Use your voice to defend New Zealand’s GE-free food production.
The Government has opened submissions on its proposed Gene Technology Bill. It takes a few minutes to create a submission on the Gene Technology Bill and tell the Government what changes you would like to see made to the Bill.
Make a submission to ensure the Government takes a precautionary, science-and-evidence based approach to the use of genetic technologies.
Submissions close at midnight on the 17th of February 2025.
What’s at stake?
The ability to intervene directly in life at the genetic level is a powerful ability. That is why it must be done with precaution, with ethics, and in a way that takes account of te Ao Māori and broader societal values.
Everyone should have access to safe, nutritious and healthy food produced in a way that doesn’t harm the environment. Farmers should be able to maintain their ability to choose to produce food without the risk of genetic contamination.
Currently, there are no genetically engineered animals, crops, fruits, or vegetables grown in New Zealand. The Government want to radically deregulate genetic engineering risking our valuable GE-free production status.
The ability for farmers to choose to remain GE free will not be protected under the proposed Gene Technology legislation. The thorough consideration of ethics, risks and benefits, te Ao Māori, and economic and environmental impacts is also not provided for.
Why make a submission?
The Government’s Gene Technology legislation has been rushed with limited opportunities for public and farmer engagement. The current proposal is not based on evidence of the impact of GE crops overseas, which include increased herbicide use, superweeds, higher costs for seed, and lower yields. There has been no consideration of agroecological solutions or economic analysis. Independent analysis suggests the loss of our GE-free reputation could cost New Zealand 10-20 billion dollars annually.
Risk to farmers
New Zealand risks losing our GE-free production status because of this Bill. The release of live self-replicating organisms into the environment and agricultural systems risks unintended or irreversible impacts. This includes contamination of non-GE food producers who may lose substantive premiums for their products as well as an unfair cost burden for farmers who wish to remain GE-free.
Undermines Māori interests
The Crown has a responsibility to protect Māori interests in relation to indigenous flora and fauna, cultural knowledge, and practices. The proposed regime will undermine our founding agreement Te Tiriti o Waitangi by limiting Māori input and decision-making power regarding resources and taonga over which they hold rangatiratanga.
How to make a submission?
Visit the Health Committee submission page through the button below. Once there, decide whether or not you would like to do an oral submission. This can be really impactful, but a written submission is just as valuable.
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Set out your position
“I strongly oppose the Gene Technology Bill. I request that the Health Select Committee recommend that it does not proceed through further stages.”
Key points to include in your submission
Tell the Select Committee why you OPPOSE the Gene Technology Bill. Listed are several key areas of opposition to the Gene Technology Bill, you could say, for example:
We encourage you to also add your own reasons.
Further information you can draw on in your submission
Absence of a precautionary approach
I do not support this Bill because there is no provision requiring a precautionary approach to be taken. This is a concerning change in approach from what is currently required in existing legislation under the Hazardous Substances and New Organisms Act. A precautionary approach, or using the precautionary principle, is important in the context of GE in order to exercise caution in managing adverse effects where there is scientific and technical uncertainty about those effects.
By removing the precautionary principle, the approval process under the Bill will not require researchers to investigate potential hazards that may not have been identified already which allows unknown but rational risks to be factored into decision-making (such as requesting monitoring of an organism after release).
Removing the precautionary approach will undermine international obligations, for example, the Convention on Biological Diversity and Cartagena Protocol on Biosafety.
The precautionary approach should be retained to ensure the critique of GE products can occur, regardless of whether potential risks are fully realised, and establish requirements that could help manage those risks.
Inability to consider ethics
I do not support this Bill because there is no specified requirement or process for ethics to be considered, including for the prevention of animal cruelty. Consideration of ethics is important because decision-making processes for GE needs to go beyond purely scientific and technical assessments, to ensure it aligns with societal values and ethical standards.
While any approved GE application will need to meet ethical requirements within existing legislation, there are unique ethical considerations specific to GE that are not covered by current legislation in New Zealand. For example, the use of genome editing on living organisms, and intellectual property rights on genetic material, particularly germplasm.
The legislation is not aligned with Ministry for the Environment advice to include ethics provisions to ensure a more robust regulator.
