11 June 2018
Ministry for Primary Industries
PO Box 2526
Wellington 6140
Submission on MPI Discussion Paper N0: 2018/19
Background
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organization supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
Introduction
2. Soil & Health welcome the opportunity to comment on the MPI Discussion Paper “Would New Zealand benefit from new organic regulation?” (“Discussion Paper”). However, we are concerned that the consultation and submission period was both at short notice and for a relatively short time. Organisations throughout the sector will have had difficulty to have appropriate discussions among their members and members including both consumers and organic licensees. We reserve the right at Select Committee and further consultation to further refine our position.
- To know our food is safe, free from contamination and harmful residues is a fundamental human right. However, the right to know exactly what we are eating is often taken away and even routinely denied to us. While growing our own food remains the best way to ensure that we know what we are eating and how it is grown, we must also know what has been sprayed onto crops and soil, added to foods, and used in the processing of the food we purchase. There is a growing awareness in society of how food determines health and people are now demanding to know what is in their food and how it is grown. Safeguards to protect people and the environment are becoming more important and need greater attention as the presence of toxins in the environment become more common.
- Soil & Health is committed to advocating for transparent and honest food labelling in New Zealand. We believe that transparent food labelling is fundamental in allowing people to make informed choices. We believe that everyone has a right to safe and nutritious food that is grown in a way that enhances the environment. This covers the right to have food free from microbial contamination, harmful organisms, pesticides, harmful chemicals and heavy metal contaminants, harmful additives, irradiation and genetic engineering. We believe in the right of people to equip themselves with the knowledge to make informed food choices. This is only achievable through clear and transparent food labelling.
- Soil & Health as an organisation that advocates for organics, is a strong supporter of organic certification as it provides a verification system for consumers that ensures that the food product they are purchasing is produced according to specific organic standards. Consumers can trust food or other products that are labelled as certified organic, because they are subject to rigorous audits to ensure their safety and integrity. Most importantly it helps to ensure that businesses do not deceive or mislead consumers through false representation or false information when labelling themselves as organic. We consider certification important as it supports consumers in making informed choices about organic food.
- Currently there are several different organic certification agencies in New Zealand which all have their own standards and labels. Labels however can be confusing for consumers as there can be many different ones used on food products, for example, regulated and accredited ones like the Heart Foundation tick, or some companies creating labels such as ‘vegan’ or ‘100% natural’. As stated in the Executive Summary of the Discussion Paper, consumers have a mixed understanding about what these claims mean. People want clean, safe food, and are increasingly turning to organic foods and products. Many farmers and producers are responding to demand and producing high quality, certified organic products. But there are a few producers claiming their products are organic when in fact they are not. Some producers may be unintentionally misleading consumers; others may be deliberately using the word organic as part of their marketing strategy to sell more product and/or at a higher price. While consumers are protected by the Fair Trading Act 1986, which requires producers to be able to substantiate any claims that they are making on their products, the absence of a single definition in New Zealand of what organic means makes enforcement difficult. Furthermore, with no government oversight of organic standards, and no national standard to protect the word ‘organic’, the integrity of the organic industry as a whole is compromised.
- Soil & Health therefore strongly supports the proposal to introduce a mandatory National Organic Standard and associated regulatory regime for organic production. A fundamental point for Soil & Health in developing a single National Organic Standard is to reduce consumer confusion that is created when there are multiple certification agencies. Creating a single National Organic Standard for organics in New Zealand would help to reduce consumer confusion and boost consumer confidence in organic labelled food. It would also put us in step with nearly all of the top 25 organic exporting nations. This will give comfort not only in New Zealand but to export markets as well and will make exports easier.
- However, regulations which would follow adoption of a single National Organic Standard should not disadvantage small growers. While all relevant businesses should comply with the National Organic Standard there should be provision for a lesser burden of verification on smaller scale growers and producers where the cost would be disproportionate to the benefit. We therefore support exemptions that support smaller growers and produces who typically supply local markets and direct to their consumers. We recognise that among the myriad of reasons for supporting smaller producers is the fact that before big producers were big they generally were small, and we must support them in order to foster the growth of the organic industry. Effective exemptions must still require a claim of ‘organic’ to be meeting the National Organic Standard, and examples exist for on-line registration, or affidavits of compliance for operators below a certain monetary threshold.
Discussion Paper Questions
Part 1: Introduction, purpose and context
- Do you agree or disagree with the proposed scope? Are there any other products, for example aquaculture products, that should be considered? Please specify.
We generally agree with the proposed scope so long as this is recognised as merely a starting point. However, some aquaculture products, both salmon and mussels, have previously been certified organic in New Zealand, so it is important that aquaculture would be covered by regulation of organics to ensure inappropriate claims are not made.
The scope is currently limited to primary and processed products and we recognise this is a good place to start from as they form a large part of New Zealand’s organic production. However, as the development of the regulations progress other products might need to be included for example, it is also not clear whether cosmetics, body care products and textiles are included in the scope.
- To what extent do you agree with the description of the current context for organics? Please explain why.
We agree. The market information provided is consistent with reports produced by Organics Aotearoa New Zealand. However, the description lacks any information about or acknowledgement of New Zealand’s current GE-free status and the market advantages that this provides. The use of GE or GMOs is prohibited in organic products, and products cannot be labelled certified organic if they contain GMOs. The global Non-GMO market is at US$550 billion,[1] and trends show this is only going to grow.
Of New Zealand’s five key trading partners, three have non-GMO labelling regulations.[2] New Zealand has a market with these countries due to the perception and the fact that no GMO seeds are currently being cultivated in New Zealand. China is the largest trading partner with dairy being the largest single export. In 2014 NZ$5.3 billion of dairy products were exported to China.[3]
What is also important to mention is that organic and sustainable agriculture is the highest value added agricultural market with over US$80 billion worldwide sold as organic in 2014.[4] New Zealand primary industries are looking for ways to export value-added products as they move away from commodity-based trading. The collapse of the dairy industry in 2015 and the rise of tourism as the largest contributor to New Zealand’s GDP indicate an over-reliance on a narrow range of commodities. Federated Farmers sponsored a number of speakers during their national conference on 1-3 July 2015 in Wellington, who shared the view that value added agriculture is important to the resilience of the industry.
- To what extent do you agree with the description of the current regulatory environment for organics? Please explain why?
We agree with the description of the current regulatory environment for organics, namely that they are not regulated at all. One could conclude that MPI’s Official Organic Assurance Programme (“OOAP”) Technical Rules have by default become a national organic export standard. However, the OOAP Technical Rules is an export one and run through MPI with the Organic Export Association of New Zealand. While the process is consultative, it is hardly representative of the wider organic sector in New Zealand and is focused solely on exports.
