.

“These experiments caused immense animal suffering and should never have been allowed to happen,” said Charles Hyland, chair of Soil & Health.

The Association applauds GE Free NZ for exposing the scale of the harm. Their report, based on AgResearch’s own annual statements, documents spontaneous abortions, cancers, deformities and other adverse effects on cattle, sheep and goats.

“After 25 years and tens of thousands of dollars of public money, these experiments have delivered no benefits,” Hyland said. “We are deeply concerned they could resume if the proposed Gene Technology Bill is passed. Animals must not be subjected to such cruelty again.”

“New Zealanders – and our overseas markets – expect high animal welfare standards and food that is healthy, ethical and safe. The future lies in organic and sustainable food and farming.” 

ENDS

FURTHER INFORMATION: Genetically Engineered Animals in New Zealand 2010 – 2025: Part 2 – The second fifteen years (GE Free NZ)

Media contacts:

Charles Hyland, Chair, Soil & Health Association of New Zealand, 027 707 0747
Philippa Jamieson, Organic NZ editor, Soil & Health Association of New Zealand, 027 547 3929 

Email: editor@organicnz.org.nz
Website: www.soilandhealth.org.nz

TOP IMAGE: Genetically engineered cows at AgResearch’s Ruakura facility in 2011 (Photo: Steffan Browning)

Soil & Health submission on GE purple tomatoes in food

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10 September 2025

To Food Standards Australia New Zealand

Submission to Food Standards Australia New Zealand

A1333 – Food derived from purple tomato lines containing event Del/Ros1-N 

Preamble

The Soil & Health Association of New Zealand is an incorporated society founded in 1941. Its primary purpose is to promote and advocate the production and consumption of organic food. Our motto is ‘Healthy soil – healthy food – healthy people: Oranga nuku – oranga kai – oranga tāngata’. 

We represent approximately 17,000 members and supporters around Aotearoa New Zealand, including consumers, home gardeners, farmers, horticulturists, business people, chefs and more. 

Our members and supporters are health conscious and highly concerned about their food: how it’s produced, what’s in it, and what effects it has. They want food that is natural and unadulterated, free from harmful chemicals and toxins, and produced in ways that enhance our soils, environments, health and communities. 

We represent people who have many reasons for wanting to avoid GE food – such as health, environmental, ethical, cultural, philosophical, climate change and more.  

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

Submission

  1. Soil & Health categorically opposes the application for the Purple Tomato for the following reasons.  

No justification

  1. Norfolk Healthy Produce’s justification for their application is that the genetically engineered Purple Tomato contains high levels of anthocyanins, which are beneficial compounds.  
  2. However, simply containing high levels of anthocyanins is no justification for allowing this genetically engineered tomato into the food supply of New Zealand and Australia.  
  3. This application is for an unnecessary food and is primarily for the purpose of patenting.  
  4. There are already numerous plant foods that contain anthocyanins, such as blueberries, blackcurrants, blackberries, elderberries, cherries, purple grapes, eggplants, purple cabbage, purple cauliflower, purple carrots, blue corn, red onions, oranges, raspberries, red wine, pink grapefruit, red radishes, purple asparagus, black beans, red broad beans, and many more.  
  5. There are already several heirloom varieties of tomato with blue and purple hues that contain anthocyanins.  
  6. The applicant’s claim (as part of its justification for the application) that the Purple Tomato is visually striking and ‘delights consumers’ is subjective and a flimsy justification for the application.  

Human health effects are unknown 

  1. A pilot study on mice was conducted in 2008 and showed and found some benefits of consuming the Purple Tomato in terms of longer life span (Butelli et al, 2008 – referred to in the application).  
  2. However this was a limited, small-scale study on just 20 mice, and further tests of a more extensive scope are required to provide evidence of beneficial and/or adverse health effects.  
  3. The health effects (positive and negative) of humans consuming these tomatoes are unknown. To our knowledge there have been no trials involving humans.  
  4. As the UK’s National Health Service said: ‘until the tomato is tested in humans we cannot be sure that it will offer the same benefits, or that there will not be any unexpected harms’.  

