To: Primary Production Committee
Submitter: The Soil & Health Association of New Zealand
Date: June 2026
Soil & Health wishes to speak to this submission.
1. Summary position
The Soil & Health Association of New Zealand opposes the Hazardous Substances and New Organisms Amendment Bill in its current form.
Soil & Health supports efficient, transparent and scientifically robust regulation. However, efficiency must never come at the expense of the core purpose of the Hazardous Substances and New Organisms Act 1996: the protection of human health, ecosystems, soil, water, biodiversity and future generations from the adverse effects of hazardous substances and new organisms.
The Bill is presented as a measure to streamline regulatory processes while maintaining protection. However, the supporting policy material shows a strong emphasis on reducing delays, increasing access to products, relying more heavily on overseas regulatory decisions, and supporting productivity and economic growth.
Our concern is not that applications may be processed more quickly. Our concern is that the balance of the legislation is being shifted away from precaution and protection, and toward speed, market access and economic outcomes.
HSNO was created to protect people and the environment from harm. It exists because environmental and public health harms are often delayed, cumulative and difficult to reverse. The lesson from decades of environmental regulation is simple: harm is usually easier to create than it is to repair.
Soil & Health therefore asks the Primary Production Committee to recommend that the Bill does not proceed in its current form.
If the Committee does proceed with the Bill, Soil & Health asks that it be substantially amended so that environmental protection, human health, soil and water health, Te Tiriti obligations, public participation, organic integrity, GE-free production and the precautionary approach remain central to the HSNO Act.
Our key requests are:
- Do not proceed with the Bill in its current form.
- Do not use the HSNO Amendment Bill to prepare the ground for a more permissive gene technology regime while the Gene Technology Bill remains contested and unresolved.
- Remove, or substantially narrow, the proposed temporary hazardous substances approval pathway, particularly for agrichemicals and novel biological, nano-enabled or gene-related technologies.
- Ensure overseas regulator assessments may inform New Zealand decisions, but must not replace independent New Zealand assessment.
- Keep the burden of proving safety on applicants, not on communities, objectors, iwi, organic producers, neighbouring landowners or affected sectors.
- Retain strong public notification, consultation and hearing rights where approvals may affect organic producers, GE-free production, Māori interests, neighbours, waterways, soil health, biodiversity, pollinators, food systems or public health.
- Keep key safeguards in the Act itself, not only in later regulations, notices, guidance or discretionary decision-making.
- Explicitly require precautionary assessment of novel and emerging technologies, including but not limited to genetic engineering (encompasses gene editing), nanotechnology, nanoparticles, RNA-based sprays, gene-silencing products, synthetic biology, microbial products, biological controls and combined chemical-biological technologies.
- Ensure applicants and approval holders, not affected farmers, organic producers, certifiers, councils, tangata whenua or future land users, carry responsibility for contamination, monitoring, containment failure and market loss.
- Require transparent post-approval monitoring, public reporting and reassessment where new evidence emerges.
- Protect the integrity of organic and GE-free production in Aotearoa New Zealand.
2. About Soil & Health
Soil & Health is one of the world’s oldest organic advocacy organisations. Our kaupapa is healthy soil, healthy food and healthy people. We advocate for food and farming systems that protect soil, water, biodiversity, human health and future generations.
Organic production is built on trust. That trust depends on clear standards, strong regulation, careful assessment of risk, and the ability of producers and consumers to rely on products being genuinely organic and GE-free.
For organic producers, environmental release of, or contamination with hazardous substances or new organisms is not an abstract regulatory issue. It can affect certification, market access, export relationships, consumer confidence, neighbouring properties and the long-term integrity of production systems.
Soil & Health approaches this Bill from the perspective of public health, environmental protection, organic integrity, soil health, water quality, biodiversity, precaution and intergenerational responsibility.
3. The purpose of HSNO must remain paramount
The purpose of the HSNO Act is protective. It is 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.
That protective purpose must remain paramount.
Economic benefits, productivity and access to new products can be legitimate considerations. However, they must remain secondary to the protection of:
- organic and GE-free production
The Bill risks creating a regulatory environment in which commercial opportunity is given increasing weight, while environmental and health uncertainties are expected to be managed after approval rather than resolved before approval.
The central question under HSNO should be:
Can this product, organism or technology be shown to be safe and appropriate for use in New Zealand conditions?
The Bill risks replacing that question with:
Can this product, organism or technology be approved more quickly?
That is a significant change in regulatory philosophy.
Regulatory speed is not, by itself, a measure of good regulation. In environmental regulation, delay is sometimes evidence of necessary diligence. The costs of delayed approval are often visible and immediate. The costs of premature approval are often delayed, diffuse and difficult to attribute. That does not make them less important.
Slow harm is still harm. Diffuse harm is still harm. Harm that is hard to attribute after the fact is precisely the kind of harm that a precautionary statute should prevent.
4. The Bill must be considered alongside gene technology and ACVM reform
The HSNO Amendment Bill is not occurring in isolation. It sits alongside the Gene Technology Bill and the Agricultural Compounds and Veterinary Medicines Amendment Bill.
Together, these reforms raise significant concerns for organic and GE-free production.
The Gene Technology Bill proposes a major shift in the regulation of genetic technologies. The HSNO Amendment Bill changes how new organisms and hazardous substances are assessed. The ACVM Amendment Bill changes pathways for agricultural compounds and veterinary medicines, including products already approved overseas.
Soil & Health is concerned that the combined effect of these bills could create regulatory gaps. Products involving genetic technologies, biological controls, microorganisms, RNA-based tools, nano-delivery systems, agrichemicals, veterinary medicines, novel biological products or chemical-biological combinations may move across regulatory boundaries in ways that are difficult for farmers, consumers, certifiers and the public to understand.
The Committee should not assess the HSNO Amendment Bill as a narrow technical efficiency update. It should ask how the Bill interacts with the wider reform package and whether the overall framework remains protective enough for food, farming, biodiversity, organics and GE-free production.
5. New Zealand assessment must not be outsourced
The Bill places considerable weight on the use of overseas regulatory assessments.
Soil & Health does not oppose the EPA considering high-quality international information. International science can be useful. However, overseas decisions must not substitute for full and independent New Zealand assessment.
New Zealand is not simply a branch office of overseas regulators.
New Zealand has distinct environmental, cultural, agricultural and market conditions, including:
- unique indigenous biodiversity
- distinctive soils and soil biota
- small catchments and sensitive waterways
- high rainfall and runoff risks in some regions
- wind drift and spray-drift conditions
- pastoral, horticultural and mixed farming systems that differ from many overseas jurisdictions
- Māori relationships with whenua, wai, taonga species, whakapapa and mahinga kai
- significant organic, regenerative and GE-free production systems
- premium export markets that depend on trust and integrity
- consumer expectations around natural, organic and GE-free food
An approval granted in North America, Europe, Australia or elsewhere cannot automatically account for New Zealand conditions.
Regulatory decisions should be informed by international science, but never outsourced to overseas regulators.