It must also be noted that over decades the BioGro NZ standard has been run by its Society’s members and licensees who have contributed to its development through standards and certification committees. It has had significant voluntary input and provided a chance to review the impact of decisions on growers, input providers etc. Soil & Health also contributed to this largely as the consumer voice on all boards. However, this process of keeping the standard up to date is is exhausting on resources and the voluntary base.
- Do you agree that this is a good opportunity to change the way organics are currently regulated in New Zealand? In your opinion, what needs to change? Please explain why.
We agree that this is a good opportunity to change the way organics are regulated in New Zealand. The current unregulated environment undermines the credibility of certified organic products produced in New Zealand and this needs to change. Organic licensees, the retail sector and the public are confused and often have a poor understanding of what organic means, or the implications of false claims. Regulation should aim to protect consumers from fraudulent claims and protect producers from unfair competition (products with false claims), thereby building the credibility of organic products produced in New Zealand. There is also an opportunity to rationalise other activities like auditor training, and upskilling, technical development, certification management and to develop a common national mark.
- Do you think that the appropriate objectives for a new organic regime have been identified? What would you suggest a new regime should achieve? Please explain why.
We agree with the objectives outlined however question whether the regulatory regime needs to be flexible.
We consider that the new regime should endorse and protect the status of existing New Zealand certifiers. The regime should enable certifiers to set higher standards (above the regulation) should they want to. It should also allow for equivalency between New Zealand produced and certified imported organic products provided the certification standards are at least equivalent to the New Zealand regulation. Soil & Health strongly supports the Participatory Guarantee Systems such as OrganicFarmNZ to be recognised as a credible certification pathway.
Part 2: Options for how a new regime for organics could work
- Do you think that a standard setting out requirements for production methods would be best suited to organic production? Please explain why.
Yes, because organics also has environmental and sustainability outcomes, not just food safety outcomes. Production methods are important because of the benefits to the environment as well as end product qualities.
Issue 1: Should a new standard be voluntary?
- Do you think that the correct options have been identified? Are there alternative option(s) that should be considered? Please describe.
Yes, we agree that the correct options have been identified. We do not propose any other alternatives.
- Are there positive or negative impacts of any options that are not described? Please describe any impacts that we’ve missed.
Cost is a significant concern to all organic growers and producers but most especially to small-scale growers and producers suppling local markets direct to the consumers. Small-scale growers and producers are important for the support of fresh organic products to New Zealand consumers and therefore any new regulations which would follow adoption of a single standard must not penalise them through unnecessary compliance costs.
The importance of genuine organic consumers expectations needs to be considered in the structure of Standards setting/maintenance body, and stakeholders groups. The importance of the consumer guarantee aspect of organic regulation must be reflected in significant organic consumer representation, which Soil & Health has experience of.
There are a number of overseas examples of standards maintenance groups that have been dominated by business interests that have not reflected genuine organic consumers and licensees’ interests, for example USDA now includes an option for ‘organic’ hydroponic production, although hydroponics by design does not meet New Zealand organic requirements, nor organic consumer expectations that organic production is soil based.
At one consultation, it was suggested that legislation for organic regulation would be likely be ahead of standards group representation being consulted on. It is therefore necessary to ensure that a minimum representation outline is included in the primary legislation to ensure organic consumers will be an effective part of standards setting and maintenance.
- If a standard became mandatory for all organic operations, what would be the positive and/or negative impacts on you or your business?
If mandatory the system should not be designed so that it constrains or prevents alternative certification systems being developed and recognised. A mandatory standard would be acceptable if it allowed for small-scale growers and producers to continue to function without unfair constraints and allowed the opportunity of lower cost Participatory Guarantee System certification.
For an organic consumer guarantee with integrity, the degree of organic consumer representation on the standards setting/maintenance group will potentially dictate either positive or negative outcomes. Soil & Health is probably the most visible advocate for New Zealand organic consumers.
- To what extent do you support or oppose the use of a logo to help distinguish organic products from non-organic products? Please explain why.
We support the development of a national logo provided it can be accessed by local and small-scale market growers and producers, not just larger scale operators that export.
Issue 2: How should we check that relevant businesses meet the standard?
- Do you think that the correct options have been identified? Are there alternative option(s) that should be considered? Please describe.
We consider that the correct options have been identified.
- Are there positive of negative impacts of any options that are not described in the above section? Please describe any impacts that we’ve missed.
No other positive or negative options are suggested.
- If ongoing verification (with limited exemptions) was used to check compliance, what would be the positive and/or negative impacts on you or your business?
As stated previously local and small-scale operators should not be disadvantaged. Costs relating to MPI regulatory requirements in other sectors have frequently been described as prohibitive to small businesses, and although some changes have been made for example raw milk cheeses, there is a strong cost recovery model in existence using high salary and travel fees. Regulation and compliance in that context threatens small producers if exemptions are not set sensitively.
Home gardeners that garden organically and would meet the National Organic Standard, should they be commercial, must also be able to describe their home grown produce as organic, whether sold or not. Such situations could include A&P Show vegetable competitions or descriptions in a newspaper article. Compliance could be by external interests checking against an affidavit or online registration if necessary, and complaints lodged with MPI or the accredited agency.
- If some businesses were not required to be verified on an ongoing basis, what do you think the criteria for exemption could be? For example, method of sale, annual turnover, volume sold, others…
If exemptions are to be allowed, then conditions on which they are based should be clearly defined, for example if there are multiple companies held by a single owner they should not be allowed to all be exempt (all should be verified).
Summary of proposals
- To what extend do you support this combination? Please explain why.
We strongly support the combination of Option 1C: mandatory compliance for all relevant businesses, and Option 2C: ongoing verification, with limited exceptions.
We support Option 1C due to the level of certainty and transparency that it provides to both businesses and consumers about what the definition of organic means. Under this option, whether or not a product is certified, consumers can be sure that if it is labelled organic then it means the same as certified organic as both terms must meet the National Organic Standard. This is significant for consumers who are too often sold products as organic, even though the grower/producer is not subject to any checks that their claim is authentic. If a producer uses the term organic to sell their system should be able to be verified in some way.
However, many of our members are small-scale organic growers and producers who only sell their products locally, direct to their consumers. Their growing and production standards meet that of certification standards, yet they choose not to become certified due to the costs and effort involved. Some growers and producers prefer to remain small-scale and want to keep their costs down in order to keep their products affordable. Certification would be an extra cost that they may not be able to meet unless they scaled up. For them to have to change their labels from “organic” to “spray-free” simply because they are not certified, despite meeting a certification standard, would not be fair on them. We consider that the integrity of certified organic is not compromised by these types of growers using the term organic.
Therefore, we also support Option 2C in that while all businesses that label their products organic would need to comply with the standard, not all businesses would be required to have their activities independently verified on an ongoing basis, or certified. The integrity of organics would still be maintained as any grower/producer, small or large, that defines their product as organic would be subject to enforcement action if it was shown that they were not meeting the standard. We also support the proposal to introduce measures that reduce compliance costs for small-scale businesses if and when needed through for example group certification or by adjusting the audit frequency.
