PO Box 13402
Wellington, New Zealand

GE-Free New Zealand

in food and environment (RAGE Inc.)

Action Templates - Call to Action

!!Current Actions!!

Hazardous Substances and New Organisms (Hazardous Substances Assessments) Amendment Bill

Hazardous Substances Assessments : improving decision making

Make a submission : Submissions close: 3 October 2021

The links above will take you to the MfE paper on this Bill and also the online portal where you can make your submission. 
We have put together a list of suggestions that you might like to use to make your submission. 
To : Hazardous Substances and New Organisms Amendment Bill 2021

I would like to be heard (optional)

It is vital for the public interest that there be transparency and accountability around decisions. I oppose the removal of the notification of decisions and reasons for the decision.

  • This is undermined by the proposed repeal of the clauses – 29(3), 32(3), 38(5), 45(3) and 48(3) Determination of Applications.
  • The clauses are necessary for the accountability of any decision-making by the bodies that carry out approvals, and removal of these clauses will create a lack of transparency and accountability.

Regarding Genetically Modified Organisms - There should be a further addition to HSNO Sec: 62 Reassessment of 62 (d) any new organism released without controls.

  • There should be text change to move 62 (d) Any hazardous substance

To meet the purpose of the Act authorities need to be able to consider new information relevant to managing risks of any new organisms released without controls.

  • The Bill needs to it made clear who is responsible for recalling or reassessing new organism that has been released without controls if new information arises regarding their risk.
  • If a new organism that has undergone approval for release without controls is found to be harming the environment, affecting livelihoods or economic viability of communities, an avenue for reassessment must be in place.
  • As the experts in new organisms are in the Environmental Protection Authority (EPA), it is most appropriate for the HSNO Act to be the legislation for the necessary safety reassessment to occur.
  • This requires that a clause in HSNO Sec: 62 be included to address the omission.

Engagement and Local Government Information

  • It is important that all local authorities be given notification of applications and be permitted to decide there own level of interest.

The wording in HSNO amendment Bill sec: 53 4 (c) ii) "if, in the opinion of the Authority, the local authority is likely to have an interest in the application" is subjective and limiting to those councils who may have a new or unidentified interest.

  • The wording should be amended so the clause reads –

53 The Authority shall, upon receipt of the application, notify 4 (c) ii) all local authorities (within the meaning of the Local Government Act 2002).

Emerging biopesticide products

  • The Act must be fit for purpose to address risks in emerging novel techniques used in products e.g synthetic biology, nanotechnology and new RNAi biopesticides
  • To address this the Act should have an addition to Section 26 (3) a new clause (d)
  • 26 (3) (d) A hazardous substance that has been approved but is re formulated to contain or act like a genetically modified organism or contain nanoparticles must be publicly notified.

 Nga mihi, ........

We have put together our concerns regarding the Natural and Built Environment Bill.  Calls for submissions are due 4 August. 
Details on how to make contact: phone: 04 817 9520 email direct en@parliament.govt.nz and online submission here 

Please add you own lead in and thoughts these are just a guideline. 




do you want to be heard Yes/No

  • Community democracy, decision making, and recourse to the Environment court must be restored.
  • The RMA Natural and Built Environment Bill must allow communities and local councils to regulate land use activities relating to Genetically Modified Organisms within their region.
  • GE is a contentious issue that must be defined to allow the ability of communities to decide what types of land and water use they want. 
  • Local councils are the only place that communities can actively participate in civic democracy and have the power to submit on what type of land use and regional policies are best for their livelihoods, economy and future generations
  • The RMA's overarching Precautionary policy needs to be strengthened to include the important  precautionary GE/GM section in the current Act Section 360d
  • There must be a retention of the 30 years of case law that the Environment and High Courts have ruled.  These have set out clarification of the intention and responsibilities between central government and local government
  • Based on past experiences, centralisation of all local assets leads to privatisation. This prospect of loss of public interest and oversight must be prevented. 
  • The new legislation (NBER Bill) proposes more national direction through a National Planning Framework.  Local Bodies must be able to place higher standards than those set by a NPW. 
  • The role of Māori is a major issue for the Resource Governance legislation and local bodies must give tangata whenua the power to vote when engaging in decision making. Membership of Committees should have 2 local members:  a tangata whenua member elected by the iwi and a member elected by the the local community
  • Wording in relation to Genetically Engineered activities must be in the new Act and be defined to include Gene Edited organisms (which are GMOs as defined in Law in NZ and as ruled by the highest EU court) and organisms from synthetic biology.
  • Wording on Council's rights should be added to refer to GMO animals and forestry in addition to             GMO crops (currently mentioned in 360d)
  • Climate Change policy and replacement /changes to the RMA need to include:
    • Promoting sustainable food growing using regenerative organic agriculture methods.
    • Include Nature-based solutions to enhance and restore biodiversity and ecosystems (wetlands, soil, regenerative agriculture, native forests).
    • Reinserting and updating wording allowing the ability of local councils to make rules and policies.
  • The Purpose (Part 2, 5 (2 b)) should include biodiversity as a recognised priority alongside climate change. and should be safeguarding and restoring ecosystems, protecting ecological integrity in nature and protecting biodiversity
  • Environmental outcomes ( 8 (n) -  protection and sustainable use of the marine environmen should include mention of not just plastic pollutants to be: (n) Ensuring plastic and other persistent pollutants including living genetically modified organisms and organisms from synthetic biology do not enter waterways             and coastal marine areas.
  • Implementation Principles P(art 18 B ) should include: Allowing local bodies to place rules or types of rules that regulate the growing of crops, forestry and animals that are genetically modified organisms or organisms of synthetic biology. 

