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Soil & Health submission on the proposal to increase glyphosate maximum residue levels

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16 May 2025

To New Zealand Food Safety

Submission to New Zealand Food Safety on Proposed Amendments to Glyphosate Maximum Residue Levels (MRLs)

Introduction

The Soil & Health Association of New Zealand unequivocally opposes the proposed amendments to the Food Notice: Maximum Residue Levels for Agricultural Compounds, which would significantly raise allowable glyphosate residues in staple crops. Specifically, the proposed increases from the current default MRL of 0.1 mg/kg to:

  • 10 mg/kg in wheat, barley, and oat grain
  • 6 mg/kg in dried field peas

These changes contradict the principles of precautionary public health protection, environmental stewardship, and sustainable agriculture that underpin New Zealand’s food system. They also pose substantial risks to our international trade relationships and the integrity of our agricultural exports.

Public Health Concerns

Glyphosate has been classified by the International Agency for Research on Cancer (IARC) as “probably carcinogenic to humans” (Group 2A). This classification is based on evidence linking glyphosate exposure to non-Hodgkin lymphoma and other cancers. While some regulatory bodies have disputed this classification, the IARC’s assessment is grounded in peer-reviewed studies and reflects a precautionary approach to public health.

Increasing the allowable MRLs for glyphosate could lead to higher dietary exposure among consumers, including vulnerable populations such as children and pregnant women. The long-term health effects of chronic low-level exposure to glyphosate are not fully understood, and raising MRLs without comprehensive risk assessments undermines public confidence in food safety.

Recent biomonitoring studies have found glyphosate residues in human urine in multiple countries, indicating widespread population exposure. A 2022 CDC report in the United States found detectable levels of glyphosate in 80% of urine samples tested, including from children. While these findings do not directly demonstrate harm, they highlight the need for stricter—not more lenient—residue controls to protect population health.

Emerging research also raises concerns about glyphosate’s potential endocrine-disrupting effects and its role in gut microbiome disruption, which are not accounted for in current MRL risk models.

Environmental and Soil Health Impacts

Glyphosate’s widespread use has been associated with adverse effects on soil health and biodiversity. Studies have shown that glyphosate can disrupt soil microbial communities, reduce earthworm populations, and negatively impact soil fertility. These effects compromise the resilience of agricultural ecosystems and can lead to increased reliance on chemical inputs.

A 2021 meta-analysis published in Science of the Total Environment found that glyphosate significantly alters soil microbial diversity, reducing populations of beneficial fungi and bacteria essential for nutrient cycling and plant resilience. This undermines long-term soil fertility and increases the need for synthetic inputs—counterproductive to climate and sustainability goals.

Furthermore, glyphosate’s degradation product, AMPA, is more persistent in the environment and has been shown to accumulate in both aquatic and terrestrial ecosystems. The New Zealand Pesticide Residues Committee has documented increasing AMPA detections in soil and water over the past decade, with insufficient understanding of its long-term ecotoxicity.

Trade and Market Access Risks

New Zealand’s reputation for producing clean, green, and safe food is a cornerstone of our export economy. Raising glyphosate MRLs could jeopardize access to key international markets that have stricter residue limits. For example, Japan has rejected New Zealand honey shipments due to glyphosate residues exceeding their permissible levels.

As of 2024, more than a dozen EU countries—including Austria, France, Germany, and Luxembourg—have announced partial or full bans on glyphosate use. The European Commission has approved glyphosate for only a temporary 10-year extension, amid growing pressure for a full phase-out. This creates a volatile regulatory climate in Europe where elevated MRLs could soon be interpreted as non-compliance.

In the Asia-Pacific region, Taiwan and South Korea have tightened import controls for glyphosate residues in cereals, and consumer groups in Japan have lobbied successfully for lower glyphosate thresholds in food imports. These dynamics place New Zealand exporters at risk of rejection and reputational damage if glyphosate levels are increased domestically

Policy Coherence and Future Agricultural Practices

The proposed MRL increases appear to facilitate the adoption of genetically engineered glyphosate-tolerant crops, which are associated with increased herbicide use. This shift contradicts New Zealand’s commitments to sustainable agriculture and environmental protection.

The timing of this MRL proposal, alongside the Gene Technology Bill currently before Parliament, raises concerns about alignment. Increasing glyphosate residue limits could be perceived as regulatory paving for the eventual introduction of herbicide-tolerant genetically engineered crops—an issue not openly debated with the public or iwi.

In addition, lifting MRLs for glyphosate contradicts New Zealand’s commitments under the APEC Food Security Roadmap and the Global Biodiversity Framework, both of which prioritize reductions in agrichemical inputs and the promotion of agroecological practices.