- What changes or impacts would this combination of options involve for you and/or your organisation?
For our members and for consumers of organic products there will be benefits as the baseline standards will be clearly defined.
- What would be your preferred combination of options? This can include any listed options and any other possible option not listed.
We have already stated our preferred option – that being Option 1C and Option 2C.
Part 3: If needed, proposed features of empowering legislation
- Have the powers required to implement a new regime been correctly identified? Are there any other components you think would be necessary?
Those already certified (BioGro NZ/Asure Quality/OFNZ/Demeter) we consider are already following what will become the National Organic Standard – the process for how they become integrated needs to be clear and separate to those not already certified. We consider that MPI should recognise agencies not individuals.
As commented in Q8; At one consultation, it was suggested that legislation for organic regulation would be likely ahead of standards group representation being consulted on. It is therefore necessary to ensure that a minimum representation outline is included in the primary legislation to ensure organic consumers will be an effective part of standards setting and maintenance.
- Do you have any comments on the range of proposed compliance and enforcement tools?
We consider that minor non-compliances should be handled appropriately and be dependent on the level of the organic integrity of their products and the risk to consumer expectations and health.
- Do you have any other comments about the proposed legislation settings?
We consider that the legislation must allow for new certifiers and other certification systems (that can demonstrate compliance to the National Organic Standard) to be recognised. Legislation must include minimum requirements of the structure of standards groups and representation and include an expectation of GMO free food and production.
Part 4: General comments and next steps
- What evidence should be examined to inform further analysis of this proposal?
We consider that the affordability of the ‘product’ in terms of the comparative costings from similar situations should be considered from both export and local market certification options.
Options from overseas, particularly around exemptions, affidavits and online registrations, what financial thresholds or other measures are used.
- If you have any other comments or suggestions, please let us know.
For an organic supply chain there can be several steps (actors handling product) – organic oversight should be sustained along with the whole supply chain.
Yours sincerely
Name: Lucy Blackbourn
Position: Acting General Manager
The Soil & Health Association
PO Box 9693
Marion Square
Wellington, 6141
Website: www.organicnz.org.nz
[1] http://www.prnewswire.com/news-releases/packaged-facts-global-non-gmo-food–beverage-market-reaches550-billion-us-sales-at-200-billion-300127127.html
[2] http://www.stats.govt.nz/browse_for_stats/snapshots-of-nz/nz-in-profile-2015/trading-partners.aspx
[3] http://www.stats.govt.nz/browse_for_stats/industry_sectors/imports_and_exports/global-nz-jun-14/keypoints.asp
[4] https://shop.fibl.org/fileadmin/documents/shop/1698-organic-world-2016.pdf
2019 AGM of the Soil & Health Association
/in Association Meetings and EventsRead the minutes of our 2019 Annual General Meeting.
Submission on Climate Change Response (Zero Carbon) Amendment Bill
/in SubmissionsINTRODUCTION
The Soil & Health Association of New Zealand 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. The Association receives no government or other official support, nor is it sponsored or supported by any commercial organisation, political party, religion or other vested interest.
With every year that passes the vision of Soil and Health of an organic New Zealand becomes more relevant, more imperative, and in fact, more mainstream. The maxim of the organisation is “Oranga nuku – Oranga kai – Oranga tāngata, Healthy Soil – Healthy Food – Healthy People”. This extends into the sphere of climate change, as healthy, living soil is potentially the most important carbon sink our planet has. For planetary health (and therefore our own health) not only must we stop the burning of fossil fuels, but we must change our actions so as to sequester the existing carbon from the air into soil and biomass. Organic and regenerative[1] production methods, which maximise the accumulation of soil organic matter, are key to sequestering atmospheric carbon and keeping global warming within 1.5ºC.
BACKGROUND SCIENCE
This section is aimed not at outlining the climate crisis, which the Bill recognises, but at highlighting the key role that organic and regenerative agriculture can play in ameliorating climate outcomes.
The degradation of soils from unsustainable “conventional” agriculture has released billions of tons of carbon into the atmosphere[2]. It is estimated that the world’s cultivated soils have lost between 50 and 70 percent of their original carbon stock[3]. Conventional agricultural methods, such as the use of chemical biocides and fertilisers, heavy mechanical tillage, mono-cropping and overgrazing, have killed or rendered ineffective a multitude of living organisms within soils, leading to the oxidation of soil organic carbon and its release in gaseous forms. Although classed as “conventional” and therefore normal, these methods of agriculture are new, having arisen only since the “Green Revolution” after the Second World War. In 2019 we have enough evidence that these new ways cannot be continued if we are to survive.
According to soil scientists, at current rates of soil destruction (i.e. decarbonisation, erosion, desertification, chemical pollution), within 50 years we will not only suffer further serious damage to public health due to a qualitatively degraded food supply, but we will literally no longer have enough arable topsoil to feed ourselves[4]. Without protecting and regenerating our arable soils and grazing lands, it will be impossible to feed the world adequately and keep global warming below 1.5ºC.
So we come back to the key focus of the Soil and Health Association: how to grow food in such a way that soil, human and overall planetary health are supported? There is a growing body of research and many examples, from within NZ[5] and from overseas[6], showing how to manage land profitably to meet human needs, while sequestering carbon. These carbon farming methods have been largely ignored as we scramble for solutions to the global climate catastrophe that faces us. For too long, the focus of NZ government has been on offsetting carbon emissions from conventional agriculture by purchasing overseas carbon credits, or planting monocultures of pine trees to sequester carbon within NZ. Of course, we are all in favour of planting more trees, however this does to some extent detract from the opportunities that exist in pastoral, silvopastoral and arable systems. NZ needs to move more urgently in the direction of changing agriculture through appropriate policy and regulation, rather than avoiding the necessary change to appease strong vested interests or maintain lucrative but unsustainable export industries.
OUR POINTS ON THE BILL ITSELF
There are several positive things about the Bill which we wish to tautoko:
Having said this, we believe the Bill has not gone far enough. To limit warming to 1.5ºC, New Zealand has a limit on our total remaining greenhouse gas emissions. Our pathway to net-zero must stay below this limit. The Intergovernmental Panel on Climate Change says this pathway requires carbon emissions to halve by 2030 and reach zero before 2050. Aotearoa New Zealand has the tools to achieve deep emission reductions in the next decade, as long as we have the legislation to back them.
We want this Bill to ensure an emissions pathway that limits our contribution to warming to no more than 1.5ºC. The Climate Commission must ensure we are on the right path, acknowledging New Zealand’s historical emissions. The Bill in its current state will not ensure our contribution to limiting warming to 1.5ºC.
Therefore we wish to propose the following revisions to strengthen its effectiveness:
The Soil & Health Association of New Zealand wishes to speak to its submission.
