OANZ Submission on the Proposed National Organic Standard
16 June 2023
This submission, which represents the collective views of the organic sector.
To: Ministry of Primary Industries
Date: 16 June 2023
1. Introduction
The National Organic Standard is critical to maintaining the high-trust model that Aotearoa New Zealand’s organic farmers, growers, businesses and certifiers have built up over decades. We appreciate the goodwill and culture of the MPI Organic team; at the same time, there are significant changes that need to be made to the Standard - and that we consider are essential to be made.
This submission, which represents the collective views of the organic sector, details those submissions and OANZ considers that without these changes the sector will not be well served.
Focus of this submission
The Consultation Document is not a “Draft” National Organic Standard because it is not yet clear what will actually be included in the drafting instructions for the actual Standard.
Using the “three box” red, green and blue categories that divide up the consultation document our understanding is that:
Red box = Proposed Principles/Aims are aspirational in that there is uncertainty over whether they would appear in the standard.
Green box = Proposed Regulation Content is a draft of what is intended to be in the Standard.
Blue box = Proposed Supplementary Notice or Guidance Document that sets out matters that may be subsequently set out in Notices.
OANZ’s submission focuses on the red and green boxes of the consultation document on the assumption that there will be later consultation on any notices that are intended to be issued.
Submission 1: Second round of consultation on a revised draft
The difficulty for OANZ and other organisations and individuals is the uncertainty over what will be in the final drafting instructions to Parliamentary Counsel.
Further, we do not consider this to be a complete Standard. For example, definitions that are critical to delivering the assurances that organics rests upon are absent from the standard. Other provisions, as detailed in this submission, are simply not adequate.
MPI have now confirmed that there will be a further short consultation process to review a final draft with definitions included. This is a very positive development and will help to ensure we achieve a high-quality standard.
We also consider that during the further period of consultation a formal review process is undertaken by external experts to ensure that the proposed standard meets the common objectives and requirements of organic standards (COROS) generally. OANZ would be happy to collaborate with MPI to arrange such a review.
3 General requirements
3.1 Scope
Section 3.1 Scope is very general, too vague and does not include everything that should be covered in the Standard. Therefore, MPI must include the following points in section 3.1 Scope:
A clear definition of ‘organic’ with clarity for specific sub-sections e.g. organic processed products, wine (alcoholic beverages), imported ingredients, etc…
Clarification on whether or not the Standard covers yeast, wool and other animal fibres, and multi-ingredient foods.
3.2 Links to other legislation
Freshwater Farm Plan legislation must be referenced.
Requirement to comply with other legislation: MPI has provided no analysis about what compliance with other legislation will mean for the standards, their interpretation over time, and/or their implementation.
This is critical to understanding how the standards will actually work and should have been provided with the initial draft. We request that MPI provide this detail before the second round of consultation so we can understand if and how other statutes such as the RMA, HSNO Act and others will shape the organic Standard.
3.3 Principles
Changes needed: The current wording in section 3.3 Principles should be deleted and replaced with IFOAM principles and Māori values.
Rationale: The “principles” set out at the beginning of each section of the draft Standard are important guides for the interpretation of the mandatory rules set out in the regulation and must be included.
The principles in the draft do not express the ethos of organic production and do not sit well with the sector. Instead, they read like a cut and paste from other New Zealand statutes. IFOAM is the authoritative source on such matters and placing the IFOAM principles within the Organic Standards will ensure that New Zealand standards have international currency, resonance and connection. These are:
The Principle of Health - Organic production should sustain and enhance the health of soil, plant, animal and human as one and indivisible.
The Principle of Ecology - Organic production should be based on living ecological systems and cycles, work with them, emulate them and help sustain them.
The Principle of Fairness - Organic production should build on relationships that ensure fairness with regard to the common environment and life opportunities.
The Principle of Care - Organic production should be managed in a precautionary and responsible manner to protect the health and well-being of current and future generations and the environment.
Each principle is articulated through the above statements followed by an explanation (refer to this IFOAM webpage for explanations).
Māori values must be included under Principles and we ask MPI to work with OANZ’s Treaty Partner, Te Waka Kai Ora, for guidance.
There is no reference to Te Tiriti o Waitangi that assures the right as Māori to have
Kaitiakanga over their lands and their whakapapa, mauri, wairua, tapu, mana,
tikanga that organic production systems protect for future generations. This includes the right to maintain, protect and develop the past, present and future land and taonga relating to kai atua production.
3.5 Prohibitions
Changes required: Definitions for prohibited technologies and approaches must be included in this section. Specifically, OANZ provides definitions for:
Genetically Modification (GM) = Genetic Engineering (GE)
Genetically Modified Organisms (GMOs)
Nanotechnology
These definitions draw upon IFOAM definitions to uphold international best practice because IFOAM is the worldwide authority on organic principles, safeguards and integrity achieves this goal.
These must be included in the National Organic Standard as they are critical to the integrity of New Zealand’s organic regime and in meeting equivalency with trading partners.
Every term in section 3.5 Prohibitions must be defined.
MPI wrote - “In order to maintain consumer confidence in organic production, this Standard intends to require a number of prohibitions.” Change “intends to require ” to “ contains a number of prohibitions."
Issue:
Non-GM is a critical proof point for organics. As such, organics must maintain a high-trust model in respect of GM technology.
As currently drafted, the HSNO regime (and the EPA as the regulator) would act as the authority over what constitutes a GMO for organic standards. This arises because of the requirement for the standards to be consistent with the HSNO Act and the absence of a definition in the Organic Standard.
It is entirely inappropriate that HSNO/the EPA define what a GMO is for the purposes of the National Organic Standard for the following reasons:
The HSNO Act and Organic Products Regime (and IFOAM principles) are fundamentally different regimes, even if some aspects overlap.
Ultimately, it is a different jurisprudence.
The HSNO Act is not focussed on outcomes and costs and benefits to organics, but to NZ Inc in general. As such, the risk/cost-benefit assessment that HSNO sets out weighs considerations differently to the Organic Standard. This means that EPA could make decisions that are assessed to be a net benefit to NZ (for example, via benefits to an individual sector) even though the outcomes are overwhelmingly or even somewhat negative for the organics sector
This creates risks and exposures for the organics sector because the EPA can make (and has made) decisions that are not consistent with organics sector principles or international organic standards.
Indeed, recent decisions by the EPA interpreting what constitutes a GMO (under section 26 of the Act) are antithetical to organics and current standards within the sector and internationally. (See for example, the determination on siRNA. This determination alone would set Aotearoa NZ at odds with key organic standards - and the expectations of customers on Day 1 that the standards come into effect were the current settings under the draft standard to be unchanged.