Recommendations

In light of the concerns outlined above, the Soil & Health Association of New Zealand recommends the following actions:

  1. Reject the proposed glyphosate MRL increases for wheat, oats, barley, and peas.
  2. Maintain the current default MRL of 0.1 mg/kg, adhering to the precautionary principle in food safety regulation.
  3. Conduct comprehensive, independent reviews of glyphosate’s health and environmental impacts, incorporating the latest scientific evidence.
  4. Enhance monitoring and transparency regarding glyphosate residues in food products, ensuring public access to residue data.
  5. Promote and support alternative weed management practices, including organic and regenerative agriculture methods that reduce reliance on chemical herbicides.

Conclusion

The proposed increase in glyphosate MRLs poses significant risks to public health, environmental sustainability, and New Zealand’s international trade relationships. Upholding our nation’s commitment to safe, sustainable, and high-quality food production requires adherence to precautionary principles and robust regulatory standards.

We urge New Zealand Food Safety to reconsider the proposed amendments and to engage in a comprehensive review process that prioritizes the health of our people, the integrity of our environment, and the resilience of our agricultural economy.

Submitted by:

Charles Hyland
Chair, Soil & Health Association of New Zealand
16 May 2025
Email: charles.hyland@soilandhealth.org.nz

See also our Glyphosate Campaign Page here.

Goodbye Glyphosate! Rethinking Weeds

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Learn how to eliminate glyphosate and other harmful herbicides.

This recording is available to members, below. Please log-in using the email associated with your membership. If you have trouble logging-in please contact our team by email: info@organicnz.org.nz

About the video

This webinar is part of the Soil & Health Association’s campaign to strengthen regulation of glyphosate: https://soilandhealth.org.nz/glyphosate/

Join Philippa Jamieson, former editor of Organic NZ magazine, in conversation with Dr Charles Merfield and Mike Palmers who will discuss the way we think about and experience the plants we call “weeds”, and offer some organic, non-chemical and agro-ecological ways of managing them.

Followed by questions and discussion about practical weed solutions for your home garden, small block or farm.

The panelists

Dr Charles Merfield is head of the BHU Future Farming Centre and Merfield Agronomy Ltd. He has a particular interest in physical and ecological weed management.

Mike Palmers is an organic landscape gardener, he is currently a member of Soil & Health’s national council, and has served on the board of BioGro.

Video series

Suggested donation $10 – funds go towards Soil & Health’s glyphosate campaign. Make your donation by credit card: https://soilandhealth.org.nz/donate/#!form/Donate

Or transfer funds to our account: BNZ Account number: 02 0108 0058415 001

Wake-up call on the environmental and human health harms of toxic agrichemicals

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The Soil & Health Association is welcoming last week’s “Knowing what’s out there” report by the Parliamentary Commissioner for the Environment. The report criticises New Zealand’s lack of monitoring and regulation of environmental harm from chemicals.

Jodie Bruning, national councillor for the Soil & Health Association

“New Zealand lags behind other countries on monitoring and regulation of toxic agrichemicals, putting our health, environment and overseas trade agenda at risk,” says Soil & Health spokesperson Jodie Bruning.

“A more integrated framework, suggested by the report, will help the right hand know what the left hand is doing, this is currently not happening in New Zealand, when it comes to environmental chemicals.

“For example the Environmental Protection Agency, our government watchdog on these issues, had to make a public appeal last year for information on glyphosate use. Why do they need to resort to this?  Because they don’t monitor glyphosate’s use, availability, or impacts. There’s no feedback loop between the agency and our territorial and local authorities.

“It’s been shown that glyphosate is a probable carcinogen and its widespread use in New Zealand must be stopped. 

“Glyphosate is the tip of the iceberg. Our regulatory settings are useless if we are not informed about environmental pollution, and if the regulator is not keeping an eye on what’s happening on the ground.

“The government needs to take this report seriously. This includes expediting a formal reassessment of glyphosate as a key next step in protecting New Zealanders and the natural environment from harm.”

ENDS

Notes

The PCE report is covered here: https://www.rnz.co.nz/news/national/462653/lack-of-mechanisms-to-govern-chemical-use-in-nz-commissioner

Glyphosate risk assessment urgently needed

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The New Zealand Environmental Protection Agency’s call for information on the use of glyphosate in Aotearoa is a missed opportunity to properly risk assess the substance says Jodie Bruning, spokesperson for the Soil & Health Association.

Today the EPA extended the process for a second time. Submissions were due to close today but now close on October 22nd. 

“The NZEPA is delaying. This call for information should be integrated into a genuine risk assessment of glyphosate and glyphosate-based herbicides sold and used in this country.

“Government is moving to review glyphosate because it knows that glyphosate causes health and environmental damage. But the major users of glyphosate will fight strongly to keep hold of it.

“On behalf of the thousands of New Zealanders who want action to reduce the harm from toxic agrichemicals we’re making this submission as part of the call for information.