Potential adverse health effects 

  1. Soil & Health notes that while anthocyanins are generally beneficial for health, they are not essential nutrients. 
  2. When anthocyanins are taken in pill form, safe levels may be exceeded, and they may have adverse health effects including the potential to limit iron absorption.  
  3. The levels of anthocyanins in the Purple Tomato are much higher than occur in other foods and in supplement form, but there is limited research on the overconsumption of anthocyanins except when taken as supplements.  
  4. Before approving the introduction of the Purple Tomato to our diet, independent research must first be undertaken into the health effects of consuming it, to investigate any potential adverse effects.  
  5. We don’t know the safe upper limits of anthocyanin consumption. A Harvard University mini review states there is a ‘need for increased regulation and guidelines for polyphenol consumption and supplementation in order to ensure consumers remain safe and informed about polyphenols.’ (Anthocyanins are polyphenols.) 
  6. One of the risks of genetically engineering foods is that allergens, toxins and novel proteins can be created.  
  7. The applicant says the Purple Tomato does not contain anything matching or similar to any known allergens or toxins. However this does not rule out containing allergens or toxins yet unknown.  
  8. Absence of evidence is not evidence of absence. If you’re not looking for something, you won’t find it.  

Safety and equivalence

  1. The claim that foods produced using GE are equivalent to their non-GE counterparts cannot be made with any certainty – in fact significant differences have been discovered. 
  2. Existing non-GE tomatoes have a history of safe use over hundreds and thousands of years. The Purple Tomato does not have a history of safe use. 
  3. There is no long-term independent research on the Purple Tomato. 
  4. The Purple Tomato contains genetic material from not only the purple snapdragon but also bacterial and viral material.  
  5. We are increasingly discovering unexpected (‘off-target’) changes resulting from genetic engineering. For example, gene-edited cattle were found to have unintended alterations to the DNA, with bacterial DNA conferring antibiotic resistance, despite the developer having claimed the cattle contained no additional genetic material.  
  6. If these tomatoes were released into the food supply, any adverse effects on humans would be unable to be measured or monitored.  
  7. Therefore FSANZ must apply the precautionary principle and reject this application, to fulfill its regulatory function of upholding and safeguarding public health. 

Māori concerns, and Te Tiriti o Waitangi 

  1. Many Māori – including Māori members and supporters of Soil & Health – strongly object to any form of genetic engineering, as it disturbs whakapapa (kinship with the natural world), mana (dignity), mauri (life force or essence), wairua (spirit) and tino rangatiratanga (sovereignty). 
  2. In Aotearoa New Zealand there is at least one claim before the Waitangi Tribunal that involves genetic engineering – Claim WAI262. 
  3. Until or unless this is settled to the satisfaction of Māori, no genetically engineered organisms or foods should be approved in Aotearoa New Zealand. 

Consumer rejection 

  1. The applicant’s claim that consumers would seek out this novel food is speculative and no evidence is given to back it up.  
  2. Many surveys in many countries have shown consumers to be wary about, if not opposed to, consuming genetically engineered foods.  
  3. Soil & Health members and supporters have been giving us feedback that they would be horrified to see the Purple Tomato on sale in Aotearoa New Zealand, and would actively seek to avoid buying or consuming it.  
  4. While it may not be too difficult for consumers to avoid buying the Purple Tomato as fresh produce, it may be harder to avoid it if it’s included as an ingredient.  
  5. New Zealand’s GE labelling laws are already inadequate for consumers to make informed choices about avoiding GE food ingredients.  
  6. For example, GE ingredients do not have to be labelled in restaurants and other food service outlets, so if the Purple Tomato is served fresh or as an ingredient in a processed product or meal it would not need to be labelled, making it harder for consumers to try to avoid.   

Trade impacts

  1. The application says there would be no trade impacts to Australia, with no mention of New Zealand.  
  2. While we are aware application A1333 is about food derived from the Purple Tomato, clearly those tomatoes have to be grown somewhere, and we note that an application has been filed with the Office of the Gene Technology Regulator to grow the Purple Tomato in Australia.  
  3. The only country New Zealand currently imports fresh tomatoes from is Australia. Based on the many consumer surveys over the years, we anticipate low consumer demand in New Zealand for any Australian-grown Purple Tomatoes.  
  4. New Zealand exports about 902 tonnes of tomatoes annually (2023 figures), mainly to Asia, the Pacific and Pacific Rim countries.  
  5. If in future they are grown in Aotearoa New Zealand for export that could negatively affect our clean green export brand and image in international markets. 

