PO Box 13402
Wellington, New Zealand

GE-Free New Zealand

in food and environment (RAGE Inc.)

Action Templates - Call to Action

!!Current Actions!!

 Consultation paper on New Breeding Techniques

Food Standards Australia and New Zealand (FSANZ is reviewing the Food Standards code and calling for submissions on whether  "New Genetic Breeding Technologies" should be regulated.  

Comments to FSANZ on New Breeding Techniques consultation paper has been extended until 6pm (Canberra time) 19 April 2018  FSANZ Submissions Portal:  

Or email your submission to:  NBTConsultSubmissions@foodstandards.gov.au

Please also contact the Minister for Food Safety,  Hon Damien O'Connor  -  damien.oconnor@parliament.govt.nz  or  d.oconnor@ministers.govt.nz  and  cc. Secretariat@foodregulation.gov.au  Jenny Reid, she is on the Forum that oversees our food regulator FSANZ who want to allow this new GM into our food. Ask her to ensure these new GM techniques are regulated.  

Or go to Friends of the Earth submission tool and fill in the form  

We suggest that you ask for everything to be regulated including: gene editing, CRISPR, GM rootstock grafting, cisgenesis, intragenesis RNA interference and null segregants. Why? Because the research simply hasn't been done to show there are no unintended consequences and that these foods or techniques are safe for commercial use. They are required to be regulated under the Gene Technology Act 2000. This defines gene technology as "any technique for the modification of genes or other genetic material". It clearly includes all new GM techniques including RNA interference.

FSANZ convened an expert panel in 2012 - 13. It consisted almost entirely of genetic engineers holding gene patents, and therefore biased toward the new techniques as they did not declare their conflicts of interest. They concluded the majority of techniques did not pose significant safety risks and that many should be deregulated.  

This is in stark contrast to decisions of overseas government agencies.   There is insufficient knowledge of the risks of these techniques and all of them should be regulated, according to Austrian government agencies. The Norwegian Environment and Development Agencies concluded further biosafety research needs to be done before these techniques are commercialised.   New Zealand legislation has ruled they are Genetic Modification and therefore need regulation.   They cannot be used in organic food says the International Organic Federation IFOAM.  

We have a right to know what we are eating and growing. If these techniques are safe and valuable then pre-market testing, full labelling and follow up monitoring will confirm this.

Please make a submission by the 12th of April.

FSANZ Questions to answer  

3.1.1 Questions - Genome contains new DNA,

Do you agree, as a general principle, that food derived from organisms containing new pieces of DNA should be captured for pre-market safety assessment and approval?  YES. All new genetic modification techniques should be assessed for safety before being allowed in our food. They should also be labelled for consumer choice. This includes gene editing, GM rootstock grafting, cisgenesis, intragenesis RNA interference and null segregants.

Should there be any exceptions to this general principle?  NO

3.1.2 Questions - Genome unchanged by gene technology.

  Should food from null segregant organisms be excluded from pre-assessment and approval?  NO.

If no, what are your specific safety concerns for food derived from null segregants -  The assumption that there have been no unintended genetic changes needs to be tested before products derived from these techniques are allowed in our food. Hence the need for a full safety assessment.

3.1.3 Questions - Genome changed but no new DNA
Are foods from genome edited organisms likely to be the same in terms of risk to foods derived using chemical or radiation mutagenesis?   NO.
If no, how are they different? -  While chemical and radiation mutagenesis can increase the rate of random DNA point mutations, gene editing techniques cause DNA double strand breaks and can be used sequentially to make dramatic differences to DNA. They are also prone to additional unexpected mutations. They therefore carry a greater risk and warrant pre-market safety assessment and approval.
3.2 Questions - Other techniques
Are you aware of other techniques not currently addressed by this paper which have the potential to be used in the future for the development of food products?
RNA interference which can result in DNA methylation and gene silencing and has the potential to be used in the future for the development of food products. It poses unique risks such as gene silencing in non-target species that need to be assessed before it is allowed in food. Products produced using RNA interference should also be labelled as genetically modified for consumer choice.
3.2.1 Should food derived from other techniques, such as DNA methylation, be subject to pre-market safety assessment and approval?  
Yes.  DNA methylation  is quite clearly a genetic modification technique and can result in heritable genetic changes. It therefore needs to be assessed for safety before being used in our food.
3.3 Questions - Regulatory Trigger
Do you think a process-based definition is appropriate as a trigger for pre-market approval in the case of NBTs? -  YES, genetically modified organisms pose unique risks and a process based trigger is appropriate for assessing these risks.
If yes, how could a process-based approach be applied to NBTs?                          

