under the Official Information Act 1982
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4
To: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Update to AM24-0683 Exotic caulerpa Controlled Area Notice
Review and Targeted Engagement Process
Date 5 August 2024
Reference
AM24-0773
Purpose
•
As discussed with you at the Of icials Meeting today (5 August 2024), this
aide-memoire provides you with a further update to the information provided in
AM24-0683 (
Exotic caulerpa Controlled Area Notice Review and Targeted
Engagement Process) regarding the intended direction for using Controlled Area
Notices (CANs) for the management of exotic caulerpa in New Zealand.
Background
CAN Options presented in AM24-0683
1. AM24-0683 set out three potential options for the use of CANs. These are
summarised below:
a) location-specific CANs, in areas referred to as Exotic Caulerpa High Risk Zones,
that restrict anchoring, the taking of marine life, and impose cleaning
requirements;
b) a Regional Exotic Caulerpa CAN applying throughout the habitable range of
exotic caulerpa (Cape Reinga to East Cape) that would impose controls,
including cleaning obligations on craft that have anchored or equipment that has
under the Official Information Act 1982
been used; or
c) Cease all CAN controls for exotic caulerpa.
2. AM24-0683 set out that option 1(b) (A Regional Exotic Caulerpa CAN) would be the
option preferred by Biosecurity New Zealand (BNZ).
Updated Advice regarding immediately viable CAN options
Released
3. The existing Aotea Great Barrier Island and Te Rāwhiti CANs both expire on
30 September 2024. A decision on the future of these is a priority and BNZ will
engage with local communities and others on replacement options for these CANs
prior to this date.
5
s 9(2)(f)(iv)
4.
5.
6. The two key options that could be implemented for 1 October 2024 and that wil be
actively tested in targeted engagement as a replacement for the existing CANs are:
a) to develop location-specific controls in Exotic Caulerpa High Risk Zones, in
particular Great Barrier Island/Great Mercury Island and Te Rāwhiti; or
b) cease all CANs in relation to exotic caulerpa.
Minister / Minister’s Office
Seen / Referred
/ / 2024 under the Official Information Act 1982
Released
6
Priority – Low
Security Level – In Confidence
To: Hon Nicola Grigg, Associate Minister of Agriculture
From: Fiona Duncan, Director Regulatory Systems Policy
Gene Technology Reform and the Horticulture Sector
Date
19 August 2024
Reference
AM24-0754
Purpose
•
This aide-memoire provides information on the gene technology reform and potential
effects on New Zealand’s horticulture sector. Definitions of some key terms are
supplied in
Appendix One.
Gene Technology Reform
Background and context
1.
The Government has committed to the reform of New Zealand’s gene technology
regulations and legislation (the reform) and this process is now underway. The reform
adapts and improves the Australian gene technology regulatory system for
New Zealand’s unique context.
2.
An overview of the proposed regulatory regime is provided in
Appendix Two
Out of Scope
. Key differences from the current system include: the
establishment of a dedicated independent gene technology regulator, a hybrid
regulatory approach1, and a proportionate rather than precautionary risk management
system. A summary table comparing different regulatory approaches is supplied in
Appendix Three.
under the Official Information Act 1982
3.
In developing the reform, the Ministry of Business, Innovation and Employment (MBIE)
undertook targeted engagement with stakeholders, including research and industry
representatives, and Māori. The Industry Focus Group membership list is provided as
Appendix Four.
4.
Talking points to support your conversations on gene technology are provided in
Appendix Five.
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1 A combination of a process-based and outcome or trait-based approaches. New Zealand’s current approach
is process-based.
AM24-0754
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7
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8
10. The gene technology regulatory reform could impact market access for the organic
sector and others making GM-free claims. Different markets vary in their expectation
regarding product assurances for gene technology. In some markets manufacturers’
declarations or labelling claims are sufficient for products that are not the result of
gene technology 3, while others require government assurance.
11. The Ministry for Primary Industries (MPI) currently provides GM-free assurances for
exported seed and horticulture products to a range of export markets – such as apples
to India.