Leaving the HSNO Act as a default would leave the organic sector vulnerable to law changes by a future government. For example, were some or all gene editing techniques to be deemed non-GM under HSNO by regulatory review or law change, this would automatically apply to the Organic Standard, even if the rationale for the law changes did not consider the impacts on the organic sector or give any weight to the impacts.
For these reasons, it is absolutely critical that there is a definition in the Standard that is not vulnerable to external dynamics that are not primarily concerned with the principled and strategic interests of the organic sector. It is the job of the Standard to protect those interests.
The Definitions Supported by the Sector
Genetically Engineered (GE) / Genetically Modified Organisms (GMOs)
For the purposes of this standard, genetic modification means a set of techniques to make interventions at the level of the molecular composition of organisms (such as using recombinant DNA and RNA) and through which the genetic material of plants, animals, micro-organisms, cells and other biological or heritable units are altered in ways or with results that would be practically impossible without using those techniques or would be impractical to obtain by methods of natural mating and reproduction or natural recombination. These techniques may also use a combination of materials that accelerate the cellular internalisation of gene altering agents and which would also not occur in nature without human intent.
Techniques of genetic modification include, but are not limited to those that make rapid or extensive changes in the nature of the organism using: recombinant DNA and/or RNA techniques, micro and macro injection, encapsulation, gene deletion and gene/chromosome doubling. In addition and for clarity, methods that target specific genes such as genome editing, base editing, and gene silencing are classified as genetic modification procedures. These can depend on homologous recombination or non-homologous end joining, employ nucleases including mega nucleases, zinc finger nucleases (ZFNs), transcription activator-like effector nucleases (TALENs), Cas, or similar, and/or use engineered co-factors such as siRNA or gRNA/gDNA (CRISPR). Genetically modified organisms do not include organisms resulting from techniques such as conjugation, transduction, natural hybridization, and marker assisted breeding, traditional chemical or radiation mutagenesis or cell fusion unless a genetically modified organism was involved in any of these techniques.
Genetically Modified Organism (GMO) – For the purposes of this standard, any organism (e.g., plant, animal, or microorganism) that has been altered by the techniques of genetic modification and descendants and products thereof of such organisms. For clarity, these include but are not limited to: null/negative segregants and any cells, genes, nucleic acids, or other molecules from the organism or heritable material that can, without human intervention, create a character or trait when used to alter another organism or which can be passed on to subsequent generations of the organism, or which may be produced under the protection of intellectual property rights that are secured through a demonstration that the process was distinct from what occurs in nature.
3. Explanation of the proposed definitions
The definitions of genetic modification and a genetically modified organism we provide are supported by large parts of the sector.
They draw upon IFOAM definitions that have been worked through lengthy processes. This is appropriate as IFOAM is the authority on such matters and is internationally facing, which is important for the definition adopted for Aoteoroa’s organic sector.
Amendments to the IFOAM definition have been made to:
Update the definition to provide greater clarity to organic producers and the supply chain as to what techniques are included and which techniques are not included.
Provide a forward-looking definition that future-proofs the standards at least for the foreseeable future.
These have been reviewed by internationally recognised experts in the field.
As MPI will note, the definition comprises: a chapeau description of genetic modification and then moves to describe what types of techniques and approaches are included and which techniques are not.
Given that genetic engineering is a reasonably fast-moving field the list of techniques that are considered GM is non-exhaustive.
As a general principle of interpretation of this definition, a conservative interpretation should be made such that if a technique is borderline, it should be deemed GM. This is consistent with the fourth IFOAM Principle - the Principle of Care. This is effectively the precautionary principle and requires that decisions be made that favour caution where there is uncertainty. This is appropriate in that Standards are subject to periodic review, and this default provides a safe harbour for the sector until the status of individual technologies could be reviewed, if required.
These definitions must be in the Standard. This is what the organic sector expects and are conditions for the support of the Standard by the organic sector.
The following information was provided by OANZ’s Te Tiriti o Waitangi partners, Te Waka Kai Ora: GE and GMO issues affect Māori because of our role as Kaitiaki. Protecting our future generations, our mokopuna, our tamariki, our lands and taonga. It is the protection of important parts of ourselves such as whakapapa, mauri, wairua, tapu, mana, tikanga. Te Tiriti o Waitangi assures that we have the right as Māori to have kaitiakitanga over our lands and, forests, fisheries and ensures the protection of all our taonga. This has not happened in the case of GE or GMO.
Kai atua, Food from the Gods, as Percy Tipene stated:
“Food from the gods ( atua) that has had no interference from outside sources.“
Article 11 of the UN Declaration on the Rights of Indigenous Peoples states that:
Indigenous peoples have the right to practice and revitalize their cultural traditions and customs. This includes the right to maintain, protect and develop the past, present and future manifestations of their cultures, such as archaeological and historical sites, artifacts, designs, ceremonies, technologies and visual and performing arts and literature, and
States shall provide redress through effective mechanisms, which may include restitution, developed in conjunction with indigenous peoples, with respect to their cultural, intellectual, religious and spiritual property taken without their free, prior and informed consent or in violation of their laws, traditions and customs.
Also, the UN declaration on the rights of Indigenous peoples states, “Indigenous peoples are entitled to the recognition of the full ownership, control, protection of their cultural and intellectual property. They have the right to special measures to control, develop and protect their sciences, technologies and cultural knowledge of the properties of fauna and flora, oral traditions, literature, designs, and visual and performing arts.”
The Convention on biological diversity also contains an important clause that protects Indigenous peoples and their knowledge.
We reaffirm and remind MPI that there are teaching and learning practices that are inherent and unique to Maori and are our pedagogy. This ensures our aspirations are formed from within our people, handed down from our elders, alive in our storytelling, visible in our surroundings and exercised by our desires , not driven from external extractive sources. We question Western ideas of knowledge culture and research and the impacts these have on Indigenous communities.
For indigenous peoples it is impossible to separate our indigenous knowledge from what western science calls genetic resources. It is total disrespect for the knowledge and whakapapa spiritually bequeathed by our elders. As indigenous peoples, we have been given the responsibility to take care of our sacred taonga, to protect and care for them, to learn from them and to use them in a way that ensures their health and survival so that our future generations will be strong and able. We consider this a vital investment in our future bloodlines and the health of our environment.
Nanotechnology
Issues: As per the GMO prohibition, the current draft defaults to the HSNO regime for authority over what constitutes nanotechnology/nanomaterials.