If overseas assessments are used, the Act should require that they are only one source of evidence. The applicant should still carry the burden of proving safety and suitability in New Zealand conditions. The EPA should be required to publish how it used overseas information, what New Zealand-specific assessment was undertaken, and what uncertainties remain.
The public should not be required to prove, after the fact, that a substance or organism is unsafe for New Zealand conditions.
6. The burden of proof must remain with applicants
The burden of proof should remain firmly on applicants seeking approval to introduce hazardous substances, new organisms or novel technologies into New Zealand’s environment, food systems, waterways and communities.
Soil & Health is concerned that reliance on overseas approvals, narrowed assessment pathways, rapid approvals and temporary approvals may shift the practical burden away from applicants and onto the public, affected neighbours, organic producers, iwi, communities and environmental groups.
That would be wrong.
The applicant seeks the commercial benefit. The applicant should carry the evidential burden and the risk.
The public should not be required to prove that a product is unsafe after approval has already occurred. Organic producers should not be required to prove why their markets and certification need protection after contamination has already happened. Iwi and hapū should not have to prove that whenua, wai, taonga species and mahinga kai matter after exposure has occurred.
If uncertainty remains regarding persistence, chronic toxicity, endocrine disruption, cumulative exposure, food-chain effects, microbiome impacts, non-target species effects, soil effects, water effects or ecosystem consequences, that uncertainty should weigh against approval rather than in favour of speed.
7. “Significant effects” must not be narrowed too far
Soil & Health is concerned about any narrowing of “significant effects” so that an international pathway turns mainly on whether an objector can identify effects that are specifically New Zealand-specific and not already addressed overseas.
Such an approach risks creating a presumption that overseas conclusions are correct unless New Zealand-specific concerns can be demonstrated by the public or affected parties.
The precautionary approach requires the opposite.
Where uncertainty exists, decision-makers should require robust evidence demonstrating safety before approval is granted.
“Significant effects” should be defined broadly enough to include:
- impacts on microbial, fungal and invertebrate communities
- aquatic toxicity and stream health
- pollinators and non-target species
- cumulative and synergistic effects
- chronic low-dose human exposure
- residues in food, compost, manure, silage, soil and water
- contamination risk for organic and GE-free farms
- cultural, ethical, spiritual and whakapapa concerns
- market access and certification consequences
- effects that may not become visible for years
A narrow test may improve administrative speed, but it would not improve environmental protection.
8. Temporary approvals can create permanent harm
Soil & Health is particularly concerned about the proposed temporary hazardous substances approval pathway.
Temporary approval can still create permanent consequences. Even short-term use can result in:
- non-target species impacts
- loss of organic certification
- market impacts for neighbouring producers
- harm to beneficial organisms
- long-term ecological disruption
Once a product has been used in soil, water or open environments, exposure cannot simply be unwound. Once residues move through waterways, drift onto neighbouring land or enter compost, manure, silage or food-chain pathways, subsequent regulatory action may not reverse the damage.
A “temporary” approval may create permanent consequences.
This is especially concerning for agrichemicals, because these products are designed to be released into the environment. It is not enough to say that a full assessment will occur later if exposure has already happened.
If the Committee retains any temporary approval pathway, Soil & Health asks that it include at least the following safeguards:
- temporary approvals must not apply to products involving genetic technologies, RNA-based gene silencing, nanotechnology, synthetic biology, self-replicating organisms, engineered microorganisms or novel microbial products unless full public assessment has first occurred
- the EPA must publicly notify proposed temporary approvals where use may affect soil, water, biodiversity, human health, organic production, GE-free production, neighbours or Māori interests
- the applicant must submit a full application before any temporary approval is granted
- the applicant must fund independent monitoring during and after use
- use near organic or GE-free production, schools, public places, waterways, wetlands, conservation land and sensitive habitats must be subject to strict controls and public notification
- affected neighbours and certifiers must be notified before use
- clear suspension, modification and revocation powers must be retained
- applicants and approval holders must be liable for contamination, certification loss, monitoring costs, clean-up costs and market loss caused by use under the temporary approval
9. Speed is not a substitute for good regulation
The policy material repeatedly identifies delay as a problem requiring correction.
Soil & Health accepts that regulatory delay can create real costs. However, the assumption that faster approval is always better is not sound in the context of hazardous substances and new organisms.
In environmental regulation, the consequences of approving a hazardous substance too quickly are often borne by others:
- ecosystems that have no voice in the approval process
The economic costs of delayed approvals are usually visible and immediate. The environmental costs of premature approvals are often delayed, diffuse and irreversible.
That does not make them less important.
HSNO should not become a system in which uncertainty is increasingly tolerated in the pursuit of economic opportunity.
10. The Bill risks privatising benefits and socialising risks
One of the most troubling features of the proposed reforms is the potential transfer of risk.
The commercial benefits of approval flow primarily to:
When things go wrong, however, the costs are often borne by:
This creates a profound imbalance.
The private sector captures the upside. The public carries the uncertainty.
The HSNO framework should prevent this imbalance, not enable it.
Soil & Health therefore asks that the Bill include a clear polluter-pays principle. Applicants and approval holders should be responsible for monitoring, containment failure, contamination, clean-up, certification loss and market loss caused by products approved under accelerated or temporary pathways.
11. Emerging technologies require greater caution, not less
New and emerging technologies are rapidly changing the landscape of agricultural and environmental interventions.
These include:
- Gene technologies (including gene-editing)
- RNA interference and RNA-like gene-silencing products
- synthetic biology applications
- engineered microbial products
- microbial consortia and biologicals
- nanotechnology and nanoparticles
- lipid nanoparticles and other delivery systems
- products combining chemicals, adjuvants, biologicals and genetic material
Many of these technologies are promoted as precise, targeted, lower residue and environmentally benign.
History teaches caution.
Asbestos, DDT, PCBs, PFAS compounds, neonicotinoids and numerous other technologies were once promoted as useful solutions. Only later were broader environmental and health consequences understood.
Regulators must remain humble in the face of scientific uncertainty.
Products using nanoparticles, lipid nanoparticles, nano-carriers or other nano-enabled delivery systems can behave differently from conventional formulations. They may alter persistence, uptake, transport, toxicity, cell penetration, bioavailability and environmental movement. The same concern applies to RNA-based or gene-silencing products, especially where they are delivered through sprays, microbial systems or nano-carriers.
The Bill should not allow products to receive reduced scrutiny because they are described as “targeted”, “biological”, “low residue”, “innovative” or “approved overseas”. These descriptions are not substitutes for evidence.
12. Example scenario: RootSilence-R
A plausible future example illustrates the risk.
Imagine a product called RootSilence-R. It is a spray containing lipid nanoparticles carrying RNA-based gene-silencing material designed to suppress a fungal pasture pest.
The product receives conditional approval overseas. It is promoted as targeted, innovative and low residue.
Under a more permissive HSNO pathway:
- the applicant points to overseas regulator assessments
- the EPA focuses mainly on New Zealand-specific differences
- a temporary approval allows use before the full assessment is complete
- public notification is limited because the product is framed as targeted and low-risk
- the product is applied before heavy rainfall
- runoff carries residues into drains, soil, streams and neighbouring properties
- soil fungi, mycorrhizal networks, earthworms, aquatic invertebrates, non-target microorganisms and neighbouring organic production systems are exposed
- several years later, evidence emerges of unexpected off-target effects, persistence in certain soil types or ecological interactions not identified during approval
By then, the product has already delivered financial benefits to its developers and users.