NZ EXAMPLES OF ORGANIC AND REGENERATIVE FARMS
Biofarm, Palmerston North https://www.facebook.com/pg/BiofarmOrganic/
Bostock’s Organic Free Range Chicken, Hastings https://bostocksorganic.co.nz/
Field to Feast Organics, Christchurch http://www.canterburyorganic.org.nz/field-to-feast-organics/
Grow Together Farm, Rotorua https://www.growtogetherfarm.co.nz/
Harts Creek Farm, Canterbury, http://www.hartscreekfarm.co.nz/
Kotare Village, Wairoa http://kotarevillage.org.nz/regenerative-agriculture/
Lawson’s True Earth, Hastings https://trueearth.co.nz/
Lux Organics, Rotorua https://www.luxorganics.co.nz/
Mangarara Station, “The Family Farm”, Hawkes Bay https://www.mangarara.co.nz/
Milmore Downs, North Canterbury http://www.milmoredowns.co.nz/
Puramahoi Fields, Takaka https://www.puramahoifields.com/
Pikiroa Farm, Te Awamutu
Rainer Ramharter, Lincoln, Canterbury https://www.facebook.com/Ramharter-Organic-Farm-575814699192206/
Six Toed Fox Organics, Tauranga https://www.sixtoedfoxorganics.co.nz/
Spring Collective Organics, South Canterbury https://www.facebook.com/springcollectiveorganics/
Winiata Dairy Farm, Rotorua winiatat@farmside.co.nz, 07 333 2139.
[1] As coined and defined by the Rodale Institute https://rodaleinstitute.org/
[2] https://www.onpasture.com/wp-content/uploads/2017/10/Lal-Soil-carbon-sequestration-to-mitigate-climate-change.pdf
[3] https://e360.yale.edu/features/soil_as_carbon_storehouse_new_weapon_in_climate_fight
[4] https://regenerationinternational.org/why-regenerative-agriculture/?fbclid=IwAR219PNjLCveGhUgdavaefaXNVjrB4DJfik2NN441hwf-lURgj9zkaCjkS0
[5] See the end of this document for a list of organic and regenerative NZ farms.
[6] Toensmeier, E. 2016. The Carbon Farming Solution – A Global Tookit of Perennial Crops and Regenerative Agriculture Practices for Climate Change Mitigation and Food Security. Chelsea Green Publishing, Vermont, U.S.A.
Worried about ‘free-range’ chickens? Choose organic!
/in Food, Health, Media Releases, Organics“The only way to ensure that the chickens you are eating are genuinely free range is to choose organic,” says Marion Wood, co-chair of the Soil & Health Association. “And what better time to start than during Organic Week which is right now.”
She points out that there is no enforceable industry standard for free-range farming. Farms are regularly audited by the Ministry of Primary Industries for food safety standards, but these standards do not relate to auditing free-range farming practices.
“What this means is that the scope of a ‘free-range’ label on your chickens is actually very wide. People think of happy chickens wandering in a field, but the reality is that the label ‘free range’ can be used by farms that confine their hens to small spaces or subject them to overcrowding. In 2014, it came to light that a farmer had been selling cage eggs as ‘free range’ for over two years – something that slipped under the radar because there was no authority checking such claims.”
But if you choose certified organic chickens, says Soil & Health, you know that the hens are looked after and their quality of life guaranteed because the farms are audited every year.
To get BioGro certification, farms must not have more than 10 hens per square metre in fixed housing or 16 per square metre in mobile sheds. Hens must have unrestricted access to outside runs and access to fresh grass or a forage crop containing a diversity of species. Other organic standards are similar.
Marion Wood suggests everyone makes the change in Organic Week.
“Organic food is grown naturally without the routine use of synthetic pesticides or fertilisers. Certified organic chickens are healthy chickens with a good quality of life – something that the label ‘free-range’ alone doesn’t guarantee.”
ENDS
Contact: Marion Wood, 022 032 7122
Photo: iStock/Fotokon
Submission on Dairy Industry Restructuring Act 2001 review
/in SubmissionsIntroduction
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) thanks the Ministry for Primary Industries for the opportunity to comment on the Dairy Industry Restructuring Act 2001 (“DIRA”) review and specifically the ‘Review of the Dairy Industry Restructuring Act 2001 and its impact on the dairy industry’ Discussion Document (“Discussion Document”).
2. Soil & Health is an incorporated society, with charitable status, supporting organic food production established in 1941. It is the largest membership organization supporting organic food and farming practices in New Zealand and is one of the eldest present-day organic organisations in the world. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bimonthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
3. Soil & Health has concerns about a lack of government support for dairy farmers to transition to higher premium organic milk production. We consider that the Government should recognize the economic and environmental benefits of organic milk production for New Zealand; these include higher returns for farmers and less environmental degradation. The changes we therefore seek from the DIRA review are that:
a) Fonterra must be obligated to collect all certified organic milk and in transition to certified organic milk; and
b) Fonterra must be obligated to pay any Fonterra organic milk supplier a minimum of 25% premium above the annual farm gate price, irrespective of location or availability of processing capacity.
Submission
4. Soil & Health understand that the DIRA was enacted in 2001 to facilitate the formation of Fonterra to drive the New Zealand dairy industry’s economic performance in global dairy markets, and to regulate its dominance domestically, for the long-term interests of New Zealand dairy farmers, consumers and the wider economy. However, we consider that this strong focus on economic growth has come at the expense of the environment.
5. We strongly agree with the Discussion Document that, along with economic benefits of the growth of the dairy industry, there have been negative effects on our environment. Such effects include increased greenhouse gas emissions, nitrate leaching, and the expansion of dairy into increasingly marginal land areas. We are pleased to see this acknowledged in the Discussion Document.
6. We share concerns highlighted in the Discussion Document that the DIRA has been encouraging uneconomic and environmentally unsustainable milk production inevitably preventing Fonterra from transitioning to higher value-add processing activities such as organic dairy.
7. It is well known that New Zealand’s freshwater is in a dire state, with a staggering 62% of monitored waterways being unsafe for swimming, and a big factor in this is nitrogen pollution from the increasing intensification of agriculture. The Ministry for the Environment says New Zealand has recently experienced one of the world’s highest rates of agricultural intensification.
8. There is also growing concern about the public health impacts of highdensity livestock production – especially for dairy farming. There are health concerns as nitrate levels in drinking water increase.
9. Nitrogen pollution comes from cow urine and synthetic nitrogen fertilizer diffusing through soils and pasture root zones, so simply planting stream banks and fencing off streams cannot solve this issue.
10. Our concerns are that Fonterra’s focus on economic value growth, primarily from greater volume of commodity production, have made it more difficult for dairy farmers to transition to organic dairy production, and therefore to more environmentally friendly methods of dairy farming.