All genetic modification techniques should be assessed for safety and these new GM techniques are quite clearly genetic modification techniques under   -The Hazardous substances and New Organisms Act (HSNO) 1996 includes all new GM techniques including RNA interference.   
Are there any aspects of the current definitions that should be retained or remain applicable?  
Standard 1.5.2 defines "food produced using gene technology" as   "a food which has been derived or developed from an organism which has been modified by gene technology." It states that "gene technology means recombinant DNA techniques that alter the heritable genetic material of living cells or organisms." This definition clearly includes gene editing techniques. The intent of the Gene Technology Act and Standard 1.5.2 was to capture all new GM techniques. Since RNA interference can also "alter the heritable genetic material  of living cells or organisms"  through DNA methylation the definition of gene technology in Standard 1.5.2 would be better changed to "gene technology means  in vitro  techniques that alter the heritable genetic material of living cells or organisms"  for clarity.
Further submissions to the Northland Regional Plan  Deadline:   3pm, Monday 26 March 2018.

Please make a "further submission" supporting the original submissions made by, GE Free NZ,   GE Free Tai Tokerau, Whangarei District Council, the Soil & Health Association Aotearoa NZ, Organics Aotearoa NZ (OANZ) and Te Waka Kai Ora on the important GE/GMO issue.

How to make your  further submission in response to the NRC proposed Regional Plan

  • Email:  submissions@nrc.govt.nz
  • Post: PRP Further Submissions, Northland Regional Council, Private Bag 9021, Whangārei Mail Centre, Whangārei 0148
  • Drop it in to one of the NRC offices (ring  0800 002 004 to find your local NRC office)

-  or, you can  Go to the NRC consultation site to make your further submission online  (but DO remember to save a copy of your further submission!)


Further information can be found here:  GE Free Northland  

The  Proposed Northland Regional Plan 2017

GE Free NZ is considering a Judicial Review over the approval for A1138 GM rice (17.3.2018)

GM rice correspondance and OIA reports on the GM rice.  

Food Standards Australia New Zealand (FSANZ) has just approved and gazetted GM rice (A1138) in case it contaminates the rice supply.   Threats of trade issues if contamination occurred, were alluded to if not approved.   There are no safety data provided by the applicants and only their unpublished data was relied on.   The Minister chose to ignore the absence of food safety studies when he did not call for a review.     

Please write to express your concerns over the lack of action to the Minister,  Hon Damien O'Connor -  damien.oconnor@parliament.govt.nz or d.oconnor@ministers.govt.nz

cc. Secretariat: Secretariat@foodregulation.gov.au

Free Post: Private Bag 18888,  Parliament Buildings,  Wellington 6160

Past Actions

Submission -  A1139 - GE potatoes.
Food Standards Australia New Zealand (FSANZ)

FSANZ approved the GE potato into the food chain.  

FSANZ decision (29 September 2017)  

GE Free comment press release  Food Standards Approval Ignores Possible Dangers Of GE Potatoes.

Application A1139


Name of submitter

Contact details

(address, email phone)

I ask that FSANZ decline the approval of application A1139 - Food derived from Potato Lines E56, F10, J3, W8, X17 & Y9.

I strongly object to FSANZ approving application A1139 - Food derived from Potato Lines E56, F10, J3, W8, X17 & Y9. I ask that FSANZ decline the application.

There is no comprehensive data showing evidence of unintended effects of the transgenic potato lines. It makes it mandatory for FSANZ to decline the approval.

  •   It is necessary for FSANZ to require whole genome sequencing to identify off-target mutations and also essential to ascertain the effects of unintended changes on global patterns of gene function.

FSANZ must require sequencing using molecular profiling analyses or 'omics"-

  • transcriptomics "” gene expression profiling,
  • proteomics
  • protein composition profiling,
  • metabolomics;
  • profiling of metabolites,
  • miR-omics – microRNA profiling

The best evidence available for effective safety assessment also requires long-term toxicity studies in established animal model systems. In the absence of these data to inform FSANZ, there can be no legal approval of A1139.

The APHIS documentation shows that these GE potato lines offer no nutritional advantage, as there are non-GE potato varieties that are naturally low in the desired profiles.   This demonstrates that there is no need for approval of the GE potatoes.

  • Instead of approving this application, FSANZ could instead recommend non-GE potato varieties that have naturally-occurring low levels of compounds responsible for acrylamide production. They could also educate food businesses on storing and cooking procedures that minimize acrylamide production..
  • The FSANZ assessment is compromised with respect to rigorous scientifc procedure.   These GE potato lines cannot be approved for the human or animal consumption, without the provision of comprehensive information regarding compositional differences to their non-GE counterparts.   Compostional analyses are very limited in that they can only assay for known compounds. Any novel compounds would not be detected in such analyses.  
  • FSANZ must provide evidence of safety, when eaten, in the lines that have significant variations in nutrients, or more importantly anti-nutrients. Anti nutrients such as glycoalkyloids can be highly toxic for consumers.  
  • The afore-mentioned studies have not been carried out and in their absence, there should be no legal approval of the A1139 application.