The risks have been transferred to everyone else.
The question Parliament must ask is simple:
Who should carry the burden of uncertainty?
The applicant seeking commercial gain?
Or the public, organic producers, tangata whenua and environment that receive no opportunity to consent?
Soil & Health’s answer is clear: the burden must remain with the applicant.
13. Public participation and transparency must be protected
Public participation is not an administrative obstacle. It is a safeguard.
Soil & Health is concerned that too much detail may be moved into regulations, notices, guidance or discretionary processes. That risks reducing Parliamentary scrutiny and public visibility.
Key protective thresholds should remain in the Act. Public notification and hearing rights should be retained where approvals may affect communities, ecosystems, organic producers, iwi, food systems and future generations.
The Act should require public notification where an application may involve:
- new organisms such as genetically engineered organisms (includes gene editing)
- agrichemicals with broad environmental exposure
- RNA-based or gene-silencing technologies
- biologicals or microbial products
- effects on organic or GE-free producers
- potential contamination beyond the applicant’s property
- significant public interest
- Māori cultural, spiritual, whakapapa or taonga species concerns
- uncertain or irreversible effects
The people and ecosystems affected by approval decisions must have a meaningful opportunity to be heard before exposure occurs, not after harm is suspected.
14. Power should not drift away from Parliament
The Bill and related policy material move significant operational detail into regulations, notices, ministerial determinations and administrative processes.
Delegation can improve administrative efficiency. However, environmental protections should not depend primarily on the discretion of whichever Minister, Director-General or agency happens to hold office at a particular time.
Fundamental safeguards belong in legislation debated openly by Parliament.
The greater the environmental risk, the greater the need for democratic accountability.
Soil, water, pollinators, neighbours, organic producers and future generations should not be protected only by later regulations, unpublished modelling assumptions, overseas decisions or administrative discretion.
The protective threshold belongs in the Act itself.
15. Māori interests and Te Tiriti obligations require more than technical consultation
Hazardous substances and new organisms can affect whenua, wai, mahinga kai, taonga species, biodiversity and intergenerational relationships with the natural world.
Soil & Health asks the Committee to ensure that Māori participation is active from the outset and not reduced to a technical consultation step.
Where applications may affect Māori interests, decision-making must provide for meaningful engagement with iwi, hapū and Māori organisations, and must give proper weight to mātauranga Māori, tikanga, whakapapa and kaitiakitanga.
The Bill should not allow accelerated pathways to bypass these obligations.
16. Organic and GE-free production need explicit protection
The use of genetically engineered organisms and their derivatives is prohibited in organic production systems. This includes seeds, animals, propagation material and farm inputs such as fertilisers, soil conditioners, vaccines and crop protection materials.
Organic certification is therefore directly affected by any regulatory change that increases the likelihood of environmental release, contamination, unclear product status, weak labelling, weak traceability or reduced assessment of hazardous substances and novel technologies.
For organic and GE-free producers, contamination can mean:
- loss of export opportunities
- reputational damage through no fault of their own
It is not acceptable for the costs of contamination to fall on the producer who did not use the product.
Soil & Health asks that the Bill include explicit recognition of organic and GE-free production as affected interests in relevant HSNO decisions.
The EPA should be required to consider:
- impacts on organic certification
- market access and export integrity
- buffer zones and notification requirements
- liability and compensation
- traceability and monitoring
- protection for neighbouring producers
Organic and GE-free producers should not be treated as afterthoughts in a system that could directly affect their certification, livelihoods and markets.
17. Compliance, monitoring and reassessment must be strengthened
If the Bill creates faster pathways, it must also strengthen monitoring and accountability.
Approvals should require:
- publicly available approval conditions
- independent environmental monitoring where needed
- residue monitoring in soil, water, compost, manure and food-chain pathways where relevant
- monitoring for non-target effects
- transparent reassessment triggers
- public registers of temporary approvals, conditions, incidents and reassessments
- enforceable duties on approval holders and users
- funding from applicants or approval holders for monitoring and enforcement
Without monitoring, the system may approve products quickly but detect harm too late.
18. Specific amendments sought if the Bill proceeds
Soil & Health’s primary position is that the Bill should not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be amended to achieve the following:
- Retain the precautionary intent of the HSNO Act as the overriding consideration.
- Require full and independent New Zealand assessment of hazardous substances and new organisms regardless of overseas approvals.
- Ensure international regulator assessments may inform, but not replace, EPA assessment.
- Reject pathways that allow environmental release before comprehensive assessment has been completed, particularly for agrichemicals, novel biological products, nanotechnology, RNA-based products and gene technologies.
- Ensure the burden of demonstrating safety remains with applicants.
- Maintain robust opportunities for public participation and scrutiny.
- Retain key environmental and health protections within primary legislation rather than delegated instruments.
- Require explicit consideration of impacts on soil health, soil biology, biodiversity, water quality, pollinators, organic production systems, GE-free production, Māori interests and future generations.
- Ensure new and emerging technologies such as RNA-based products, genetically engineered organisms (includes gene editing), engineered microorganisms, microbial technologies, synthetic biology, biological controls and nano-enabled products are assessed under precautionary principles appropriate to their complexity and uncertainty.
- Require public notification where applications may affect organic or GE-free producers, iwi and hapū, waterways, neighbours, sensitive ecosystems or significant public interests.
- Require applicant-funded independent monitoring for any accelerated or temporary approval pathway.
- Create clear liability for applicants and approval holders where contamination, certification loss, market loss or environmental harm occurs.
- Require public reporting of temporary approvals, conditions, monitoring results, incidents, reassessments, suspensions and revocations.
- Ensure accelerated pathways do not bypass Te Tiriti obligations, mātauranga Māori, tikanga, whakapapa or kaitiakitanga.
- Prevent speed, productivity or commercial opportunity from overriding precaution, human health and environmental protection.
19. Conclusion – Relief Sought
The purpose of HSNO is to protect New Zealanders, our soils, our waterways, our biodiversity, our food systems and future generations from avoidable harm, not to accelerate hazardous substances and new organisms into the market, not to accelerate hazardous substances and new organisms into the market.
Soil & Health asks the Primary Production Committee to recommend that the Hazardous Substances and New Organisms Amendment Bill does not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be substantially amended as per our submission, to keep the burden of proof on applicants, protect organic and GE-free production, retain meaningful public participation, uphold Te Tiriti obligations, require independent New Zealand assessment, explicitly address new and emerging technologies, and keep precaution, environmental protection and human health at the centre of the HSNO Act.
Documents and sources considered
This draft was prepared with reference to the following materials:
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Submission on the Agricultural Compounds and Veterinary Medicines Amendment Bill
/in Farming, Farming and Horticulture, Free Online, GE, SubmissionsTo: Primary Production Committee
Submitter: The Soil & Health Association of New Zealand
Date: 15 June 2026
Soil & Health wishes to speak to this submission.