This would mean that the HSNO definition of a nanomaterial - somewhat buried in the Cosmetic Group Standards would apply:
nanomaterial means an insoluble or biopersistent and intentionally manufactured material with one or more external dimensions, or an internal structure, on the scale from 1 to 100nm
Cosmetic Products Group Standard 2020 HSR002552
Again, this definition and setting the HSNO regime as the authority on what constitutes nanomaterials/nanotechnology for the purposes of organic standards are inappropriate:
It would set Aotearoa New Zealand’s organic standards at loggerheads with international organic definitions and standards.
The HSNO definition sets the ceiling on nanomaterials at 100 nanometers. As quantum changes - the changes that make nanotechnology scientifically and commercially interesting - occur above 100 nm, this inadequate ceiling simply incentivises developers to create nanoproducts that hover above 100 nm and avoid labelling (as under the Cosmetic Group Standards) or would duck prohibitions under these organic standards.
Definition required for the Organic Standards
IFOAM, as for genetic modification, is the internationally recognised authority on nanomaterials in respect of organic production systems and its definition on nanotechnology is the appropriate one for Aotearoa New Zealand’s organic standards.
It sets a 300 nm ceiling on nanoparticles (thus avoiding creating perverse incentives, as the HSNO definition does). It also helpfully excludes inadvertently generated particles - such as through traditional milling - that fall within the defined nanoscale.
Nanotechnology - For the purposes of this standard, nanotechnology means the intentional production of particles with a size less than 300 nm in at least one dimension. These particles are called nanoparticles. For the purposes of this Standard, nano particles produced by nature, for example, products of forest fires, volcanoes, salt spray or incidentally produced as a result of accepted processing methods such as flour as a by-product of traditional milling, are not excluded from an organic production or preparation system.
IFOAM. 2011. The Use of Nanotechnologies and Nanomaterials in Organic Agriculture
We note that the Australian National Organic Standards also draw upon IFOAM as their authority on matters of nanotechnology.
3.6 Environment
All the points in section 3.6 need editing. The wording is often too vague, and/or inconsistent with organic practices. This section tends to be written to achieve outcomes rather than stating what is required. There is also not enough information to make a truly informed submission. The details are clearly missing.
3.6.1 Biodiversity
Delete the following terms and sentences:
"ensure their enhanced ecological function"
"appropriately broad"
"restriction of livestock access to buffer zones"
“Maintenance work within wild and semi-wild habitats, including operations such as hedge trimming, drain clearance and mowing of field boundaries must be carried out in a phased operation, maintaining some portion of the respective element undisturbed or untouched at any time.”
Edit the following:
“Pest control in organic production depends on building an environment based on a natural balance through establishing floral and faunal diversity." Change “depends on” to helps build an environment ….
3.6.2 Soil health
Edit the following:
“Healthy soil is a prerequisite for healthy plants, animals, and products”. Add humans and change “prerequisite” to “is a BASIS for healthy”...
"Grazing by livestock; and ... Add TIMELY grazing by livestock to make it more clear
Clarify:
There is a listing here of ‘d. animal manure (preferably composted) / effluent’ as a suitable soil enhancement. This introduces inconsistency with current rules and within the standard that needs more explanation. Raw manure or effluent is currently not allowed under the BioGro organic standard in crop production (Module 9, 3.1.3g) unless hot composted to specific parameters, but there is an exception allowing its application to pasture for livestock production (but not directly to soil) (Module 5 4.2.3g). The cases in which uncomposted manures are allowed to be used need to be clearly laid out in this standard, and should include guidance on cold composted versions such as biodynamic Cow Pat Pit (CPP). Raw manure applied to vegetable gardens should not be allowed.
“Soil organic matter and soil flora and fauna must be conserved or enhanced to improve soil fertility, soil structure and humus.” What is the purpose of this sentence? Perhaps change to "Soil organic matter and soil structure are IMPORTANT", and should be maintained or enhanced …”
While the guidance section in the draft document contains some important concepts, the subject is so complex that there should be a best practice organic management manual for soil health to accompany the Standard.
3.6.3 Water Management
Clarify and Edit:
"Water must be used efficiently by carefully matching water usage to crop or pasture requirements, the use of water budgets and the adoption of efficient irrigation practices and systems." Water management is already effectively covered in existing legislation through the Freshwater Farm Plans which must be followed by all farms over 5ha growers and 20ha livestock. See 3.2 Links to other legislation.
Change "stock access to streams" to "stock access to WATERWAYS"
3.7 Managing risks to your operation
Edit the following:
“In the case of reasonable suspicion of contamination, the operator will investigate the possible sources (soil, water, air and inputs) to determine the level of contamination and notify the Recognised Entity.” Remove "to determine the level of contamination”.
"If there is a known risk, testing for the presence of contaminants or inputs not allowed in this Standard MUST be carried out. Change MUST to MAY BE carried out. …
The operator must be able to demonstrate that sources of external contamination have been minimized. This may require:
a. the use of buffer zones; = Add physical barriers here. At an higher level than buffer zones.
Clarify:
“Inputs not allowed under this Standard must not be stored within an organic production site” This is in contradiction with the split production requirements. Add split production exclusion to make it clearer.
3.8 Conversion to organic
Clarify:
Notify MPI of this date = Notify MPI or the Recognised Entity of this date.
Why does an operator have to notify MPI?
What records are required and who is to monitor them?
Change word “conversion” to “transition”
3.9 Split and Parallel Production
Clarify:
The Organic Management Plan is only referred to in Clause 3.9. This creates the impression it is only needed for those with split and parallel production systems.
3.12.1 Labelling
Clarify:
3.12.1.1. Organic - “The remaining product ingredients must be less than 5% of allowed non-agricultural ingredients or non-organic agricultural products.” It needs to expressly state here that the 5% may not contain GMOs or GE/GM derived ingredients or other prohibited substances. If they are allowed to be “non-organic” they must still be GE free.
3.12.1.2 - Made with Organic ingredients: This claim allows for a minimum of 70% organic ingredients, but it should still exclude GE ingredients and other prohibited substances from the remaining 30%. Otherwise, the claim is misleading.
3.12.2 Product Identification
Clarify:
If traceability is going to be required by the Standard, then MPI needs to explain how it will work. This includes unpackaged products, marae or community garden produce, etc.
3.13 Pest, weed and disease management
Edit:
“Pests, diseases and weeds must be managed in a way that minimise negative impacts to the overall ecology of the system.” Change to “Pests, diseases and weeds must be managed in a way that minimises negative impacts to the ecological balance of the system”.