Risk assessments should be required to have a list of ethical considerations and impacts for the regulator to consider or that the expert advisory committee should be required to advise on ethics issues.
Lack of economic assessment
I do not support this Bill because no economic assessment of the potential impacts of regulatory change has been conducted by the Government. It is important to understand the economic implications of this legislative change, including risks related to New Zealand’s trade and production of exports.
The only economic analysis conducted by the New Zealand Institute of Economic Research (NZIER) found that New Zealand’s primary sector exports could reduce by $10 billion to $20 billion annually were genetically modified organisms (GMOs) to be released into the environment.
International evidence from 30 years of commercial GE crop production does not support the Government’s claims that New Zealand has been disadvantaged by our non-GE production status or that we stand to benefit from ending that status. There is a large and growing global market for non-GE foods. The Government’s plans to release GE crops or animals effectively forfeits our current GE-free status, risking the reputation of New Zealand produce.
Lack of Māori decision-making power
I do not support the Bill because the proposed Māori advisory committee does not have substantive decision-making powers. For the regulator to meet the Crown’s obligations under Te Tiriti o Waitangi it must ensure that the advisory committee mechanism gives effect to the rights of Māori to make binding decisions regarding resources and taonga over which they hold rangatiratanga.
In accordance with the findings from WAI 262, the Government has obligations under Te Tiriti o Waitangi to ensure that kaitiaki relationships between Māori and their taonga (such as flora and fauna) are acknowledged and protected in laws, policies and practices. The regulator should therefore be required to act on the advisory committee’s advice and recommendations to address identified risks to kaitiaki relationships.
The advisory committee should have the ability to veto applications of which they determine the risk cannot be appropriately managed or mitigated. Representation of locally impacted hapū and iwi in decision-making should be required.
Lack of protection for farmers who wish to remain GE-free
I do not support the Bill because there will be no liability for contamination caused to GE Free producers. This means that famers will face increased compliance and certification costs to ensure their crops and animal products remain GE free.
The proposed regime assumes that non-GE production, including organic production, can coexist with GE, however genetic pollution of GE free producers and wild species is a real issue.
Any regime should protect the ability for farmers to choose to remain GE free and ensure full liability on those that intentionally or accidentally contaminate non-GE producers and the environment.
Removal of councils’ right to be GE-free
I do not support the Bill because it removes the hard-fought existing right of local and councils to make decisions about the use of GE in their region.
This will limit the ability of communities and councils to make informed decisions around their GE status, the risks of GE land use.
No requirement for the regulator to assess benefits
I do not support the Bill because the regulator will not be required to assess potential benefits, as well as risks of an application.
Potential benefits should be considered alongside a risk assessment, involving a clear criteria for data, incorporating uncertainty, and transparency of process as well as post-release performance milestones.
Having this as part of regulation puts a mandate to research to justify and substantiate the purported benefits, build buy-in around potential benefits, help prioritise what applications are approved and invested in, and adequately assess the risk relative to that benefit.
Background information
Currently, the use of gene technologies is regulated by the Hazardous Substances and New Organisms Act 1996 (HSNO). HSNO allows genetic research in laboratories, which has occurred in New Zealand since the 1970s. HSNO requires that field trials and applications of gene technology products outside the lab require additional approvals. The supposed compliance cost of this regime is asserted as a barrier development of GE products in NZ.
Food products and ingredients are already regulated under the Food Safety Act. There is currently no commercial production of any GE food crops, vegetables, animal feeds or pastures, fruits or animals in New Zealand. No imported fresh fruit and vegetables or animal products sold here are genetically engineered though they are permitted with Food Safety New Zealand approval. GE ingredients are most likely to appear in processed foods containing soy, maize, cottonseed oil, and canola.
There are only 27 countries in the world that have commercial production of GE crops. 99% of the global acreage involves four crops – soya, maize, cotton and canola – which largely end up as animal feed or biofuels.
Genetically engineered medicine - such as diabetic insulin produced in laboratories since the 1980s - is not contentions. Precision fermentation in containment is supported so long as food safety is ensured and there is thorough labelling for the public.
The proposed legislation is modelled on Australia’s Gene Technology Act 2000. If passed, the legislation will establish a significantly more permissive regulatory framework for genetic technology in New Zealand.
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