1. Summary position
The Soil & Health Association of New Zealand opposes the Agricultural Compounds and Veterinary Medicines Amendment Bill in its current form.
Soil & Health supports efficient, transparent and scientifically robust regulation. We also recognise that farmers, growers and veterinarians need access to safe and effective agricultural compounds and veterinary medicines, including products that support animal welfare, plant health, food safety and sustainable production.
However, efficiency must not come at the expense of careful assessment, public transparency, organic integrity, GE-free production, animal welfare, food safety, trade protection, Te Tiriti obligations, soil health, water quality, biodiversity and consumer trust.
The Bill has been progressed alongside the Hazardous Substances and New Organisms Amendment Bill and the wider Gene Technology reform programme. Together, these reforms could create faster pathways for agricultural products, veterinary medicines, novel or engineered biological products, gene-related technologies, animal treatments, inhibitor substances, fertilisers and crop protection products without sufficient consultation with the organic sector, Māori, certifiers, growers, farmers, veterinarians, exporters and consumers.
Soil & Health asks the Primary Production Committee to recommend that the Bill does not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be substantially amended to ensure that independent New Zealand assessment, precaution, public participation, organic and GE-free integrity, animal welfare, food safety, trade protection and Te Tiriti obligations remain central to the ACVM regulatory system.
2. About Soil & Health
Soil & Health is one of the world’s oldest organic advocacy organisations. Our kaupapa is healthy soil, healthy food and healthy people. We advocate for food and farming systems that protect soil, water, biodiversity, human health, animal welfare and future generations.
Organic production is built on trust. That trust depends on clear standards, strong regulation, careful assessment of risk, and the ability of producers and consumers to rely on products being genuinely organic and GE-free.
Agricultural compounds and veterinary medicines are not abstract regulatory products. They include veterinary medicines, crop protection products, vertebrate toxic agents, animal feeds, fertilisers, environmental inhibitors and other farm inputs. Decisions about these products can affect organic certification, residue status, export assurance, animal welfare, soil biology, water quality, biodiversity, consumer trust and market access.
3. Consultation has been inadequate
Soil & Health is concerned that the Bill has been progressed too quickly and with insufficient consultation with the organic community, Māori, certifiers, environmental organisations, consumers, pet owners, animal breeders, zoos, the Department of Conservation, wildlife hospitals and others working with native species.
The Bill is technically complex. It also sits alongside the HSNO Amendment Bill and the Gene Technology Bill. The combined implications are significant and cannot be properly assessed in isolation.
The organic sector has not had adequate time to analyse the Bill, understand its interactions with other legislation, assess implications for organic certification and GE-free production, and provide fully informed feedback.
Soil & Health asks the Committee to slow the process, consult properly, and require a clear assessment of the combined effects of the ACVM, HSNO and gene technology reforms before proceeding.
4. The protective purpose of the ACVM system must remain central
The purpose of the ACVM Act includes preventing or managing risks to public health, trade in primary produce, animal welfare and agricultural security. Those protective purposes must remain central.
The Bill is presented as a measure to reduce barriers, improve flexibility and provide faster access to new products. Soil & Health does not oppose better regulatory administration.
However, the test should not simply be whether a product can reach the market faster. The test should be whether it is safe, effective, suitable for New Zealand conditions, compatible with organic and GE-free production, and properly controlled.
The ACVM system must protect more than product access. It must protect food safety, animal welfare, trade assurance, organic integrity, environmental health and public trust.
5. Overseas assessments must not replace New Zealand assessment
Soil & Health is concerned about greater reliance on overseas regulators and overseas assessments. International information can be useful. However, overseas approvals must not replace independent New Zealand assessment.
New Zealand has distinct environmental, farming, animal health, trade and market conditions, including:
A product approved overseas may not be appropriate for New Zealand conditions. This is especially important where overseas jurisdictions have different approaches to gene technologies, animal treatments, crop inputs, residues, veterinary medicines, environmental inhibitors or novel biological products.
If overseas assessments are used, they should inform New Zealand decision-making only. They should not substitute for New Zealand assessment, New Zealand consultation or New Zealand accountability.
6. Recognised overseas regulators must be clearly defined
The Bill refers to recognised overseas regulators. The Act should not allow reliance on an overseas regulator unless clear statutory criteria explain how recognition is granted, reviewed and, if necessary, revoked.
At a minimum, recognition should consider:
A regulator should not be treated as recognised merely because it is located in a country with which New Zealand has a close trade relationship.
7. Exemptions must not weaken protection
Soil & Health is concerned about giving the Director-General wider ability to decide product registration exemptions. Some low-risk exemptions may be appropriate. However, exemption pathways must not become a way for higher-risk products to avoid proper assessment, public notification or scrutiny.
Soil & Health is also concerned about any drafting that could validate an exemption despite inadequate consultation. Consultation duties should be meaningful. Failure to consult affected parties should not be treated as a harmless technical issue where organic integrity, animal welfare, trade, residues, Māori interests, environmental health or public confidence may be affected.
Exemptions should not apply to products involving, derived from, or associated with:
The burden should remain on applicants to demonstrate safety, effectiveness and suitability for New Zealand conditions.
8. Organic and GE-free production need explicit protection
Organic and GE-free producers are directly affected by ACVM decisions. A product may raise organic-sector concerns because of its active ingredient, manufacturing process, carrier, adjuvant, excipient, residue profile, genetic technology status, animal-treatment use, feed use, soil impact, environmental persistence or contamination pathway.
For organic and GE-free producers, inappropriate approval or weak traceability can cause:
The Bill should explicitly recognise organic and GE-free production as affected interests in ACVM decision-making.
Decision-makers should be required to consider impacts on organic certification, market access, GE-free status, traceability, labelling, residues, coexistence, liability and compensation.
9. Veterinary medicines and animal welfare
Soil & Health does not oppose access to appropriate veterinary medicines. Organic production requires animals to be treated when treatment is needed. Animal welfare must never be compromised by ideology or by regulatory delay.
However, access to veterinary medicines must be balanced with careful assessment of public health, antimicrobial resistance, residues, trade implications, environmental effects, animal welfare outcomes and organic certification consequences.
The Bill should not allow faster pathways to weaken assessment of veterinary medicines, vaccines, animal treatments, feed additives, methane inhibitors, hormones, antimicrobials or other products used in or around animals.
Where products may affect animal welfare, food safety, residue status, antimicrobial resistance, export assurance or organic certification, they should receive full New Zealand-specific assessment and transparent conditions of use.
10. Inhibitor substances, fertilisers and animal feed additives require care
Soil & Health recognises that new products may be developed to reduce emissions, nutrient losses or other environmental impacts. Some may have genuine benefits.
However, products promoted as climate, productivity or environmental solutions can still create risks. These may include residues, soil biological impacts, animal health effects, food-chain effects, trade issues, contamination of organic systems or unintended ecological consequences.
Inhibitor substances, including methane inhibitors, nitrification inhibitors and urease inhibitors, along with coated fertilisers, feed additives and similar products, should not be fast-tracked or exempted unless their risks are fully assessed in New Zealand conditions.