11. Going organic is part of the solution to fixing polluted fresh waterways in New Zealand. Organic dairy farming involves no synthetic nitrogen fertilizers, lower stock numbers, more biodiversity, and grass-fed cows with no GE feed or palm kernel supplements. Organic farming methods improve the soil biology and soil structure, which means better water retention and less nutrient leaching. Organic and biological farmers make use of natural fertilizers including legumes, instead of soluble artificial nitrogen fertilizers that are more prone to leaching.
12. Organic dairying also has higher animal health outcomes and lower intensity. Some of the profit making of organic dairying and their ability to remain profitable with less volume is because of the reduced veterinary costs because of the reduced animal health issues.
13. Studies have found that a low-input system with fewer cows per hectare and no synthetic nitrogen fertilizer produces the most milk per cow per year. This research also confirms that the low input system is the best environmental performer, the least financially risky, and is most profitable when milk-price payouts are low (Basset-mens C, Ledgard S and Boyes M (2009). Eco-efficiency of intensification scenarios for milk).
14. We support the DIRA in that it is legislation enabling a cooperative and protective approach to market access for many farmers, controlling farmgate milk price to some degree, and because it exists it allows for what could be a legislative environmental gamechanger for dairy in New Zealand.
15. The DIRA however has allowed Fonterra to treat organic farmers poorly over time, including reducing the organic pickup area for paying the organic premium, meaning no premium, even for some of the organic pioneers that helped get the organic dairying underway, because they were beyond the ‘organic hub’. Only when it has suited Fonterra did they reinstate some parts of Taranaki and Manawatu, but overall there has been limited encouragement for new organic transitions beyond its organic hub.
16. Fonterra have made it more difficult to have certified organic dairy farmers in parts of New Zealand away from their prescribed hubs. We understand this has been done for efficiencies however at the same time has resulted in organic dairy growing better outside of Fonterra in New Zealand.
17. Fonterra established its organic programme in 2002 following three years of research and the sector grew strongly. At its peak in 2011, there were 127 dairy farms supplying Fonterra with organic milk. Fonterra had a review and changed its organic policy in the same year. This opened the door to commercial opportunities for new players to fill the supply vacuum. The Organic Dairy Hub Cooperative which is now the third largest supplier of organic milk in New Zealand was incorporated in 2015. Fonterra, Open Country Dairy, Organic Dairy Hub and Marphona Farms which operates Green Valley Dairies, are now the four main suppliers of organic milk in New Zealand (OANZ 2016 Organic Market Report).
18. Consumers worldwide are demanding safe, healthy and more environmentally friendly food, and are prepared to pay for high quality, GEfree, organic dairy products. New Zealand is well placed to provide discerning consumers with an expanding range of organic dairy products to meet their demands, particularly in Asia. The 2018 Organic Market report found that global organic dairy market is currently estimated to be worth about US$17b with a compound annual growth rate of 8% during 2009 to 2016. By 2022 the sector is projected to be worth US$25b the value of organic milk powder being an important contributor (OANZ 2018 Organic Market Report).
19. If Fonterra are obligated to pay farmers the premium for organic milk everywhere, then the co-op will be motivated to process more of the milk
into organic products and do better at marketing the same. DIRA needs to be amended to make it obligatory for Fonterra to be picking up certified organic milk and in transition to certified organic and be paying the premium for it.
Soil & Health’s recommendations
20. Soil & Health considers that government intervention is required to incentivize more sustainable and organic methods of farming. We consider that a shift towards organic farming practices is needed to protect and enhance our environment and our economy.
21. Soil & Health therefore seek that the legislation require that Fonterra must collect all certified organic milk and in transition to certified organic Fonterra milk and pay a 25% premium above the annual farm gate price for it, irrespective of location or availability of processing capacity.
22. Other changes Soil & Health seek are that the DIRA open entry requirements are repealed. As one of the key mechanisms that has facilitated the growth of this industry Soil & Health strongly recommends that the open entry provision be completely removed. For completeness we recommend that open exit be retained so that Fonterra cannot impose any restrictions on farmers who wish to leave Fonterra.
23. Further, with regards to Terms of Supply, Soil & Health recommends that the DIRA be clarified to ensure that Fonterra can provide financial incentives and disincentives to farmers who are performing above or below any element of Fonterra’s Terms of Supply or standards. Being able to use financial incentives and disincentives should include, but not be limited to, issues associated with environment, emissions and animal welfare standards.
Author: Mischa Davis
Position: Policy Advisor
The Soil & Health Association
PO Box 9693,
Marion Square,
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
Law change can support organic dairy and revitalise waterways
/in Farming, Media Releases, OrganicsSoil & Health want Fonterra to collect all certified and in transition to organic Fonterra milk and to pay a premium for it, irrespective of locality.
“We want to see the Government better commit to organic dairy production and therefore more sustainable farming practices,” says Soil & Health National Council member and former Green Party MP, Steffan Browning.
“We consider that a shift towards organic farming practices is needed to protect and enhance our environment and our economy.”
The Ministry for Primary Industries is undertaking a comprehensive review of the Dairy Industry Restructuring Act which includes looking at incentives or disincentives for the dairy industry to transition to higher-value dairy production and processing that global consumers seek for a premium, and more sustainable environmental practices on and off-farm.
Soil & Health has submitted to the MPI review.
There is growing public concern about the environmental impacts from intensive dairy farming, especially in relation to water quality and human health. Certified organic dairy farming however prohibits the use of synthetic nitrogen fertilizer, has lower stock numbers, more biodiversity, higher animal health outcomes, grass-fed cows with no GE feed or palm kernel supplements, and is generally less intensive than conventional dairy farming.
Consumers worldwide are demanding safe, healthy and more environmentally friendly food, and are prepared to pay
for high quality, GE-free, organic dairy products. The 2018 OANZ Organic Market report found that the global organic dairy market is currently estimated to be worth about US$17b. By 2022 the sector is projected to be worth US$25b, the value of organic milk powder being an important contributor.
To meet the demand, Soil & Health says that government intervention is required to incentivize more organic dairy farming.
“Overall there has been limited encouragement for new organic transitions,” says Browning.
“To help farmers make the transition to organics, we would like to see the legislation require that Fonterra collect all certified organic and in transition to certified organic milk and pay a premium above the annual farm gate price for it, irrespective of location or availability of processing capacity.”
ENDS
Media contact
Steffan Browning
Soil & Health National Councillor
021804223
Christmas comes early for the Organic Sector
/in Food, Health, Organics“This is an amazing Christmas present for the organic community and we’re delighted”, says Bailey Peryman, Co-Chairperson for the Soil & Health Association, welcoming the Government’s announcement to progress with a national standard for organic production next year.
“People want clean, safe food, and are increasingly turning to organic foods and products but it’s difficult to be sure that they really are organic. This legislation can provide certainty to everyone and build a clear definition of what the word ‘organic’ actually means.”
The national standard also opens a constructive forum for discussing the differences in practices across New Zealand. We recognise that there are a small number of organic practices and inputs that are currently certified that other producers might consider harmful for stock and the environment. It is critical that we focus on the qualitative outcomes for people – providing clear information about what is in our food and accurate labelling to guide families in making good food choices.
