Summary of our submission
The Soil & Health Association is focused on the following 10 points:
- ‘Organic’ is not defined in the Bill and is therefore open to misinterpretation. We propose that the full IFOAM definition and principles of organic agriculture be written into the Bill.
- Exclusion of GMOs: The use of genetic modification is not in accordance with organic practice, so exclusion of GMOs should be added to the definition of ‘organic’ in this Bill.
- The title of the Bill should be ‘Organic Production and Products Bill’ to reflect the importance of the connection between the production system and the product.
- The Bill needs to recognise the role that organic production plays in achieving other important public good outcomes for NZ, such as climate change mitigation, improvement of water quality, and protection and enhancement of biodiversity.
- The Purpose of the Act should be expanded to reflect the priorities of the organic sector both in NZ and internationally. Facilitation of domestic trade, growth of the domestic organic sector, and maintenance and support for the established principles of organic agriculture should be added in.
- NZ’s regulatory system should mirror the best functioning organic regulatory systems in other jurisdictions such as Canada and the EU. The proposed system, which puts the Ministry in charge of final approvals, puts an unnecessary extra level of administration and cost onto the process. We think that third party certifiers should have the power to give final approval to licensees (i.e. to issue certificates), and the relevant Ministry should restrict itself to accrediting third party certifiers, keeping a register of the approved operators (certified licensees) and carrying out enforcement in the case of breaches.
- There should be an Organic Authority with both government and organic sector representatives to oversee the organic standards. The organic sector representation on such an authority should include producers, processors, consumers, traders, certifiers, organic scientific representatives and Māori (who must be present as the Crown’s partner in the Treaty of Waitangi). This body should be more than a technical advisory board; it must have the power to decide on, develop and monitor the content of the standards rather than simply recommend it to the Ministry.
- The Bill needs to provide for low cost certification options for small to medium sized operators. Participatory Guarantee Systems (PGS), as recognised by IFOAM, such as OrganicFarmNZ are affordable and accessible to small-scale producers who produce solely for the domestic market, such as via farmers’ markets, local organic shops and box schemes. PGS should be provided for in this Bill. Very small producers should be exempt from certification, but should still have to follow the organic standards if they make ‘organic’ claims about their product.
- If the cost of certification increases, those costs will be passed onto consumers, and this will have a chilling effect on domestic trade in organic products overall. Domestic consumers should have affordable locally produced organic products of all types available to them.
- National organic standards documents should be freely available to the public as a resource for learning about organic practice and to inform consumers.