The Committee should ensure that productivity or climate claims do not override precaution, animal welfare, soil health, food safety, trade integrity or organic certification.
11. Public participation and transparency must be retained
Public notification and consultation should not be treated as administrative barriers. The ACVM system affects food safety, animal welfare, trade, agricultural security, organic production, public trust and the environment. Affected communities and sectors should be able to see and respond to significant proposed changes.
Public notification should be required where an application, exemption, reassessment or approval may affect:
The public should not have to discover risks only after approval or exemption has already occurred.
12. Te Tiriti obligations must not be bypassed
Agricultural compounds and veterinary medicines can affect whenua, wai, mahinga kai, taonga species,
biodiversity, animal health, food systems and intergenerational relationships with the natural world. The Bill should not allow accelerated pathways, overseas assessments or exemptions to bypass meaningful engagement with iwi, hapū and Māori organisations.
Decision-making should give proper weight to mātauranga Māori, tikanga, whakapapa, kaitiakitanga and Te Tiriti obligations.
13. Monitoring, traceability and liability must be strengthened
If the Bill creates faster or more flexible pathways, it must also strengthen monitoring and accountability.
Approvals and exemptions should include:
The costs of uncertainty should not be shifted to organic producers, neighbouring landowners, certifiers, councils, consumers or future generations.
14. Specific recommendations
Soil & Health recommends that the Primary Production Committee:
Conclusion
Soil & Health supports access to safe, effective and genuinely beneficial agricultural compounds and veterinary medicines. We do not oppose appropriate veterinary treatment, animal welfare tools, plant health products or organic-compatible biological inputs.
Our concern is with the direction of the Bill: faster access, greater overseas reliance, wider exemption powers and reduced regulatory friction without adequate consultation and without sufficient safeguards for organic integrity, GE-free production, Māori interests, animal welfare, public health, food safety, trade protection and environmental health.
The ACVM system must protect more than product access. It must protect trust. That trust matters to farmers, growers, veterinarians, organic producers, exporters, consumers and future generations.
Soil & Health therefore asks the Primary Production Committee to recommend that the Agricultural Compounds and Veterinary Medicines Amendment Bill does not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be substantially amended to retain independent New Zealand assessment, meaningful consultation, transparent decision-making, strong safeguards for organic and GE-free production, and clear accountability for applicants and approval holders.
Documents and sources considered
This final submission was prepared with reference to the following materials:
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/in UncategorizedFull AGM information is here on the Main 2026 AGM page
Nominations for National Council and member remits open 27 June 2026 and close 17 August 2026.
Nominations now sought for 2026
Timeline
How to nominate or be nominated
Those wishing to be nominated for National Council must send the following information to manager@organicnz.org.nz by 17 August 2026.
What does the role involve? Read more here, and view the current National Council members here.
Candidates need to be ordinary members of Soil & Health – JOIN up here. If you need to check your membership status please contact info@organicnz.org.nz.
Candidates should be free of conflicts of interest on issues we oppose, e.g. GE.
Where the council requires certain skills mid term, it may reach out and offer interim appointments.
Remits to the 2026 AGM
Any remits from members must be emailed to manager@organicnz.org.nz by 17 August 2026. Remits are generally suggested amendments to the constitution.
2026 AGM of the Soil & Health Association
/in Association Meetings and EventsThe 2026 AGM will be held from 10am–12pm on Saturday 26 September 2026, online.
We welcome all financial and honorary life members. The meeting is conducted according to our constitution.
Key dates (statutory)
Documents
Register
Register your attendance below. The Zoom link is emailed to current financial members who register. Questions about membership: info@organicnz.org.nz.
2026 Annual General Meeting
Agenda (summary)
Submission on the Hazardous Substances and New Organisms Amendment Bill
/in SubmissionsTo: Primary Production Committee
Submitter: The Soil & Health Association of New Zealand
Date: June 2026
Soil & Health wishes to speak to this submission.
1. Summary position
The Soil & Health Association of New Zealand opposes the Hazardous Substances and New Organisms Amendment Bill in its current form.
Soil & Health supports efficient, transparent and scientifically robust regulation. However, efficiency must never come at the expense of the core purpose of the Hazardous Substances and New Organisms Act 1996: the protection of human health, ecosystems, soil, water, biodiversity and future generations from the adverse effects of hazardous substances and new organisms.
The Bill is presented as a measure to streamline regulatory processes while maintaining protection. However, the supporting policy material shows a strong emphasis on reducing delays, increasing access to products, relying more heavily on overseas regulatory decisions, and supporting productivity and economic growth.
Our concern is not that applications may be processed more quickly. Our concern is that the balance of the legislation is being shifted away from precaution and protection, and toward speed, market access and economic outcomes.
HSNO was created to protect people and the environment from harm. It exists because environmental and public health harms are often delayed, cumulative and difficult to reverse. The lesson from decades of environmental regulation is simple: harm is usually easier to create than it is to repair.
Soil & Health therefore asks the Primary Production Committee to recommend that the Bill does not proceed in its current form.
If the Committee does proceed with the Bill, Soil & Health asks that it be substantially amended so that environmental protection, human health, soil and water health, Te Tiriti obligations, public participation, organic integrity, GE-free production and the precautionary approach remain central to the HSNO Act.
Our key requests are:
2. About Soil & Health
Soil & Health is one of the world’s oldest organic advocacy organisations. Our kaupapa is healthy soil, healthy food and healthy people. We advocate for food and farming systems that protect soil, water, biodiversity, human health and future generations.
Organic production is built on trust. That trust depends on clear standards, strong regulation, careful assessment of risk, and the ability of producers and consumers to rely on products being genuinely organic and GE-free.
For organic producers, environmental release of, or contamination with hazardous substances or new organisms is not an abstract regulatory issue. It can affect certification, market access, export relationships, consumer confidence, neighbouring properties and the long-term integrity of production systems.
Soil & Health approaches this Bill from the perspective of public health, environmental protection, organic integrity, soil health, water quality, biodiversity, precaution and intergenerational responsibility.
3. The purpose of HSNO must remain paramount
The purpose of the HSNO Act is protective. It is 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.
That protective purpose must remain paramount.
Economic benefits, productivity and access to new products can be legitimate considerations. However, they must remain secondary to the protection of:
The Bill risks creating a regulatory environment in which commercial opportunity is given increasing weight, while environmental and health uncertainties are expected to be managed after approval rather than resolved before approval.
The central question under HSNO should be:
Can this product, organism or technology be shown to be safe and appropriate for use in New Zealand conditions?
The Bill risks replacing that question with:
Can this product, organism or technology be approved more quickly?
That is a significant change in regulatory philosophy.
Regulatory speed is not, by itself, a measure of good regulation. In environmental regulation, delay is sometimes evidence of necessary diligence. The costs of delayed approval are often visible and immediate. The costs of premature approval are often delayed, diffuse and difficult to attribute. That does not make them less important.
Slow harm is still harm. Diffuse harm is still harm. Harm that is hard to attribute after the fact is precisely the kind of harm that a precautionary statute should prevent.