4 Plants requirements
4.1 Introduction and Scope
Edit:
“Organic production should aim to benefit the ecosystem through holistic management of land in a way that recognises and supports the crops and soil.” Change to: “Organic production aims to benefit the environment and ecosystem through holistic management of land, soil, water, crops production and other non-production vegetation.”
“Crops and, where applicable crop rotation should seek to maintain and enhance soil health.” Change to: “Crops should be grown in a way that maintains and enhances soil health, and, where necessary, crop rotation should be used.”
Clarify:
‘The conversion period of land for annual horticulture crops and pasture is two years.’ OANZ understands that the standard conversion period of three years should apply to all land uses.
4.2 Conversion of land
Clarify:
What soil testing is required? e.g., heavy metals and synthetic contaminants.
Specific tests and their limits could be listed in a Supplementary Notice.
4.2.1 Conversion of plants
Clarify:
"Non-organic plant material must be grown for a minimum of 12 months in compliance with this Standard for conversion." This needs additional information, more description, difference between perennials, bi-annuals, annuals, scion wood, rootstock, etc.
4.3 Environment
Edit:
“Organic plant production should ensure crop rotation is varied and balanced to maintain and enhance long-term soil fertility and plant health.” Change to “Organic plant production should ensure crop rotation or crop diversity is balanced to maintain and enhance long-term soil fertility and plant health.”
4.3.1 Soil health
Edit:
“The operator must put measures in place to protect and enhance the soil, and so that there is minimal need for intervention to control weeds.” Change to “The operator must put measures in place to protect and enhance the soil, so that intervention to control weeds is minimised.”
4.4 Split and Parallel Production
Clarify:
Parallel production is the same variety of organic and non-organic crops grown on one operation. = Shouldn't be visually indistinguishable? Same species different clones can be completely different as so not parallel production. Also, a difference should be considered between parallel production and high-risk parallel production.
4.5 Seeds & Propagation Material
Clarify:
4.5.2 states the guiding principle and should be located at the start of the section. This is vital to understand before moving on to additional information about source of seeds and propagation material.
4.5.1 Source
Edit:
"Seeds used to produce sprouts or microgreens must be organic." This is not always the case currently in other organic standards as they allow non-organic seeds for microgreens where organic seeds are not available, if seed are not covered in a seed treatment post-harvest. Change to: "Seeds used to produce sprouts or microgreens must be organic where possible, but non-organic seeds for microgreens where organic seeds are not available”.
Clarify:
Seeds and vegetative propagating material may temporarily be grown in containers, before transplanting for production. This needs more guidance and clarification.
Seed treatments should not be allowed unless they are permitted by international organic regimes and for clarity, these should be listed in a supplementary notice (this should be referred to in point c). For example, neonicotinoids should be entirely prohibited, but there are other treatments that are currently allowed (with conditions) by the organic standards of our trading partners (BioGro has a list of these).
“d. Treated, non-organic material that is treated to meet New Zealand import requirements.” This statement needs more clarification. Unless the treatments used for import requirements are also compliant with point c., they will be unacceptable in organic production. As it stands now point d. is not compliant with organic practice and should be removed.
4.5.2 Variety
Edit:
“The operator must demonstrate that the selection of crop type is suited to the local conditions and the property the product will be grown on.” and “The operator must demonstrate that the selection of varieties and strains are suited to organic production and minimise the likelihood of weeds, pest and disease problems.” Both sentences are too simplistic and should either be removed or completely rewritten
4.6 Compost
Clarify:
“Commercial compost for use in organic production must meet the requirements as set out in NZS 4454:2005 in addition to the requirements set out in this Standard.” The above statement is not clear as to what “commercial compost” means.
“On-farm composting must be done in accordance with organic production principles as set out in this Standard.” No specific guidelines or rules have been provided about compost-making on-farm.
Basic requirements should be set out in a supplementary notice (e.g., minimum temperature reached, types of ingredients, aeration etc.). Many organic farms and gardens currently make their own compost for use on site and do not test or monitor the compost to NZS 4454:2005.
There should be a distinction made between compost for sale, which should comply with NZS 4454:2005, and compost produced on site for use within an on-farm system, which should only have to meet the organic guidelines (that are not currently in this document).
It is too restrictive to make a blanket requirement for all organic compost to meet NZS 4454:2005
4.7 Landless production systems
Clarification:
Is the term ‘landless production systems’ synonymous with ‘container growing systems? Definitions must be provided.
This section is confusing and needs to be rewritten. It needs to align with organic principles.
Hydroponic systems are specifically prohibited, yet this section could allow for systems like hydroponics to exist within an organic operation.
The intended use of container growing which should be for short-term use, e.g., seedlings and microgreens, not full life-cycle production.
Making allowance for perennial plants to be grown in pots for their entire lifecycle is not consistent with European organic regulations (Regulation (EU) 2018/848) where explanatory notes make it clear that pots and containers are only intended to produce transplants for planting into soil.
OANZ asks that MPI take on board the feedback provided by the OANZ Standards Technical Group and work closely with them to improve this section so that it meets the needs of the sector.
4.8 Wild harvest
Clarify:
What is “an appropriate distance” from non-organic activities, and when will such figures be presented for consultation with the NZ public?
This section does not adequately capture the harvest of fish or seaweed (wild products from the sea or beaches), nor wild harvest of soil.
Wild harvest products include plants, plant products, aquatic plants, and fungi. What about wild harvested soil?
4.9 Fungi
4.9.1 General Principles
Edit:
“To maintain a healthy growing environment in the production of fungi an operator should consider, proper airflow, sanitation and removal of used material.” Change to: “To maintain a healthy growing environment in the production of fungi an operator should consider proper airflow, sanitation and the return of used growing media and fungal matter to a composting system or to natural ecosystem where such used materials can be incorporated into biological cycles without harmful environmental effects.”
4.9.3 Source of substrate
Edit:
The draft reads: “c. peat (not chemically treated); d. wood and wood products (not chemically treated);” Sections 4.9.3c and 4.9.3d should not state ‘not chemically treated’, rather they should state ‘without prohibited inputs’ or ‘uncontaminated by prohibited inputs. Chemically treated is a vague term, whereas prohibited inputs will appear on a list in a supplementary notice.
iii. "This material must not exceed 25% by weight (excluding the covering material and any added water) - too prescriptive. iii. Remove requirement to limit manure to 25%
‘Fungal spawn or cultures must come from organic operations.’ - too prescriptive. ‘Fungal spawn or cultures must come from organic operations - add ‘WHERE FEASIBLE’ - there should be a hierarchical approach like seeds etc.