New Zealand is presented with a great opportunity to learn from the failures of organic regulation overseas. Primarily, that regulation needs to be managed by producers and consumers to maintain the integrity of organics within the standard.
Soil & Health has a long history of campaigning for these standards. It cautions that the adoption of a single National Organic Standard is holistic and must not disadvantage small growers and local markets.
“Many of our members are small-scale organic growers and producers who only sell their products locally, direct to their consumers and choose not to become certified due to the costs and effort involved. While all relevant businesses should comply with a new National Organic Standard, the framework of regulation needs to be proportional so not to unfairly disadvantage anyone” says Peryman.
“We are looking forward to working with Government and the sector to draft legislation which ensures that the oversight and integrity of organics is being upheld for the benefit of all”.
Bailey Peryman
Co-Chair, Soil & Health Association
021 122 7638
bailey@organicnz.org.nz
advocacy@organicnz.org.nz
Photo: iStock ID:184813025
Where’s our food from? Better labelling a step forward
/in Food, Media ReleasesSoil & Health welcomes the passing into law of the Consumers’ Right to Know (Country of Origin of Food) Bill. The Bill, which requires food to carry country of origin labelling, passed with near unanimous support last night in Parliament. While footwear and clothing must be identified where they’re from, until now country of origin of food labelling has only been voluntary in New Zealand.
The Bill was a first introduced in 2016 by former MP, and now Soil & Health National Council member, Steffan Browning, as a Green Party Member’s bill.
“Transparent food labelling is fundamental in allowing people to make informed choices. Mandatory country of origin labelling is a step towards allowing consumers to do this,” says Steffan Browning.
The Bill however only applies to single ingredient foods such as fresh fruit, meat, fish and vegetables and Soil & Health says foods of multiple origins should be labelled too. This requirement could be brought in later through the setting of Fair Trading Act regulations.
“The Bill is a building block to more comprehensive food labelling requirements,” says Browning.
Soil & Health is also concerned that several single origin foods have been excluded from the Bill, including flour, oils, nuts and seeds.
“We particularly want flours and grains included, as most of the soy and maize products from the US are genetically modified. It’s absolutely necessary we have GE food labelling, but in that absence of enforcement we should at the very least be able to choose what country maize and soy products are from,” says Browning.
There has been widespread support for country of origin labelling. A survey conducted last year by Consumer NZ and Horticulture NZ found that 71% of Kiwis want mandatory country of origin labelling and 65% said they looked for country of origin labelling when they were shopping.
“There are many reasons why consumers want to know which country their food comes from. Some want to avoid GE food, food with pesticide residues, or food coming from countries with poor labour conditions or environmental and animal welfare standards,” says Browning.
Soil & Health has been campaigning for mandatory country of origin labelling for over a decade, since the government opted out of joining Australia in mandating country of origin labelling under the Food Standards Code on the grounds it would be an impediment to trade.
[ENDS]
Media contact:
Steffan Browning
021804223
Community Support for a GE-free Coastal Marine Area in Northland
/in GEMedia release: Soil & Health Association of NZ
30 October 2018
Usually associated with land-based farming, the Soil & Health Association is now wading into the coastal marine area in its latest bid towards an Organic Aotearoa New Zealand.
A precautionary approach is needed to any genetically engineered (genetically modified) organisms that may be trialed or used commercially in the Coastal Marine Area (CMA), says Soil & Health.
The Association is therefore encouraging the Northland Regional Council to adopt precautionary provisions for GMOs in the Proposed Regional Plan for Northland, and is presenting its case to the Council today. (Soil & Health’s submission can be viewed at https://soilandhealth.org.nz/submissions/submission-on-proposed-regional-plan-for-northland/)
“We want to ensure that the Council adequately protects growers and producers in Northland from the significant adverse effects posed by GMO use,” says Soil & Health co-chair Bailey Peryman.
The Proposed Regional Plan for Northland as currently drafted fails to regulate GMOs in the CMA, despite the Northland Regional Policy Statement placing an obligation on the Council to take a precautionary approach to GMOs in the region.
“We call on the Northland Regional Council to follow the lead of Auckland Council which has already adopted precautionary provisions and banned the outdoor release of GMOs in the CMA via the Auckland Unitary Plan,” says Peryman.
GMOs in the CMA could threaten the economic sustainability of a wide range of activities that benefit from having GE-free status. This includes organic and non-organic primary producers in the Northland Region, including oyster farmers, and any growers who collect seaweed from the coastline for fertiliser.
“Organic certification standards prohibit the use of any input containing GMO material. A certified organic farm could be contaminated by GMOs in the CMA by using seaweed harvested from the coastline. The composting of seaweed is a popular form of natural fertiliser for crops for many organic farmers. Any GE contamination from seaweed would mean having to stop harvesting seaweed for fertiliser use or otherwise risk losing their organic certification.”
“Aquaculture is a growing industry in New Zealand with exports to nearly 80 countries and our seafood regarded as some of the best in the world. Markets around the world don’t want seafood products that are contaminated with GMOs,” says Peryman.
“All New Zealand fish and shellfish products currently enjoy GE-free status. But contamination of kai moana by GMOs could mean the loss of the premium that the GE-free status and reputation attracts.”
“New Zealand has already seen several GE field trials breach the conditions of approval,” says Peryman. “GMOs in the CMA run additional risks due to the fluid nature of the marine environment, making buffering and containment impossible. We have to also expect that activities in the CMA can cross into terrestrial and freshwater ecosystems.”
If GMOs were released into the Northland CMA it would no longer be regarded as a GE-free region. This could affect the marketing of products within New Zealand and internationally, and premium returns.
The latest OANZ Organic Market Report 2018 reaffirms that the growth in New Zealand organic production and exports is very strong, reflecting global trends. It makes sense economically and environmentally to protect and encourage organic primary production.
ENDS
Media contact
Bailey Peryman
021 1227 638
EPA must reassess glyphosate and neonics
/in Media ReleasesWednesday 17 October 2018
PRESS RELEASE FOR IMMEDIATE RELEASE
The Soil & Health Association is calling for an enquiry into the independence of New Zealand’s Environmental Protection Authority (EPA), following the EPA’s announcement of priority chemical reassessments for possible bans or new controls.
“While Soil & Health welcomes the reassessment list, there is a glaring omission of two notable harmful chemicals. We want them added to the list, and we want an inquiry into the processes and decision-making that has led to this,” says Soil & Health co-chair Bailey Peryman.
The chemicals that should be on the list for reassessment are:
Both are heavily used in New Zealand, meaning most people have some exposure to them.
“The EPA must add them to the list and urgently conduct robust independent reassessments of them.”