4. The Bill must be considered alongside gene technology and ACVM reform
The HSNO Amendment Bill is not occurring in isolation. It sits alongside the Gene Technology Bill and the Agricultural Compounds and Veterinary Medicines Amendment Bill.
Together, these reforms raise significant concerns for organic and GE-free production.
The Gene Technology Bill proposes a major shift in the regulation of genetic technologies. The HSNO Amendment Bill changes how new organisms and hazardous substances are assessed. The ACVM Amendment Bill changes pathways for agricultural compounds and veterinary medicines, including products already approved overseas.
Soil & Health is concerned that the combined effect of these bills could create regulatory gaps. Products involving genetic technologies, biological controls, microorganisms, RNA-based tools, nano-delivery systems, agrichemicals, veterinary medicines, novel biological products or chemical-biological combinations may move across regulatory boundaries in ways that are difficult for farmers, consumers, certifiers and the public to understand.
The Committee should not assess the HSNO Amendment Bill as a narrow technical efficiency update. It should ask how the Bill interacts with the wider reform package and whether the overall framework remains protective enough for food, farming, biodiversity, organics and GE-free production.
5. New Zealand assessment must not be outsourced
The Bill places considerable weight on the use of overseas regulatory assessments.
Soil & Health does not oppose the EPA considering high-quality international information. International science can be useful. However, overseas decisions must not substitute for full and independent New Zealand assessment.
New Zealand is not simply a branch office of overseas regulators.
New Zealand has distinct environmental, cultural, agricultural and market conditions, including:
An approval granted in North America, Europe, Australia or elsewhere cannot automatically account for New Zealand conditions.
Regulatory decisions should be informed by international science, but never outsourced to overseas regulators.
If overseas assessments are used, the Act should require that they are only one source of evidence. The applicant should still carry the burden of proving safety and suitability in New Zealand conditions. The EPA should be required to publish how it used overseas information, what New Zealand-specific assessment was undertaken, and what uncertainties remain.
The public should not be required to prove, after the fact, that a substance or organism is unsafe for New Zealand conditions.
6. The burden of proof must remain with applicants
The burden of proof should remain firmly on applicants seeking approval to introduce hazardous substances, new organisms or novel technologies into New Zealand’s environment, food systems, waterways and communities.
Soil & Health is concerned that reliance on overseas approvals, narrowed assessment pathways, rapid approvals and temporary approvals may shift the practical burden away from applicants and onto the public, affected neighbours, organic producers, iwi, communities and environmental groups.
That would be wrong.
The applicant seeks the commercial benefit. The applicant should carry the evidential burden and the risk.
The public should not be required to prove that a product is unsafe after approval has already occurred. Organic producers should not be required to prove why their markets and certification need protection after contamination has already happened. Iwi and hapū should not have to prove that whenua, wai, taonga species and mahinga kai matter after exposure has occurred.
If uncertainty remains regarding persistence, chronic toxicity, endocrine disruption, cumulative exposure, food-chain effects, microbiome impacts, non-target species effects, soil effects, water effects or ecosystem consequences, that uncertainty should weigh against approval rather than in favour of speed.
7. “Significant effects” must not be narrowed too far
Soil & Health is concerned about any narrowing of “significant effects” so that an international pathway turns mainly on whether an objector can identify effects that are specifically New Zealand-specific and not already addressed overseas.
Such an approach risks creating a presumption that overseas conclusions are correct unless New Zealand-specific concerns can be demonstrated by the public or affected parties.
The precautionary approach requires the opposite.
Where uncertainty exists, decision-makers should require robust evidence demonstrating safety before approval is granted.
“Significant effects” should be defined broadly enough to include:
A narrow test may improve administrative speed, but it would not improve environmental protection.
8. Temporary approvals can create permanent harm
Soil & Health is particularly concerned about the proposed temporary hazardous substances approval pathway.
Temporary approval can still create permanent consequences. Even short-term use can result in:
Once a product has been used in soil, water or open environments, exposure cannot simply be unwound. Once residues move through waterways, drift onto neighbouring land or enter compost, manure, silage or food-chain pathways, subsequent regulatory action may not reverse the damage.
A “temporary” approval may create permanent consequences.
This is especially concerning for agrichemicals, because these products are designed to be released into the environment. It is not enough to say that a full assessment will occur later if exposure has already happened.
If the Committee retains any temporary approval pathway, Soil & Health asks that it include at least the following safeguards:
9. Speed is not a substitute for good regulation
The policy material repeatedly identifies delay as a problem requiring correction.
Soil & Health accepts that regulatory delay can create real costs. However, the assumption that faster approval is always better is not sound in the context of hazardous substances and new organisms.
In environmental regulation, the consequences of approving a hazardous substance too quickly are often borne by others:
The economic costs of delayed approvals are usually visible and immediate. The environmental costs of premature approvals are often delayed, diffuse and irreversible.
That does not make them less important.
HSNO should not become a system in which uncertainty is increasingly tolerated in the pursuit of economic opportunity.
10. The Bill risks privatising benefits and socialising risks
One of the most troubling features of the proposed reforms is the potential transfer of risk.
The commercial benefits of approval flow primarily to:
When things go wrong, however, the costs are often borne by:
This creates a profound imbalance.
The private sector captures the upside. The public carries the uncertainty.
The HSNO framework should prevent this imbalance, not enable it.
Soil & Health therefore asks that the Bill include a clear polluter-pays principle. Applicants and approval holders should be responsible for monitoring, containment failure, contamination, clean-up, certification loss and market loss caused by products approved under accelerated or temporary pathways.
11. Emerging technologies require greater caution, not less
New and emerging technologies are rapidly changing the landscape of agricultural and environmental interventions.
These include:
Many of these technologies are promoted as precise, targeted, lower residue and environmentally benign.
History teaches caution.
Asbestos, DDT, PCBs, PFAS compounds, neonicotinoids and numerous other technologies were once promoted as useful solutions. Only later were broader environmental and health consequences understood.
Regulators must remain humble in the face of scientific uncertainty.
Products using nanoparticles, lipid nanoparticles, nano-carriers or other nano-enabled delivery systems can behave differently from conventional formulations. They may alter persistence, uptake, transport, toxicity, cell penetration, bioavailability and environmental movement. The same concern applies to RNA-based or gene-silencing products, especially where they are delivered through sprays, microbial systems or nano-carriers.
The Bill should not allow products to receive reduced scrutiny because they are described as “targeted”, “biological”, “low residue”, “innovative” or “approved overseas”. These descriptions are not substitutes for evidence.
12. Example scenario: RootSilence-R
A plausible future example illustrates the risk.
Imagine a product called RootSilence-R. It is a spray containing lipid nanoparticles carrying RNA-based gene-silencing material designed to suppress a fungal pasture pest.
The product receives conditional approval overseas. It is promoted as targeted, innovative and low residue.
Under a more permissive HSNO pathway:
By then, the product has already delivered financial benefits to its developers and users.
The risks have been transferred to everyone else.
The question Parliament must ask is simple:
Who should carry the burden of uncertainty?