Summary

  1. In summary, Soil & Health strongly rejects the application. 
  2. Accepting this application would mean exposing the public of New Zealand and Australia to potential risks that would not be able to be measured and monitored.  
  3. We support FSANZ to take a precautionary approach to the Purple Tomato and indeed all GE foods, in order to uphold public health and safety. 
  4. We urge FSANZ to reject this application as there is insufficient evidence of the safety of the Purple Tomato.
Woman browsing in supermarket aisle

Unlabelled GE food leaves consumers in the dark

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MEDIA RELEASE

3 AUGUST 2025

Aotearoa New Zealand – Consumers have just lost a fundamental right to informed choice about the food they’re eating, says the Soil & Health Association.

New Zealand Food Safety Minister Andrew Hoggard and his eight Australian state counterparts have approved a decision to allow genetically engineered food ingredients enter unlabelled into the food chain of both countries.

“This is an alarming and unscientific move that removes our right to know what’s in our food,” says Charles Hyland, chair of the Soil & Health Association.

“New Zealanders want to know what they’re eating, and be able to avoid things they don’t want.”

“Allowing unlabelled GE ingredients that have no novel DNA ignores the fact that changes can and do occur as a result of all types of genetic engineering – whether it introduces novel DNA or not.”

Gene edited cattle in the USA were heralded as a success and claimed to have no novel DNA. However it was then found that bacterial DNA had been introduced, conferring antibiotic resistance, and the cattle were withdrawn from the market.

Similar situations could happen with food that supposedly has no novel DNA.

Our knowledge of the risks to health from GE foods is still very limited, and there is very little long-term independent research to draw from.

“What happens if there is a health issue from GE food? How could we pinpoint it to that GE food? If it’s unlabelled, authorities won’t be able to trace it or issue a food recall.”

The onus will now be on consumers to ask retailers and food companies whether there are any GE ingredients in their food.

“The best ways to avoid GE food ingredients are to eat organic food, grow your own, favour whole foods and avoid ultra-processed foods.”

ENDS

FURTHER INFORMATION: Soil & Health’s submission to Food Standards Australia New Zealand, 10 September 2024


Contact:

Charles Hyland, Chair, Soil & Health Association of New Zealand, 027 707 0747
Philippa Jamieson, Organic NZ editor, Soil & Health Association of New Zealand, 027 547 3929 

Email: editor@organicnz.org.nz
Website: www.soilandhealth.org.nz

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 ↩︎
Soil & Health Association of New Zealand round logo

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/

Changing the definition of GE in food would leave consumers in the dark

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Soil & Health Association stands firm against redefinition of gene technology in food standards

MEDIA RELEASE

For immediate release 6 September 2024

Aotearoa New Zealand – The Soil & Health Association of New Zealand has officially submitted its comprehensive response to Food Standards Australia New Zealand (FSANZ), rejecting Proposal P1055, which seeks to change the definition of genetic engineering technologies used in food production. The association also urges FSANZ to extend the consultation period by at least a month to allow for sufficient time to make submissions.

Charles Hyland, soil scientist and co-chair of the Soil & Health Association, says: “Redefining gene technology to exclude new breeding techniques (like gene editing) without proper labels and safety checks threatens our ability to choose what we eat. We stand for transparency and informed choices in food consumption, not ambiguity.”

Echoing this sentiment, Jenny Lux, organic producer and co-chair of Soil & Health, highlighted the potential impacts on the organic sector. “Introducing gene-edited products into our food system without clear labels could inadvertently lead organic foods to contain genetically engineered ingredients. This is unacceptable and undermines the trust consumers place in organic labels.”

“People are concerned not just about what’s in their food, but also about how it’s been produced. The  global market for non-GMO foods is growing.”

Philippa Jamieson, Soil & Health spokesperson on GE issues, emphasised the need for rigorous safety assessments. “Gene editing and NBTs bring significant risks and uncertainties. Any food product derived from these technologies must undergo stringent safety evaluations and be clearly labelled to ensure public health is not compromised.”

The Association also acknowledges the deep cultural, ethical, intellectual property and spiritual concerns associated with gene technology expressed by Te Ao Māori. Soil & Health aligns with the perspectives of our Treaty partner organisation, Te Waka Kai Ora, that the proposal does not support their cultural expressions and rights as guaranteed under Te Tiriti o Waitangi.