“To give the community trust in the regulatory system, Soil & Health calls on the EPA to adopt a precautionary and proactive approach around glyphosate-based herbicides like Roundup, instead of its apparent economics-first approach that favours the agrichemical industry over the environment and people’s health.”
“For true environmental protection, the EPA should follow the EU Commission recommendations, which are to minimise glyphosate use in public places such as parks, playgrounds and gardens, and to scrutinise its use as a pre-harvest spray on a number of crops.”
“Christchurch City Council has shown that a transition to glyphosate-free public spaces is possible, and in New Zealand and internationally, organic farmers successfully manage crops without the need for glyphosate herbicides or the bee-killing neonicotinoids, improving environmental, worker, and food safety outcomes.”
“Consumers’ interest in food grown free from synthetic pesticides is rapidly growing both here in Aotearoa and internationally.”
Media contact:
Bailey Peryman
021 122 7638
ADDITIONAL INFORMATION
In March 2015, the International Agency for Research on Cancer (IARC) issued a report labelling glyphosate a “probable carcinogen”. Europe has since come out strongly against the use of both glyphosate and neonicotinoids. Recently in a landmark court case in the US, Monsanto was found to be misleading consumers about the safety of its flagship product, Roundup – the primary ingredient of which is glyphosate.
Following the IARC finding, the NZ EPA and the Ministry for Primary Industries (MPI), contrary to a Ministry of Health recommendation not to, did a poor review of that finding, essentially using flawed science guidelines and data provided by industry. Some industry-supplied glyphosate research has been shown to be ghost-written by Monsanto.
“In Australia, following a Four Corners TV showing of the Poison Papers last week, exposing how Monsanto influences regulators, the Federal Opposition there is calling for an inquiry into the funding and independence of its APVMA (Agricultural Products Veterinary Medicines Authority), the equivalent of New Zealand’s MPI agrichemical products arm and our EPA.”
New Zealand regulators need to be investigated for the same reasons, according to Soil & Health.
Using its new Flexible Reassessment Categorisation Screening Tool (FRCaST), theoretically based on risk to people and the environment, the EPA said it would prioritise 40 chemicals from an initial list of more than 700, most of them used in agriculture although some are also used around the home. However, questions of the effectiveness of the screening tool FRCaST also need to be asked.
“The two international regulatory bodies chosen by the NZ EPA to peer review FRCaST were the National Industrial Chemicals Notifications and Assessment Scheme (NICNAS) in Australia and Health Canada (HC) / Environment and Climate Change Canada (ECCC) which also saw limitations in the EPA approach and sought for New Zealand to have greater alignment with Australia and Canada, neither great examples of the precautionary approach.”
“The NZ EPA has generally used the US EPA and the European Food Safety Authority (EFSA) for risk assessment guidance. They all have been heavily influenced by the agrichemical industry. EFSA, following significant criticism, has since been actively improving its independence and transparency, reducing their exposure to industry.”
Soil & Health believes that neonicotinoids and glyphosate should be phased out quickly.
Submission on an organic standard in New Zealand.
/in Submissions11 June 2018
Ministry for Primary Industries
PO Box 2526
Wellington 6140
Submission on MPI Discussion Paper N0: 2018/19
Background
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organization supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
Introduction
2. Soil & Health welcome the opportunity to comment on the MPI Discussion Paper “Would New Zealand benefit from new organic regulation?” (“Discussion Paper”). However, we are concerned that the consultation and submission period was both at short notice and for a relatively short time. Organisations throughout the sector will have had difficulty to have appropriate discussions among their members and members including both consumers and organic licensees. We reserve the right at Select Committee and further consultation to further refine our position.
Discussion Paper Questions
Part 1: Introduction, purpose and context
We generally agree with the proposed scope so long as this is recognised as merely a starting point. However, some aquaculture products, both salmon and mussels, have previously been certified organic in New Zealand, so it is important that aquaculture would be covered by regulation of organics to ensure inappropriate claims are not made.
The scope is currently limited to primary and processed products and we recognise this is a good place to start from as they form a large part of New Zealand’s organic production. However, as the development of the regulations progress other products might need to be included for example, it is also not clear whether cosmetics, body care products and textiles are included in the scope.
We agree. The market information provided is consistent with reports produced by Organics Aotearoa New Zealand. However, the description lacks any information about or acknowledgement of New Zealand’s current GE-free status and the market advantages that this provides. The use of GE or GMOs is prohibited in organic products, and products cannot be labelled certified organic if they contain GMOs. The global Non-GMO market is at US$550 billion,[1] and trends show this is only going to grow.
Of New Zealand’s five key trading partners, three have non-GMO labelling regulations.[2] New Zealand has a market with these countries due to the perception and the fact that no GMO seeds are currently being cultivated in New Zealand. China is the largest trading partner with dairy being the largest single export. In 2014 NZ$5.3 billion of dairy products were exported to China.[3]
What is also important to mention is that organic and sustainable agriculture is the highest value added agricultural market with over US$80 billion worldwide sold as organic in 2014.[4] New Zealand primary industries are looking for ways to export value-added products as they move away from commodity-based trading. The collapse of the dairy industry in 2015 and the rise of tourism as the largest contributor to New Zealand’s GDP indicate an over-reliance on a narrow range of commodities. Federated Farmers sponsored a number of speakers during their national conference on 1-3 July 2015 in Wellington, who shared the view that value added agriculture is important to the resilience of the industry.
We agree with the description of the current regulatory environment for organics, namely that they are not regulated at all. One could conclude that MPI’s Official Organic Assurance Programme (“OOAP”) Technical Rules have by default become a national organic export standard. However, the OOAP Technical Rules is an export one and run through MPI with the Organic Export Association of New Zealand. While the process is consultative, it is hardly representative of the wider organic sector in New Zealand and is focused solely on exports.
It must also be noted that over decades the BioGro NZ standard has been run by its Society’s members and licensees who have contributed to its development through standards and certification committees. It has had significant voluntary input and provided a chance to review the impact of decisions on growers, input providers etc. Soil & Health also contributed to this largely as the consumer voice on all boards. However, this process of keeping the standard up to date is is exhausting on resources and the voluntary base.
We agree that this is a good opportunity to change the way organics are regulated in New Zealand. The current unregulated environment undermines the credibility of certified organic products produced in New Zealand and this needs to change. Organic licensees, the retail sector and the public are confused and often have a poor understanding of what organic means, or the implications of false claims. Regulation should aim to protect consumers from fraudulent claims and protect producers from unfair competition (products with false claims), thereby building the credibility of organic products produced in New Zealand. There is also an opportunity to rationalise other activities like auditor training, and upskilling, technical development, certification management and to develop a common national mark.
We agree with the objectives outlined however question whether the regulatory regime needs to be flexible.