The key points in the Soil & Health Association submission are:

  • A glyphosate risk assessment is needed urgently
  • The health risks from glyphosate keep getting bigger
  • Farmers and applicators are exposed more often than regulators assume
  • New mowing and robotics technology mean there’s no excuse for spraying roadsides and urban environments
  • The economic risks to glyphosate-based herbicides are real and growing

“Further delays to this process are unacceptable and we need to get on with the formal risk assessment,” says Bruning.

ENDS

EPA Call for Information on glyphosate, September 2021

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Summary of our submission

A GLYPHOSATE RISK ASSESSMENT IS NEEDED URGENTLY

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

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

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

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

SURVEY OF COUNCIL USE OF GLYPHOSATE

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

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

THERE ARE KNOWN HEALTH RISKS FROM GLYPHOSATE

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

We provide evidence of these risks our submission document.

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

We urge the government to take a strict precautionary approach.

GLYPHOSATE USE LEADS TO INCREASING HERBICIDE RESISTANCE

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

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

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

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

ECONOMIC RISKS OF GLYPHOSATE-BASED HERBICIDES

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

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

SOIL & HEALTH’S GLYPHOSATE PETITION

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

Supporters of our petition are calling on the government to:

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

OUR FULL SUBMISSION

Included in our submission are

Soil & Health launches glyphosate campaign

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The Soil and Health Association are calling for councils to stop spraying glyphosate to keep New Zealand families safe.

‘The public increasingly understand that it is no longer acceptable to be exposed to glyphosate-based herbicides,’ says Soil & Health spokesperson Jodie Bruning,

We are working with US based Non-Toxic Neighbourhoods who have had significant success helping councils transition affordably to non-toxic urban management.

The importance of glyphosate science

Public health scientists think it is bizarre that the findings of the most prestigious cancer agency in the world were rejected by New Zealand’s Environmental Protection Authority (the EPA).

The International Agency for Research on Cancer (IARC) determined that glyphosate probably causes cancer in humans. The IARC also found that glyphosate (and it’s commercial formulations) definitely causes cancer in laboratory animals – placing our pets at risk too.

 In 2016 the EPA produced what scientists consider to be a flawed cancer review to discredit the findings of the EPA’s own cancer authority.  New Zealand professors and scientists remain ‘mystified’ and have spoken repeatedly (here and here and here) about the EPA’s frozen stance on glyphosate. An Official Information [ENQ-35127-N5J6C7]request has found that the EPA has never conducted a formal risk assessment of glyphosate or the commercial formulation.

Glyphosate is not just a cancer risk. Scientific studies show that glyphosate-based herbicides, including Roundup, may not only probably cause cancer but cause oxidative stress and disrupt endocrine system function which can set the stage for disease and delays.

Chemical companies are paying out for the damage caused

Following the IARC decision, cases in the U.S. have awarded the claimants damages against Monsanto (since 2018, owned by Bayer). The court cases uncovered evidence that showed how Monsanto took action to limit and distort public knowledge. Punitive damages were awarded for ‘reprehensible’ conduct. The jury trials are now under appeal with Bayer claiming the verdict of regulators across the world upholds Bayer’s stance. Unfortunately, as scientists have illustrated (in Europe and the USA), regulatory agencies relied on ghostwritten industry studies and ignored data that the IARC considered important.

In June 2020 Bayer proposed a settlement of USD$8.8-10.9 billion to settle over 125,000 U.S. lawsuits to resolve Roundup litigation. Bayer has framed the complex settlement proposal as an end to ‘uncertainty’. The proposal contained no admission that glyphosate-based herbicides caused the cancer claimed by cancer sufferers, many former farmers, who see the proposal as a slap in the face. The settlement proposal may restrict future claimants from a jury trial. New Zealand doesn’t face the same court cases here because the ACC covers such cases as accidents.

Why isn’t New Zealand taking action?

Ignoring the calls of scientists, New Zealand councils refer to the New Zealand Environmental Protection Authority (NZ EPA) to claim that glyphosate is a ‘low toxicity herbicide’. The hazard rating given by the NZ EPA provides a legal rationale that it is safe enough to spray in public places. This is wrong!

It is evident from operations in Auckland and Christchurch that councils and contractors need to make a lot of changes in order to shift away from glyphosate dependency – like any addiction – shifting to a new mindset isn’t always easy. Much of the management and contract negotiation are out of the public eye – so it is difficult for the public to understand what is going on. Councils don’t appear to be undertaking properly accountable trials with new technologies and recording and documenting trial methods, how they cope with and reduce over time the weed seed banks, and making this information public. We know non-toxic alternatives and management regimes can never neatly replace toxic chemical use. Shift away from addiction requires a change in mindset and operations.

We also understand that councils struggle to adopt the precautionary principle. This would help deal with uncertainty (which is always present). Councils may not be comfortable weighing the risk to families, and particularly babies and children, with the risk of complaints from irate rate-payers or staff worried about the stress on physical assets. These are value-based decisions, and are an important part of making any decision to protect health or the environment.