The public is urged to participate actively in the consultation process by making individual submissions to FSANZ. The deadline for these submissions is the 10th of September 2024, at 8 PM New Zealand time. Submissions can be made via email or through the FSANZ consultation hub. The association encourages individuals to also communicate their concerns directly to MPs and through media channels to amplify their voice.

For further guidance on making submissions, or to read the full Soil & Health Association submission, please visit the Soil & Health Association website.

Contact:
Rebecka Keeling, Communications Specialist, Soil & Health Association of New Zealand  

Email: editor@organicnz.org.nz

Phone: 021 202 7664  
Website: www.soilandhealth.org.nz

Philippa Jamieson, Editor Organic NZ

Organic regenerative farming needed, not GE

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Our genetic engineering regulations are robust, protective, and must not be loosened, says the Soil & Health Association of New Zealand. 

“We need significant investment in organic, regenerative agriculture, rather than risky genetic technologies in the outdoor environment,” says Soil & Health spokesperson Philippa Jamieson. 

Genetic engineering techno-fixes – such as GE ryegrass – are not the solution to reducing greenhouse gas emissions in agriculture. 

“It’s already been demonstrated that diverse, mixed species pastures reduce ruminant methane emissions, and are more resilient in the face of climate extremes,” says Philippa Jamieson. “Organic regenerative farming methods are free for all farmers to adopt, and they’re not under any patents.”

“By being GE-free, we’re far from ‘missing out’. Being GE-free gives us a point of difference in the world market.”

“Who is this GE product for? If customers and consumers are told the product is GE, none want it. Not even the rats in the warehouse. It adds no commercial brand value to growers or distributors. GE inclusion is hidden or secret for products to be sellable,” says David McNeill, Soil & Health National Council member. 

“We already have an advantage in being an island nation in the South Pacific, and need to be really careful about any uncontrolled releases of GMOs into the outdoors. Our products are attractive to overseas buyers because they’re seen as clean, safe, natural and uncontaminated. Once we release GMOs there’s no containing them. We need to continue to safeguard our environment and our brand,” says Philippa Jamieson.  
 
“Organic regenerative farming and growing practices result in lower greenhouse gas emissions, cleaner waterways, reduced soil erosion, increased biodiversity and more resilient ecosystems.”

Soil & Health urges all political parties not to loosen regulations on GE in Aotearoa New Zealand, and instead to direct energy and funding towards expanding organic farming methods here. 

Organic regenerative farming sequesters more carbon in the soil, and uses fewer costly inputs, empowering farmers. We need research centres dedicated to organic, regenerative agriculture and farmer extension programmes to build that knowledge in rural communities.

Genetic Engineering Webinar: What do Consumers Want? Navigating GE Issues with Jon Carapiet

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On 5th March 2024, the Soil & Health Association of NZ held an online webinar with Jon Carapiet, to discuss consumer issues around GE. This included the right to choose, labelling, traceability, and consumers overseas – our export markets. Scroll down to read more about the webinar and to access the full recording. If you benefited from this webinar, please consider donating to Soil & Health to support our vital work, details below.

Jon is a consumer advocate, market researcher and national spokesperson for GE Free NZ (in food and environment). For almost 20 years, Jon has spoken out about the need to moderate the powerful use of gene technology to protect New Zealand’s capacity to produce and sell non-GMO food and to protect the rights of consumers at home and overseas. As an advocate for Brand New Zealand, Jon draws on his years of experience as a senior market researcher and brand communications consultant. Jon has a Bachelor’s degree from Cambridge University and a Master’s from Auckland University, and as well as working in research, he is a keen photographer, regularly exhibiting his artwork.

Access the webinar here

The webinar can be viewed here: Jon Carapiet – 5th March 2024.

A copy of Jon’s PowerPoint presentation can be viewed here.

If you would like to view the other webinars in our GE series, please go to the GE Free Campaign page of our website.

Donate to support the vital work of Soil & Health

All webinars and events are free for all members of Soil and Health; otherwise we suggest a donation of $20. All funds go towards Soil & Health’s advocacy and campaign for a GE-free New Zealand, and are eligible for tax credits.

Make your donation by credit card: soilandhealth.org.nz/donate

Or transfer funds to our account: BNZ, account number: 02 0108 0058415 001
With the reference: GE donation