‘Fungal spawn or cultures must come from organic operations.’ Clarify how this is obtainable in NZ as no organic spawn is available.
5 Livestock requirements
Clarify:
The stocking density for laying birds in housing does not fit with free range husbandry rules.
The stocking density for meat chickens is too high per m2
Identify animal husbandry terms and place in the standard.
No beak cutting or nail /foot mutilation.
Stocking levels
Organic management practices on insects and pathogens
5.2 Prohibitions
Clarify:
Please provide definitions for “cage”
Transport and slaughter: “The use of any tranquilliser before, and during transport, is prohibited, unless withholding tranquilliser compromises the animal’s welfare.” This statement is very vague and malleable. Animal welfare is paramount, and an argument could be made either for or against using a tranquiliser. Is it necessary to include?
Compost: Needs more clarification. “The use of ruminant protein as an ingredient for compost is prohibited.” It could be argued that wool is ruminant protein. Does this need to expressly state the exclusion of wool from the prohibition? The Biosecurity (Ruminant Protein) Regulations 1999 are not clear on this. The definition in those regulations is “ruminant protein means protein derived from the tissue (including blood) of a ruminant; but does not include milk, cream, butter, or cheese, or any other product of milk or cream: tallow: any derivative of tallow: rennet: dicalcium phosphate: peptides less than 10,000 daltons: amino acids. (paraphrased)”. This doesn't allow spilled or discarded milk to go to the effluent pond, or afterbirth from calving be left in woodchip bedding. What about Blood and bone?
"Force feeding and feed deprivation " is too prescriptive, doesn't allow for stomach tubing of hypothermic animals, or withholding milk when animals have diarrhoea.
Green box - "Force feeding and feed deprivation OTHER THAN FOR A TEMPORARY TREATMENT OR HUSBANDRY MANAGEMENT TOOL, without veterinary direction are prohibited”.
Prohibitions need to include any use of Organochlorines and Organophosphates
Breeds and breeding. More information around AI, is it a reproductive manipulation? If yes, it is prohibited under this NOS.
'Electrical devices etc. - Too prescriptive. Animal welfare - "The use of any device to deliver an electrical shock to coerce livestock movement MUST MEET ANIMAL WELFARE STANDARDS"
The continuous tethering of livestock is prohibited, unless for short term intervention = Clarify/Define short term? a day, a month, a year? Should be as per animal welfare standards.
5.3 Conversion
5.3.1 General
Consumers are concerned that the timeframes for converting conventional livestock into organic livestock under these proposed rules are too short and are much looser than what is currently allowed under the BioGro Standard. For example, due to the six-month conversion period for small ruminants such as sheep, it would almost be possible to be a seasonal producer of organic lamb, whereby young conventional animals are brought in on an annual basis from a conventional farm and six months later are sold as organic lamb. Year-round organic management would not be required, but this is what the consumer would be expecting.
We are still unsure how these timeframes compare with other organic standards from around the world. Are they equivalent?
This paragraph looks to have formatting issues, potentially the sentence related to Fibre is meant to be 2. And point 2. Meant to be d.?
For Livestock Progeny and Products (excluding meat) to be Organic, the livestock must ... The way this currently reads, you can buy in a non-organic lamb and sell it for meat after 6 months. It should be detailing the conversion period of the mothers to produce certified offspring.
Livestock Conversion
• Only brought in livestock that are organic, or animals born on the property can be called organic.
• Non-Organic livestock cannot be called organic but their progeny, if born on the organic property, can. Could change to "non-organic stock can be organic after they complete the conversion period above {minimum of 12 months under management to organic standard}".
5.3.2 Source and origin
Edit:
"including treatments administered in the 12 months prior" - is too prescriptive. Change to a. health records relating to any recent treatments to ensure double withholding period has been completed.
“in-conversion livestock brought onto in-conversion or organic land do not need to re-start conversion. If the land is organic, the livestock must still complete their conversion period;”
Animals brought into Full Organic certified land still should not be able to sell the animals as organic but can the progeny.
5.3.3 Breeding
Clarify:
This paragraph references carrying capacity of a production unit, it should be provided how this is determined.
• “Non-organic animals brought in for breeding purposes may not be represented or sold as organic’. This statement directly contravenes 5.3.1.
Edit:
"Breeding sires should be from sources which meet the requirements of this Standard and where suitable livestock is available" - too prescriptive and wordy. "Ideally breeding sires should be from sources which meet the requirements of this Standard where suitable livestock is available but may be bought in from other sources."
5.4 Split and Parallel Production
Clarify:
Minor change in c) to distinguishable rather than different. Will the definition of livestock include pets, working animals such as dog and horses? If pets and working animals are not organic, will they be prevented from residing on the farm?
Edit:
"Non-organic livestock must be clearly separated from organic livestock” is too simplistic. For example, this doesn't allow for a pet goat to live with the organic sheep. "Non-organic livestock OF THE SAME BREED AND TYPE"
"Organic livestock are not present on the same organic production unit" is too simplistic, what about the horse in the next paddock? a. "Organic livestock are not present on the same AREA OF THE organic production unit”.
"Non-organic livestock must be visually different ..." - need to be changed to outcome based, allows ear tags to identify stock of different status etc. c. "non-organic livestock must be visually DISTINGUISHABLE”.
5.5 Health management – prevention
Clarify:
h) and i) refer to regular exercise and appropriate stocking density, without definition or elaboration in Notice level it will not be clear what is intended.
5.6 Health management – treatment
5.6.1 General requirements
Clarify:
This seems to be a duplication of requirements under the Animal Products Act, there should be a cross reference rather than duplication.
It could be argued that homeopathic treatments alone are insufficient to meet this requirement and synthetic treatments may be needed.
b. - too prescriptive. b. - following treatment, review the effectiveness of preventative measures.
Record keeping of EVERY treatment administered. b. (brand and active ingredient), d., e. and f = all needs rewording. Records must be kept of every veterinary medicine administered to livestock, including a. date and animal ID, b. product name, C. any withholding period, d. status of the animal after treatment.
5.6.2 Use of veterinary medicines
Consumers are also concerned that this draft standard is too permissive when it comes to exceptions allowing the use of veterinary medicines.
The draft currently states:
‘Animals that receive more than the following number of courses of treatment with restricted veterinary medicines are not compliant with this Standard:
a. for animals with a productive lifecycle greater than one year: three courses of treatment per year; or
b. for animals with a productive lifecycle less than one year: one course of treatment.’
The use of the terminology ‘course of treatment’ is far too open to interpretation and could allow for continuous use of veterinary medicines on organic animals. A ‘course of treatment’ could last for multiple months, therefore three courses per year could cover the whole year. The course can be repeated if necessary.