Indicate if you would like to be heard in any stakeholder engagement regarding the Natural and Built Environment Bill. 

Whangarei District Council Long Term Plans 2021-2031, closing date for submissions 1 April

Email: mailroom@wdc.govt.nz

Online: https://www.wdc.govt.nz/News-and-events/Have-your-say/LTP-consultation-2021-2031/LTP-feedback-form

and Kaipara District Council Long Term Plans 2021-2031, closing date for submissions 1 April haveyoursay@kaipara.govt.nz

Far North District Council Long Term Plans, closing date 6 April 2021-2031.https://www.fndc.govt.nz/Whats-new/Have-your-say/Long-Term-Plan-2021-31.

Email your submission to:submissions@fndc.govt.nz

Northland Regional Council  LTP, closing date 16 April 2021l 

Please click on the link to GE Free NZ e-petition on the FSANZ Act review. and sign this important petition. 

The New Zealand Australia Food Standards Authority is reviewing the FSANZ Act.  This is the Act that governs genetically engineered (GM and gene edited) organisms into the food chain.  FSANZ has signalled that they are looking at exempting certain GE foods from assessment.  This means that without labelling we will not know what is in the food chain all choice to avoid GE food will be removed food.  We, GE Free NZ have launched an e-petition which will be open until November 29th. The wording  of the petition is - 

Petition request

That the House of Representatives urge the Minister of Food Safety to advocate for the regulation, safety trials and full labeling of GM and gene edited food in the current review of the FSANZ Act.

Petition reason

I believe New Zealand consumers are concerned about the approval process of genetically modified and gene edited (GM/GE) food, particularly the signaled GE deregulation and lack of safety trials for GM food. We ask the review: 

-regulates and labels all GM and GE food 

-requires 90 day feeding trials on GM food 

-ensures submitters can challenge GM decisions 

-consults with stakeholders before ministerial forum approvals of GM decisions, and 

-requires full assessment of pesticide residues in GM food

 Thank you for your support. 


Application A1192- Food derived from herbicide-tolerant corn line MON87429

We are calling on our members to make a submission to A1192 the latest GE Corn application received by Food Standards Australia New Zealand (FSANZ), who is the trans Tasman food regulatory body that assesses GE foods.

Application A1192 Safety Assessment supporting document 

Details on how to make and send your submission on A1192 are here

DEADLINE FOR SUBMISSIONS- 6pm (Canberra time) 21 May

Submission are best sent electronically through the FSANZ website via the link on documents for public comment

You can also email your submission directly to submissions@foodstandards.gov.au

FSANZ received an application from Monsanto Australia Proprietary Limited asking for approval for food derived from a herbicide-tolerant corn line MON87429 to enter the food chain. 

Corn line MON87429 has been genetically modified to tolerate the spraying of glyphosate, glufosinate, dicamba,2,4-D and the aryloxyphenoxypropionate group of herbicides (known as FOPs) 8 in all, throughout the plants growing life.

POINTS TO MAKE - Please personalise your individual submission




The corn is developed to survive spraying with up to twelve different pesticides risks exposing consumers in New Zealand or Australia to increased levels of toxic chemicals.

The seed is coated with a neonicotinoid insecticide.

FSANZ has made its assessment wthout safety data on potential impacts of the GE corn absorbing multiple chemicals, or unintended mutations from gene editing and transgenic engineering

FSANZ assessment of MON 87429 is based on insufficient research and relies on inaccurate and purely theoretical data.

FSANZ has missed or selectively overlooks data that reveals problems.

Allowing a food to be sprayed with a cocktail of toxic herbicides which have a history of chronic health effects is irresponsible and endangers public health.

Data cited in Bayer’s application came from Monsanto, who have shown they cannot be trusted to avoid manipulation or not to omit data

FSANZ should prioritise standards that ensure food is fresh and pesticide free. Foods that are genetically modified, highly processed, and grown with pesticides are known to undermine the human immune system making us more vulnerable to illness.


Keep regulations on all GM methods including new CRISPR

Please support our Australian Friends who are asking people to write to the Australian Government to say No to the deregulation and exemption of GMO's.

Please follow the links for more information - 
All GMOs are now regulated.  The Morrison government wants to exempt many GM animals, plants and microbes so they do not need to be assessed by the OGTR.  They will go under the radar, unregulated, unlicensed and untraceable. There will be a GM free for all, with the OGTR, governments and the public in the dark. 
We need the Greens, ALP, and the cross-bench to say NO!! to deregulation in the Senate on September 17th. The ALP will decide its position next Tuesday, September 10th, so please take action now. Without them we won't have the numbers to keep GM regulated.
Message the ALP to back the Greens disallowance (before Tuesday)

 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.  


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)?