We consider that the new regime should endorse and protect the status of existing New Zealand certifiers. The regime should enable certifiers to set higher standards (above the regulation) should they want to. It should also allow for equivalency between New Zealand produced and certified imported organic products provided the certification standards are at least equivalent to the New Zealand regulation. Soil & Health strongly supports the Participatory Guarantee Systems such as OrganicFarmNZ to be recognised as a credible certification pathway.
Part 2: Options for how a new regime for organics could work
Yes, because organics also has environmental and sustainability outcomes, not just food safety outcomes. Production methods are important because of the benefits to the environment as well as end product qualities.
Issue 1: Should a new standard be voluntary?
Yes, we agree that the correct options have been identified. We do not propose any other alternatives.
Cost is a significant concern to all organic growers and producers but most especially to small-scale growers and producers suppling local markets direct to the consumers. Small-scale growers and producers are important for the support of fresh organic products to New Zealand consumers and therefore any new regulations which would follow adoption of a single standard must not penalise them through unnecessary compliance costs.
The importance of genuine organic consumers expectations needs to be considered in the structure of Standards setting/maintenance body, and stakeholders groups. The importance of the consumer guarantee aspect of organic regulation must be reflected in significant organic consumer representation, which Soil & Health has experience of.
There are a number of overseas examples of standards maintenance groups that have been dominated by business interests that have not reflected genuine organic consumers and licensees’ interests, for example USDA now includes an option for ‘organic’ hydroponic production, although hydroponics by design does not meet New Zealand organic requirements, nor organic consumer expectations that organic production is soil based.
At one consultation, it was suggested that legislation for organic regulation would be likely be ahead of standards group representation being consulted on. It is therefore necessary to ensure that a minimum representation outline is included in the primary legislation to ensure organic consumers will be an effective part of standards setting and maintenance.
If mandatory the system should not be designed so that it constrains or prevents alternative certification systems being developed and recognised. A mandatory standard would be acceptable if it allowed for small-scale growers and producers to continue to function without unfair constraints and allowed the opportunity of lower cost Participatory Guarantee System certification.
For an organic consumer guarantee with integrity, the degree of organic consumer representation on the standards setting/maintenance group will potentially dictate either positive or negative outcomes. Soil & Health is probably the most visible advocate for New Zealand organic consumers.
We support the development of a national logo provided it can be accessed by local and small-scale market growers and producers, not just larger scale operators that export.
Issue 2: How should we check that relevant businesses meet the standard?
We consider that the correct options have been identified.
No other positive or negative options are suggested.
As stated previously local and small-scale operators should not be disadvantaged. Costs relating to MPI regulatory requirements in other sectors have frequently been described as prohibitive to small businesses, and although some changes have been made for example raw milk cheeses, there is a strong cost recovery model in existence using high salary and travel fees. Regulation and compliance in that context threatens small producers if exemptions are not set sensitively.
Home gardeners that garden organically and would meet the National Organic Standard, should they be commercial, must also be able to describe their home grown produce as organic, whether sold or not. Such situations could include A&P Show vegetable competitions or descriptions in a newspaper article. Compliance could be by external interests checking against an affidavit or online registration if necessary, and complaints lodged with MPI or the accredited agency.
If exemptions are to be allowed, then conditions on which they are based should be clearly defined, for example if there are multiple companies held by a single owner they should not be allowed to all be exempt (all should be verified).
Summary of proposals
We strongly support the combination of Option 1C: mandatory compliance for all relevant businesses, and Option 2C: ongoing verification, with limited exceptions.
We support Option 1C due to the level of certainty and transparency that it provides to both businesses and consumers about what the definition of organic means. Under this option, whether or not a product is certified, consumers can be sure that if it is labelled organic then it means the same as certified organic as both terms must meet the National Organic Standard. This is significant for consumers who are too often sold products as organic, even though the grower/producer is not subject to any checks that their claim is authentic. If a producer uses the term organic to sell their system should be able to be verified in some way.
However, many of our members are small-scale organic growers and producers who only sell their products locally, direct to their consumers. Their growing and production standards meet that of certification standards, yet they choose not to become certified due to the costs and effort involved. Some growers and producers prefer to remain small-scale and want to keep their costs down in order to keep their products affordable. Certification would be an extra cost that they may not be able to meet unless they scaled up. For them to have to change their labels from “organic” to “spray-free” simply because they are not certified, despite meeting a certification standard, would not be fair on them. We consider that the integrity of certified organic is not compromised by these types of growers using the term organic.
Therefore, we also support Option 2C in that while all businesses that label their products organic would need to comply with the standard, not all businesses would be required to have their activities independently verified on an ongoing basis, or certified. The integrity of organics would still be maintained as any grower/producer, small or large, that defines their product as organic would be subject to enforcement action if it was shown that they were not meeting the standard. We also support the proposal to introduce measures that reduce compliance costs for small-scale businesses if and when needed through for example group certification or by adjusting the audit frequency.
For our members and for consumers of organic products there will be benefits as the baseline standards will be clearly defined.
We have already stated our preferred option – that being Option 1C and Option 2C.
Part 3: If needed, proposed features of empowering legislation
Those already certified (BioGro NZ/Asure Quality/OFNZ/Demeter) we consider are already following what will become the National Organic Standard – the process for how they become integrated needs to be clear and separate to those not already certified. We consider that MPI should recognise agencies not individuals.
As commented in Q8; At one consultation, it was suggested that legislation for organic regulation would be likely ahead of standards group representation being consulted on. It is therefore necessary to ensure that a minimum representation outline is included in the primary legislation to ensure organic consumers will be an effective part of standards setting and maintenance.
We consider that minor non-compliances should be handled appropriately and be dependent on the level of the organic integrity of their products and the risk to consumer expectations and health.
We consider that the legislation must allow for new certifiers and other certification systems (that can demonstrate compliance to the National Organic Standard) to be recognised. Legislation must include minimum requirements of the structure of standards groups and representation and include an expectation of GMO free food and production.
Part 4: General comments and next steps
We consider that the affordability of the ‘product’ in terms of the comparative costings from similar situations should be considered from both export and local market certification options.
Options from overseas, particularly around exemptions, affidavits and online registrations, what financial thresholds or other measures are used.
For an organic supply chain there can be several steps (actors handling product) – organic oversight should be sustained along with the whole supply chain.
Yours sincerely
Name: Lucy Blackbourn
Position: Acting General Manager
The Soil & Health Association
PO Box 9693
Marion Square
Wellington, 6141
Website: www.organicnz.org.nz
[1] http://www.prnewswire.com/news-releases/packaged-facts-global-non-gmo-food–beverage-market-reaches550-billion-us-sales-at-200-billion-300127127.html
[2] http://www.stats.govt.nz/browse_for_stats/snapshots-of-nz/nz-in-profile-2015/trading-partners.aspx
[3] http://www.stats.govt.nz/browse_for_stats/industry_sectors/imports_and_exports/global-nz-jun-14/keypoints.asp
[4] https://shop.fibl.org/fileadmin/documents/shop/1698-organic-world-2016.pdf