Consumers also have concerns about the following:
‘Artificial synchronisation and induction of oestrus may be granted for individual animals under veterinary direction in conjunction with prior written notification to the Recognised Entity.’
There is no guidance on when or why this would be justified. Would it be for animal health reasons, or production synchronisation? This needs to be made clear.
Edit:
Reword "For restricted veterinary medicines a single course of treatment is the period of treatment the veterinary medicine is to be used for as specified by the authorising veterinarian.” Change to "For restricted veterinary medicines a course of treatment is the period of treatment required to return the animal to health ..
a. "Subject to the operator demonstrating that preventative measures are not sufficient to manage parasite populations" - too prescriptive = a. - remove "subject to the operator demonstrating that preventative measures are not sufficient to manage parasite populations"
The following treatments should not be included in the number of treatments counted above. - a. Treatments for parasites. Remove -a. treatments for parasites section. - this allows unlimited drenches for organic animals for internal and external parasites - is a carryover from EU standards where livestock is housed for most of the year. In NZ drenches should be -'included in the number of treatments above'.
Paragraph 1, Point a) is an existing requirement of the ACVM Notice: Requirements for Authorising Veterinarians, and not specific to organic products. Paragraph 2 seems to be contrary to strict organic requirements allowing up to 3 treatments per year for an animal before it is required to be re-converted.
5.6.3 Vaccines
Edits:
First green box - a. "in the specific region of your farm" - too prescriptive and should be removed. First green box - a. "there is a known disease risk, and the disease cannot be effectively controlled by other management techniques"
Clause (b) is of concern due to mandating vaccination. The introduction of vaccines made from genetic engineering should be prohibited. Organic should be exempt from mandatory vaccination.
5.6.5 Quarantine
Not required under most organic standards. Remove the requirement for quarantine.
5.6.6 Painful husbandry practices
Edit:
Surgical procedures are prohibited, with the exception of the following, when performed in accordance with the Animal Welfare (Care and Procedures) Regulations 2018. Comment: Many of the procedures allowed are covered in the surgical or painful procedures and prohibited unless specific conditions have been met, such as when done by a veterinarian for therapeutic purposes with appropriate pain relief.
c 'dehorning and disbudding'. This should refer to animals that fit with the production systems, focusing on polled animals for some Organic farms.
For Biodynamic practitioners’ horns are integral to facilitating the digestive process.
“Infrared beak tipping” this should be removed. Correct chicken free range management
5.7 Livestock feed
5.7.1 General
Clarify:
Para 2 – how would this be evidenced?
Para 4 – The milk should be able to be processed or unprocessed if it is organic. For calves, three days is a long time to provide colostrum and would likely cause diarrhoea. This minimum period is not appropriate. Removal of for a minimum of three days, and unprocessed.
Reference to when animals are normally weaned - this is a very subjective term and would need to be elaborated on in Notice.
5.8 Transport and slaughter of livestock
5.8.1 Transport of livestock
Edit:
"The operator must demonstrate that provisions have been made for watering and feeding of livestock during transport" - too prescriptive, suggestion to remove
5.9 Management of manure, effluent, and other by-products
Edit:
"Where spreading animal manure on to pasture the organic operator must determine appropriate density of livestock appropriate to local jurisdiction requirements." Change to "Where spreading animal manure on to pasture the organic operator must determine appropriate APPLICATION RATE appropriate to local jurisdiction requirements"
5.11 Living conditions
We support the intent of the guidance, that the system is “primarily” outdoors, acknowledging that we have off-paddock facilities including housing systems.
5.11.1 General
Edit:
b - remove 'protect soil from contamination (quarantine)'. b. - replace with 'facilitate herd management and supplementary feeding’.
5.11.2 Stocking rates
Edit:
"The operator must be able to demonstrate ..." - too prescriptive - “The operator must ENSURE"
5.11.3 Housing and construction materials
This information could be better moved into guidance unless there are specific requirements that differ from the relevant Codes of Welfare (e.g., Dairy Cattle, Sheep and Beef Cattle). This is something that is covered in-depth in overseas or international regulations but is not of significant relevance to NZ.
Edit:
Remove - “When animals are housed the operator must ensure the animals are regularly visited and monitored and in the event where welfare and health problems occur appropriate management adjustments are implemented (e.g. reducing stocking density) - covered by animal welfare requirements
First green box - animal housing (point three) - "at least one third is to be solid that is not slatted or grid construction and covered with a litter material such as straw, wood shavings, sand or turf" - this is too prescriptive, so remove = "animal housing must have smooth but not slippery floors."
5.12 Poultry
5.12.1 Housing and Construction Materials
a. collection of poultry droppings - too prescriptive, doesn't allow for barn housing with shavings for bedding where it is impractical to remove droppings, doesn't consider mobile poultry houses. Remove point a.
Blue box "In poultry houses, an assigned area must be available for collection of poultry droppings" - suggestion to remove.
"Poultry must be reared in open range conditions for at least one third of the bird's life where possible" - should be removed, not relevant.
“ ...access to open air run whenever weather conditions permit. Replace with - Daytime continual access to open air runs. NZ Climate allows this, the poultry will choose when they want to go outside.
New wording “All Poultry (layer and meat) should have access to outside runs all the year round.”
Protection from feral animals.
Poultry have sufficient space to stand, stretch, flap their wings, move around, groom themselves and assume other natural postures
5.12.2 Stocking rates
add - Large immobile shed systems must be able to show meat birds can walk to free range pasture at all stages of life cycle. Problem with having very large shed system for meat birds - No use having access to good free-range pasture if they will not / cannot walk that far.
“Meat chickens must have access to areas not exceeding 2,500 birds per hectare for set stocking systems, or 4,800 birds per hectare for rotational systems. “
Reduce stocking rates for meat chickens to 1500/ha
Stocking rates for layers chickens reduced to 850/ha
7 Apiary
7.1.2 Prohibitions
Remove "The extraction of honey from brood chambers where sugar feeding has been used is prohibited" - already covered by previous point "combs containing brood must not be used for honey extraction …"
7.1.4 Conversion
Clarify:
The treated hives are no longer compliant with this Standard and must undergo a conversion period in accordance with section 7.1.4 Conversion.
Whenever veterinary medicines are used the information is to be declared to the MPI before honey is marketed as organically produced. Treated hives should be clearly identified.
7.1.5 Split and Parallel Production
Clarify:
Blue box - g. a plan for converting the non-organic part of the production unit. Remove - some hive sites can never be approved as organic and operator may have agreement in place they will have hives in this area for landowner, or some other management requirement.