    Other risks from an approval by FSANZ that must be recognised as unacceptable to the public.

    • There is no consumer benefit or nutritional benefit from the GE potatoes listed in this application to outweigh known and unknown risks, compared to existing potato varieties that industry can use.
    • Whole or even very small parts of any uncooked (raw) tubers endanger New Zealand's biosecurity. GE potatoes could either potentially be planted without regulation or establish themselves as wild populations.
    • Approval will constitute a total disregard for the health of consumers,   by denying them their right to know what they are eating. There is no requirement for GE foods sold by fast food and other restaurants to be labelled as such, so as to inform consumers.This would leave the public in the dark and result in unwilling and unwitting consumption of GE potatoes.
    • The GE potato lines' compositions are significantly different to their parent line. This shows that the GE process has disrupted the cellular metabolism. As there are no feeding studies to evaluate these effects, it is not possible   to conclude that there are no biologically relevant differences.  

    Resource Management (National Environmental Standards for Plantation Forestry) Regulations 2017

    Environmental Guidance in Forestry Standards Is Welcomed (GE Free press release)

    The NES -PF has been in front of Minister for Primary Industry since 27 July 2016.   Update information says it is going to be considered in August 2017 - the GE clause still stands.

    National Environment Standard on Plantation Forestry (NES-PF). GE Free NZ Stop GE Trees principles align to the  Global Justice Ecology Project. We need to  protect native forests, and to defend the rights of  forest dependent  communities and Indigenous Peoples against  the uncontrollable and irreversible threats posed by the release of genetically engineered (GE) trees.

    Protect the right of regions to choose to say NO to GE trees.

    Date ...

    Dear .....,    

    I am writing to you regarding the  Resource Legislation Amendment Bill (RLA).

    I would like to ask you to call for the deletion of the clauses 360D, 43A (3A) and 43(3B).

    The clauses, if enacted, remove the democratic process around community protections for the environment through the RMA and  would allow GE plants and animals to be a permitted activity if approved by the EPA.    Any Council with precautionary GE provisions placed in their plans would have to remove them.   

    The damages from genetically modified organisms on New Zealand's ecosystems, including essential soil organisms, plants, birds and insects, could be both widespread, permanent and economically damaging.   These effects could be detrimental to biodiversity and trophic systems, undermining what the RMA is designed to protect.  

    replicas of the 6.4 clause in the stalled National Environment Standard on plantation forestry (NES-PF). Ministry of Primary Industries (MPI) recieved    

    16,000 submissions calling for the removal of clause 6.4 and supporting councils in their right to regulate land use provisions on GMOs.

    I urge you to ensure that these clauses are removed from the RLA.

    The decision we would like the Minister to make


    1.     Remove clause 360D

    Remove clauses



    !! The Resource Management Act (RMA)!! updated 18 September 2017  

    Fantastic news, communities are now able to make GMO Free provisions in their regional policy statements and local council plans.    The  new wording (360D) the  Maori Pary carved out  in the RMA allows Councils to place precautionary policies on GMO's without the interference of Ministers. (April 17)

    GE Free NZ submission.

    Local Body and Environment Select committee hearing

    March 2017 URGENT  Protect the right of Regions to say  NO  to GE".   Please send an e-mail to Marama Fox and all Parties asking them to ensure that clauses, 360D, 43A (3A) & 43(3B)are removed from the RLA.   This week the Bill will be debated clause by clause.   Below is a template letter for you to use and add any of your own wording. Click here to find  the email address  of all MPs.  


    Communities want and should have a say in how their livelihoods will be affected, at the moment they can do this through the Resource Management Act. However, clauses have been added in the proposed RMA, by Minister for the Environment and supported by Federated Farmers, preventing councils and communities from placing precautionary controls on the management of GMO's in their region. Please write, meet with your Labour Party, Green Party, Maori Party, NZ First and United Future MP's to insist on removal of section 360D. Write to the select committee expressing your views. Below is a template you might like to follow. (You can also include other concerns you have with the planned RMA changes).  

    Update on Whangarei and Far North District Councils submission rounds, 2014.

    This is now in front of the High Court for more information please go to GE Free Northlands page

    Information for what to put in your plan to implement a precautionary policy around GMO's

    Do you live in Northland or Auckland?   (or do you have an interest greater than the general public?)

    Do you want to protect the North's existing valuable GE-Free status? (GE=Genetic Engineering).

    Do you support your local councils ensuring that those who may wish to undertake risky GE experiments in our region should be financially liable for any harm caused by their activities?

    Do you want a complete ban on the release of all GMOs (Genetically Modified Organisms)?