The applicant seeking commercial gain?
Or the public, organic producers, tangata whenua and environment that receive no opportunity to consent?
Soil & Health’s answer is clear: the burden must remain with the applicant.
13. Public participation and transparency must be protected
Public participation is not an administrative obstacle. It is a safeguard.
Soil & Health is concerned that too much detail may be moved into regulations, notices, guidance or discretionary processes. That risks reducing Parliamentary scrutiny and public visibility.
Key protective thresholds should remain in the Act. Public notification and hearing rights should be retained where approvals may affect communities, ecosystems, organic producers, iwi, food systems and future generations.
The Act should require public notification where an application may involve:
The people and ecosystems affected by approval decisions must have a meaningful opportunity to be heard before exposure occurs, not after harm is suspected.
14. Power should not drift away from Parliament
The Bill and related policy material move significant operational detail into regulations, notices, ministerial determinations and administrative processes.
Delegation can improve administrative efficiency. However, environmental protections should not depend primarily on the discretion of whichever Minister, Director-General or agency happens to hold office at a particular time.
Fundamental safeguards belong in legislation debated openly by Parliament.
The greater the environmental risk, the greater the need for democratic accountability.
Soil, water, pollinators, neighbours, organic producers and future generations should not be protected only by later regulations, unpublished modelling assumptions, overseas decisions or administrative discretion.
The protective threshold belongs in the Act itself.
15. Māori interests and Te Tiriti obligations require more than technical consultation
Hazardous substances and new organisms can affect whenua, wai, mahinga kai, taonga species, biodiversity and intergenerational relationships with the natural world.
Soil & Health asks the Committee to ensure that Māori participation is active from the outset and not reduced to a technical consultation step.
Where applications may affect Māori interests, decision-making must provide for meaningful engagement with iwi, hapū and Māori organisations, and must give proper weight to mātauranga Māori, tikanga, whakapapa and kaitiakitanga.
The Bill should not allow accelerated pathways to bypass these obligations.
16. Organic and GE-free production need explicit protection
The use of genetically engineered organisms and their derivatives is prohibited in organic production systems. This includes seeds, animals, propagation material and farm inputs such as fertilisers, soil conditioners, vaccines and crop protection materials.
Organic certification is therefore directly affected by any regulatory change that increases the likelihood of environmental release, contamination, unclear product status, weak labelling, weak traceability or reduced assessment of hazardous substances and novel technologies.
For organic and GE-free producers, contamination can mean:
It is not acceptable for the costs of contamination to fall on the producer who did not use the product.
Soil & Health asks that the Bill include explicit recognition of organic and GE-free production as affected interests in relevant HSNO decisions.
The EPA should be required to consider:
Organic and GE-free producers should not be treated as afterthoughts in a system that could directly affect their certification, livelihoods and markets.
17. Compliance, monitoring and reassessment must be strengthened
If the Bill creates faster pathways, it must also strengthen monitoring and accountability.
Approvals should require:
Without monitoring, the system may approve products quickly but detect harm too late.
18. Specific amendments sought if the Bill proceeds
Soil & Health’s primary position is that the Bill should not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be amended to achieve the following:
19. Conclusion – Relief Sought
The purpose of HSNO is to protect New Zealanders, our soils, our waterways, our biodiversity, our food systems and future generations from avoidable harm, not to accelerate hazardous substances and new organisms into the market, not to accelerate hazardous substances and new organisms into the market.
Soil & Health asks the Primary Production Committee to recommend that the Hazardous Substances and New Organisms Amendment Bill does not proceed in its current form.
If the Committee proceeds with the Bill, Soil & Health asks that it be substantially amended as per our submission, to keep the burden of proof on applicants, protect organic and GE-free production, retain meaningful public participation, uphold Te Tiriti obligations, require independent New Zealand assessment, explicitly address new and emerging technologies, and keep precaution, environmental protection and human health at the centre of the HSNO Act.
Documents and sources considered
This draft was prepared with reference to the following materials:
Organic Week returns with online events on soil, food and health
/in Farming, Farming and Horticulture, Food, Health, Health and Food, Media Releases, Organic WeekMedia release
29 April 2026. New Zealanders are invited to take part in Organic Week 2026, a nationwide series of online events running from 1 to 10 May, focused on healthy food, healthy soil and healthy people.
Led by the Soil & Health Association of New Zealand, this year’s programme brings together farmers, health experts and food advocates for a week of webinars, interviews and community discussion.
The online series is designed to make organic knowledge accessible for everyone, from seasoned organic growers to those just starting to explore organic living.
Soil scientist Charles Hyland, chair of Soil & Health, says a key part of this year’s Organic Week is helping people understand the connection between soil, food and wellbeing.
“Healthy soil supports everything – from the food we eat to the resilience of our environment. Organic Week gives people the chance to hear directly from those working with nature and within our food systems to learn practical ways to apply that knowledge,” he says.
The programme begins with an online Organic Café on Saturday 2 May at 10am, offering an informal space for people to connect, share ideas and hear what is ahead for the week.
A webinar on Monday 4 May at 7pm will focus on dung beetles, with experienced pastoral farmers including Stephen Newman, founder of Kaipara Regenerative Farming Group and Paul Candy from Future Ready Farms sharing how these insects improve soil fertility, manage animal waste and reduce nutrient run-off.
On Wednesday 6 May at 7.30pm, a session titled “What’s behind the label?” will help consumers better understand food labels, ingredients and certification. The speakers are Alison White from the Safe Food Campaign and Sarah Reddington from Low Toxin Rabbit, with facilitation by Organic NZ editor Philippa Jamieson.
Health and wellbeing are also part of the line-up. On Thursday 7 May at 7pm, nutritional therapist Paula Sharp will discuss gut health and how to support the microbiome through food and lifestyle.
The final session on Friday 8 May at 7pm features Hawke’s Bay artist and advocate Kate White, offering a fresh perspective on rooks and their role in farming systems, challenging the view of the birds as pests and exploring their place in a functioning ecosystem.
In addition, others have come on board offering in-person events including workshops and film screenings around the country.
The Soil & Health Association of New Zealand, established in 1941, is one of the world’s oldest organic organisations and continues to advocate for systems that support long-term environmental and human health.
“Organic Week is about connection – between people, ideas and the natural systems that sustain us. We welcome anyone who wants to be part of that conversation,” says Philippa Jamieson, editor of Organic NZ.
All interviews will be screened online and later made available via the Soil & Health Association’s YouTube channel, with webinar recordings released in late May.
ENDS
About us
The Soil & Health Association is the largest membership organisation supporting organic food and farming in New Zealand and one of the oldest organic organisations in the world, established in 1941. We are committed to advocating our maxim “Healthy soil – healthy food – healthy people, Oranga nuku – oranga kai – oranga tāngata” and to creating an organic New Zealand.
More information
More information on Organic Week 2026 available here.
Full schedule available here, including links to register for events.
Please reach out for interview opportunities with our spokespersons!