7.1.6 Nutrition and Feed
Edit:
"Collection areas must be large enough to provide adequate and sufficient nutrition" suggestion to change and remove" and access to water". "Collection areas must be DIVERSE enough to provide adequate and sufficient nutrition”.
7.1.8 Health Management: Prevention
Edit:
d. suggestion to remove "at regular intervals”.
f. suggestion to remove "regular renewal of beeswax”.
7.1.9 Health Management: Treatment
Edit:
Suggestion to remove "The treated hives must be placed in isolation and all the wax must be replaced with organic wax." Change second part to "IF the treated hives are no longer compliant with this Standard, THEY must undergo a conversion period..."
If non-synthetic remedies are not effective, veterinary medicines may be used. IF the treated hives are no longer compliant with this Standard, THEY must undergo a conversion period..."
7.1.10 Living Conditions: Hive Placement
Edit:
a. i. remove "and access to water"
i Producing genetically engineered or modified plants or their products.
ii. Urban centres, industrial areas, waste sites. iii. Intensive farming areas treated with synthetic chemicals and spraysEnsure that nectar and pollen sources within a 3km radius of the apiary site consists of organic crops and/or spontaneous vegetation and/or crops treated with low environmental impact methods posing no risk to organic integrity which cannot affect the qualification of beekeeping production as being organic such as:
Add -b -iii - Commercial non-organic Horticultural production.
7.1.12 Extraction, processing and storage
Edit:
Remove "The removal of honey or by products must not include the destruction of the hive" - not sure why this is included, it doesn't usually happen unless there hive needs to be destroyed to a disease issue
Paragraph 3 - remove "or coated with beeswax" - doesn't make sense, beeswax is a food grade material - remove
Remove "Organic wax can only be from the cap or melted down comb from the foundation of organic hives" - doesn't make sense, organic wax can come from anywhere in an organic hive
The use of brood combs is prohibited for honey extraction.
8 Processing & Handling requirements
8.1 Scope
This section includes the processing and handling of agricultural products for use as food or feed, including specific requirements for winemaking. Should this include all alcoholic beverages? Wine is classified as alcoholic beverage made from grapes only. What about mead, etc…
8.2 Processing and preservation
Edit:
"Solvents used to extract organic products must be organically produced and food grade as listed in supplementary notice" - amend, solvents don't need to be organic. "Solvents used to extract organic products must be food grade as listed in supplementary notice”.
Remove "contain asbestos”.
Kegging should be added.
Allowed processing and preservation methods are as follows: - Needs a ton of descriptions here... What is a mechanical method, what is a physical one?
Noting processing aids used to produce food are food additives. Are there any processes which are expressly prohibited, and should these be mentioned as part of list?
Is enzymatic hydrolysis (e.g., production of oat milk) covered under the current list?
‘m.’ - is it appropriate to include ‘canning/bottling’ under processing when this part of production is packing/packaging/filling and not related to processing or preservation?
‘l.’ - gas flushing - question the relevance of including CO2/N2 references under this section given these gases are food additives approved under FSANZ.
Food additives and processing aids can only be allowed in organic food products if they are essential to the production of the product and allowed under this Standard.
Supplementation with vitamins of Organic flour, meal and products made from them are not allowed.
8.3 Composition, ingredients, additives, and processing aids
Edit:
“Processing methods should be mechanical, physical, or biological in nature and minimize the use of non-agricultural ingredients, processing aids and additives.” This is too generic.
Clarify:
A definition of processing aid and additives are needed. What is an additive? What is a processing aid? For example, is salt a processing aid, an additive or an ingredients? Are enzymes a processing aid, an additive or part of the biological control for processing?
8.3.1 Use of organic & non-organic ingredients
Edit:
First green box: For consistency - would suggest the wording of this section be standardised with the same wording under section 3.12.1.1. Furthermore, with reference to 3.12.1.1, this section references ‘allowed’ when describing non-agricultural ingredients and non-organic agricultural ingredients.
Second & third green box: Reference to ‘more than 70%’ versus ‘70% or greater’ as compared to section 3.12.1.2. Review cut-offs to ensure accuracy and consistency between sections.
Clarify:
“The operator must demonstrate that the non-organic agricultural ingredient cannot be sourced as organic in sufficient quality and quantity.” – what information would an operator need to demonstrate this? There are other considerations which need to be factored into the choice to source non-organic agricultural ingredients such as supply constraints and costs, both of which severely restrict the use of organic versus non-organic ingredients.
Fourth green box: With the understanding that processing aids are food additives (although they are treated separately under this Standard), should ‘processing aids’ be identified (under ingredients of non-agricultural origin) since ‘processing aid’ is mentioned specifically below ingredients a-d.
Micro Organism cannot be bioengineered or genetically engineered (GM) fermentation. ‘Made with Organic Ingredients’ more than 70% of the ingredients of agricultural origin (before processing, by weight or fluid volume, excluding added salt and water) must be organic.
8.3.2 Use of additives and processing aids
Reworded: food additives and processing aids allowed under this Standard, are only to be used under one of the following circumstances
For the production of organic micro-organisms and enzymes for processed food and feed (e.g., yeast), only organically produced substrate may be used. What about brewing enzymes with non-organic molasses? More clarification is needed here.
With reference to ‘d.’ should this statement be more explicit in terms of permitted under FSC and allowed under this Standard?
8.4 Specific requirements for Grape Wine
There should be more generic reference to alcoholic beverages, where overseas markets such as Japan's terminology could be used as a comparison.
..."the use of food additives and processing aids must be kept to a minimum and only where there is an essential oenological need This must be clearly described. What are additives and processing aid in wine? Who decide the oenological need? If the winemakers what to use it, then it is a need.
b. higher levels of total Sulphur dioxide than in previous years are necessary to get a comparable final product. - Too generic. A more specific definition is required.
The following packaging materials are not allowed for organic grape wine production:
PVC capsules for corking / capping; - What about primary fermentation on Methode traditionelle, using done with PVC capsules and up to now allowed?
9. Inputs requirements
9.2 Definition of an ‘Input’
Clarify:
As this term “input” is used in more than one section it should be defined in a general definitions section of the Standard.
Define ‘acceptable input” and “unacceptable input” and should also be moved to the definitions section.
It would be extremely helpful to provide clarity around the meaning of input, especially given an input is not an ‘ingredient’ including a food additive/processing aid.
"An input is a substance or product, which is brought onto OR PRODUCED ON, the.."
Suggest adding living organisms like microbes, soil enhancers, etc.