Media contact
Rebecka Keeling
Communications, Soil & Health Association of New Zealand
rebeckakeeling@gmail.com
UPDATE: Te Henga Wetland Spraying with Glyphosate
/in Campaigns, GlyphosateThe following is an email sent by our Chairperson, Charles Hyland, to the Parliamentary Commissioner for the Environment and also the original attached documents for your perusal:
Kia ora Parliamentary Commissioner for the Environment,
I am writing to request your office’s independent scrutiny and guidance on the use of glyphosate and surfactant spraying in sensitive wetlands in a way that, in my technical experience, appears inconsistent with how these products are intended and expected to be used. Te Henga is a timely case study with wider implications for wetland protection and good practice.
Attached are two documents from the Soil & Health Association of New Zealand regarding the resumption of herbicide spraying at Te Henga Wetland, including reports of drone application:
We appreciate your office is not an enforcement agency. Our intent is to support independent scrutiny and, where appropriate, clearer national guidance that lifts practice and reduces the likelihood of repeat harm.
I am available for a call to answer questions or provide any additional context.
Ngā mihi nui,
Charles Hyland
Chair
Soil & Health Submission on the Natural Environment Bill 2025
/in Campaigns, Farming and Horticulture, Freshwater, Submissions, WaterIn March we made a submission on the Natural Environment Bill 2025 and the related Planning Bill 2025, to voice our concerns with aspects of both bills, as we strive to raise important issues in our role as advocate for the protection and regeneration of soil, freshwater, ecosystems, and environmental health, for the benefit of all.
As there were a large number of submissions to be heard we unfortunately didn’t get the opportunity to present our views however the submission document is made available for you to download and/or view below.
We will keep you informed of developments as they come to hand.
Te Henga Wetland
/in Campaigns, Freshwater, Glyphosate, OrganicsTechnical Review of Herbicide Use and Risks
Charles Hyland, Chair, Soil & Health Association of New Zealand
26 Sept 2025
Executive summary
Two herbicide products have been reportedly used at Te Henga wetland: Polaris 450 (a 450 g/L glyphosate isopropylamine salt formulation) and Aquakynde (an anionic surfactant adjuvant). (Matuku Link)
[UPDATE March 2026: herbicide spraying again being undertaken – Waatea News]
The Environmental Protection Authority (EPA) approval for Polaris 450 (HSR000227) classifies the product as harmful if inhaled (H332), causes serious eye irritation (H319), and toxic to aquatic life with long-lasting effects (H411). The Polaris 450 Safety Data Sheet (SDS) also instructs users not to allow the product to enter waterways.
Aquakynde carries serious eye damage (H318) and aquatic harm (H402/H412) classifications; its active surfactant chemistry (e.g., sodium alkylbenzene sulfonate types) is known to be harmful to aquatic organisms at low mg/L levels.
Under New Zealand’s Hazardous Substances regime, most agrichemicals with aquatic hazards must not be applied into or onto water. For Polaris 450 specifically, the EPA has replaced the usual “no application into or onto water” rule with special “water application” controls: if application into or onto water is contemplated and the water could leave the application site, then the strictest aquatic controls apply (treated “as if” Aquatic Acute Category 1).
The Auckland Unitary Plan (AUP) E34 Agrichemicals adds local requirements on spray-drift management, setbacks, operator competence, and record keeping, with wetlands clearly treated as sensitive receiving environments.
Wetlands are intrinsically high-exposure settings: spray drift, wash-off, and hydrologic connectivity funnel herbicide–surfactant mixtures into standing water and saturated sediments with long residence times. Glyphosate binds to sediments and is microbially transformed into aminomethylphosphonic acid (AMPA), which can persist. A large literature shows that aquatic toxicity of glyphosate-based products is often driven by the surfactant system, not glyphosate alone, with amphibian eggs and larvae particularly sensitive at low mg/L concentrations.
Bottom line: Spraying in, over, or immediately adjacent to standing water in a wetland creates a high-risk exposure pathway that is difficult to keep compliant and is readily avoidable.
A precautionary pause, an independent compliance audit, switching to non-spray or contact-limited methods, and basic monitoring are warranted.
Photo: Te Henga wetland, Auckland Council
Products and hazards
Polaris 450 (glyphosate IPA, 450 g/L). EPA approval HSR000227 classifies Polaris 450 as H332, H319 and H411; its SDS further cautions “Do not allow product to enter waterways.” (Horticentre Group)
Aquakynde (anionic surfactant adjuvant). The attachment provided identifies serious eye damage (H318) and aquatic harm (H402/H412) with an anionic surfactant (e.g., benzenesulfonic acid, C10–13-alkyl derivatives, sodium salts; CAS series including 68515-73-1 / 68411-30-3). Representative SDS documents for these surfactants report fish LC50 ≈ 1.7 mg/L and Daphnia EC50 ≈ 2.9 mg/L, consistent with Aquatic Chronic hazard classifications. (Alconox)
Mixture concern. When glyphosate formulations are tank-mixed with additional surfactant, the overall aquatic hazard typically increases compared with glyphosate alone because surfactants can drive toxicity and membrane permeability in aquatic organisms. (PubMed)
Legal and planning framework (national and regional)
Implication for Te Henga: Even where “water application” may be contemplated under HSR000227, meeting the strict controls and AUP E34 expectations in a complex wetland is demanding, and label instructions (e.g., do not allow to enter waterways) still apply. (Horticentre Group)
Wetland exposure pathways
In Te Henga’s mosaic of pools, drains, and saturated peat, likely exposure routes include:
What good compliance should already cover
Health and ecological science relevant to decisions
Findings specific to Te Henga
ABOVE: Pāteke (brown teal) at Tiritiri Mātangi. In 2015 pāteke were reintroduced to Te Henga wetland. Photo: Sabines Sunbird
Recommendations
Requests to the Parliamentary Commissioner for the Environment (PCE)
Notes on the Safety Data Sheets
Scope and limitations
This review integrates product hazard information, New Zealand regulatory requirements, and peer-reviewed evidence on wetland exposure and toxicity, interpreted for Te Henga. It does not reconstruct field practices or verify on-site conditions. For a complete compliance assessment, obtain work plans, spray diaries, weather/wind records, equipment and operator certificates, GPS traces, and pair these with site inspections and basic sampling.
References
a) Alconox SDS (Sodium alkylbenzene sulfonate; fish LC50 1.67 mg/L; Daphnia EC50 2.9 mg/L). https://alconox.com/wp-content/uploads/2020/07/Alconox-SDS-english.pdf
b) Forders SDS (Sodium C10–13 alkylbenzene sulfonate; aquatic toxicity section). https://www.forders.fi/storage/product_files/0/157140-157104_KTTeng.pdf
Soil & Health Submission on the ‘Draft Inputs Notice for Generic Substances’
/in Organics, SubmissionsMPI opened consultation in relation to its intention to develop a system to manage inputs under the Organic Products and Production Act 2023.
The deadline for consultation submissions closed on November 7th and the documents submitted by us are available for you to download or view below:
Draft Inputs Notice for Generic Substances – submission document (PDF)
Draft Inputs Notice Generic Substances – submission spreadsheet (XLXS).xlsx
For more information in relation to this issue visit the MPI website consultation page.