"An input is a substance a product or a living organisms, which is brought OR PRODUCED ON the.."
Suggestion to remove section describing what an input is not (a., b., c.)
Reference to substance/product – throughout the consultation document wording is prescriptive in terms of describing ingredients and products however under this section ‘substance’ has been introduced, and product used to describe ingredients (which have been described as such previously). This inconsistency is confusing.
Organic compost for sale is an organic product and an input. This is why the scope of this section should include at least some inputs to organic production systems as organic products.
Some classes of inputs will not require verification because they are generic substances which can be listed in a supplementary notice. However, some inputs, such as compost or other biologically derived products will clearly require verification under the Act.
In this draft there are two categories of input: ‘Acceptable input’ and ‘Unacceptable input’. The USDA uses the terminology “Allowed” and “Prohibited”. Until now, BioGro licensees (most NZ organic certified businesses) have had three categories of input: ‘Permitted’, ‘Restricted’ and ‘Prohibited’. By lumping all permitted and restricted inputs into the category of ‘acceptable inputs’ we may run into problems of overuse or irresponsible use. For example, over-application of soil amendments, where there has usually been a restriction placed on their use, such as a soil test or leaf test demonstrating a deficiency. How will limits be placed on the amounts of inputs to be used? We recommend that there are published restrictions placed on specific inputs that carry a risk of misuse or overuse, such as in a supplementary notice.
Section 9.4.1.1d refers to restrictions that may be placed on inputs for fertilisation and soil conditioning. So, it seems there are likely to be sub-categories of inputs within the ‘acceptable inputs’, i.e., permitted, and restricted. This needs to be clarified.
Section 9.5 also hints at sub-categories: “Acceptable inputs in organic production must be used in accordance with any conditions that are specified in supplementary notice.” It is certainly preferable, for some inputs, that restrictions are placed on their use. For example, minerals, both major and trace, which are overused can adversely affect soil health, sometimes for a considerable length of time.
An input is not:
A product or substance where all materials are sourced onsite for use only on the organic property (e.g., compost, cut and carry hay for own use);
This should be removed an ingredient (Codex definition: any substance, including a food additive, used in the manufacture or preparation of a food and present in the final product although possibly in a modified form).
This sentence should be removed – “synthetic product that cannot make an organic claim but is necessary for organic production”.
9.3 Emergency pest or disease treatment
Addition of not detectable in the product. In these emergency situations the focus should be on residues in the product.
9.4 Criteria for assessment of inputs
9.4.1 General criteria for assessment
Edit:
revise title - "Inputs used for SOIL OR PLANT NUTRITION OR..."
Clarify:
Section 9.4.1.1d refers to restrictions that may be placed on inputs for fertilisation, soil conditioning. Will there be sub-categories of inputs within the ‘acceptable inputs’, i.e., permitted and restricted?
Section 9.4.1.2 - Revise "Inputs used for the purpose of plant pest, disease and weed control:”
This is too generic, inputs for pest, weed and disease control must be free of synthetic chemicals (pesticides)
Remove - all chemicals that control pests have off target effects,
Revise their use does not have a harmful impact on the biodiversity, ecology (non-target organisms), plant and wildlife habitats of the operation... Remove "does not have" with "Should have minimum" impact… Otherwise, copper, Sulphur, etc. cannot be used.
9.4.1.3. Substances used for the purpose of livestock feed, nutritional elements, feed additives or processing aids - (b) on its own, could justify unapproved or restricted drenches being given to animals which would undermine consumer confidence.
9.4.1.4 - remove "essential" and change to NECESSARY. … additives and processing aids … if they are necessary.
9.4.1.4 - c. ‘they are found in nature’ – we already know that ‘ingredients of non-agricultural origin’ are permitted so therefore requirements for ‘natural’ under this section are contradictory.
(d) "cannot be preserved without them" - starts to discuss knowing about inputs, but again leaves it open to the supplementary notice. Then requiring ALL inputs to be justified prior to use is a big ask.
e. ‘no organic ingredients’ – should this also read ‘no non-organic agricultural ingredients’ especially given most likely the food additives and processing aids are non-agricultural ingredients?
h. since the overarching permissions are laid out in this Standard then I would suggest adding ‘and set out in this Standard’.
9.5 Use of Inputs
Clarify:
Section 9.5 also hints at sub-categories: “Acceptable inputs in organic production must be used in accordance with any conditions that are specified in supplementary notice.”
It is certainly preferable, for some inputs, that restrictions are placed on their use. For example, minerals, both major and trace, which are overused can adversely affect soil health, sometimes for a considerable length of time.
1. justification for necessity of use - change to "REASON FOR use"
Any inputs not listed in a supplementary notice must be assessed against the criteria for assessment as specified in this Standard before use: Assessed by whom? The operator, the CE, MPI? just assessed or approved?
All inputs must be listed in your OMP and prior to initial use of any input the following information must be documented:
1. justification for necessity of use, and;
2. demonstration that alternative options are unavailable or will be ineffective;
a. how the input will be used in practice.
This section feels incomplete. what information do the operator must supply to the CE?
How the input will be used in practice doesn't really describe what information should be kept and supplied.
Conclusion
In preparing this submission OANZ has been guided by its Technical Working Group which is a small group comprising representatives of the current organic certifiers, a representative from The Soil and Health Association on behalf of consumers and a convenor. We have also convened a wider cross sector group that has met regularly, including with representatives from MPI. That wider group has provided valuable feedback on the nature of the National Standard that we want for Aotearoa NZ. We have also been grateful for the “drop in” workshops run by MPI throughout the consultation process that have enabled us to keep up to date with MPI’s thinking and given us an opportunity to effectively provide continuous feedback.
During the consultation period we have also had assistance from three external experts who have assessed the draft standard for us against their expert knowledge of the many organic standards in force internationally. Their comments are included in the schedule to this submission.
Finally, we want to record our appreciation and thanks for the contribution the late Shona Scott made to this consultation process. She set the scope and collaborative tone of the consultation and made a huge contribution to the final shape of the Standard that sadly she will not see in its final form.
Schedule
External Reviewers:
Michelle Glogou PhD: Formerly with Standards NZ, CEO BioGro NZ, currently Executive Officer Plants Market Access Council.
Sachin Ayachit; Current General manager ACO Australia, formerly with NASSA and certification manager at BioGro NZ.
The feedback from Michelle Glogou PhD and Sachin Ayachit is attached and is considered a part of OANZ’s submission.
CONTACT
For further information please contact Derek Broadmore, OANZ Advisor
E: derek@estamore.co.nz
T: 027 443 1424