These assurances leverage off the administrative plant exports framework
and the Hazardous Substances and New Organisms Act 1996 (HSNO Act). GM
freedom is also an expectation for exports to other markets, based on recognition of
New Zealand’s GM-free status or the exporter providing declarations to their importer
or the importing authorities.
12. Under the proposed reform, market risks will be mitigated entirely operationally,
through assurance and verification activities overseen by MPI. This will necessitate
new or modified assurance frameworks across the primary export sector to enable
official GM freedom assurances to be provided to trading partners.
13. s 9(2)(f)(iv)
It is not
uncommon for GMO and non-GMO supply chains to coexist in the same country, for
example Australia and the United States of America.
14. s 9(2)(f)(iv)
Funding for the new regulator is
expected to come out of reprioritisation from MBIE’s budget. s 9(2)(f)(iv)
We anticipate a lag between any reform activity and economic benefits being seen
15. We expect to see a lag between reform activities and any economic return being seen
for those utilising gene technology, because of:
a)
where New Zealand’s existing research and industry priorities lie (with several
research programmes focused on genetic modification);
under the Official Information Act 1982
b)
the time required for legislative and regulatory development;
c)
trial and commercialisation timeframes; and
d)
the time needed for some trade partners, customers, and consumers to become
more accepting towards gene technology derived products.
Minister / Minister’s Office
Seen / Referred
Released
/ / 2024
3 Some markets require labelling for products of gene technology.
AM24-0754
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9
Appendix One: Key Terms and Examples
Biotechnology: A multidisciplinary field that involves harnessing biology to make useful
products.
Examples include the monitoring of dairy cow genetics for herd management, development
of methane inhibitors, and gene editing for new cultivar development.
Gene technology: A subset of biotechnology. Specifically refers to those technologies
used to modify the genome or its expression. Includes gene editing and genetic
modification.
Gene editing: A type of gene technology. Inducing specific targeted changes in an
organism’s DNA or the addition of genes from the same or closely related species, to
achieve a specific desired outcome.
What technology and resultant organisms are encompassed under this definition varies by
country. Edited organisms can be indistinguishable from conventionally bred counterparts.
Transgenic modification is often excluded from this definition in legislation.
Examples include PRLR-SLICK cattle, gene edited to have short hair to reduce heat stress,
and bio-fortified tomatoes edited to have high levels of vitamin D.
Transgenic modification: Introducing a specific gene or genes from one organism to
another organism to produce a desired trait. The two organisms are from different and not
sexually compatible species.
Examples include Rainbow Papaya and Bt corn. Rainbow Papaya was modified for
resistance to papaya ringspot disease using a gene from the papaya ringspot virus. Bt corn
was modified for insect resistance using a gene from soil bacteria.
Genetic modification: A type of gene technology. Involves adding novel DNA to an
organism from another, either related or unrelated species. Can include methods with
random or known outcomes (including gene editing).
What technology and resultant organisms are encompassed under this definition varies by
under the Official Information Act 1982
country. In New Zealand currently this is any changes made to the genome of an organism
by any biotechnological method. In international contexts this is starting to be used to refer
only to organisms modified by methods with random outcomes and/or transgenic
modification.
Currently in New Zealand, examples include both Bt corn (modified for insect resistance
using a gene from soil bacteria) and bio-fortified tomatoes (edited to have high levels of
vitamin D).
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AM24-0754
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Appendix One
10
Appendix Two: Overview of proposed gene technology regulation
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Appendix Two
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Appendix Three: Comparison of regulatory approaches
Regulatory
Process
Hybrid
Trait/Outcome
Trigger
Description
The use of gene technology Gene technology considered
Novelty of trait in the
to attain a trait in an
“low risk” are exempted from
organism and use triggers
organism triggers
regulatory oversight.
regulation as for those
regulation.
Organisms and products are
developed through
regulated as for those
traditional means.
developed through traditional
means.
Other gene technology are
still regulated proportionately
to risk.
Jurisdictions
New Zealand
Australia
Canada
European Union (EU)
United Kingdom
EU (proposed – plants only)
under the Official Information Act 1982
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AM24-0754
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Appendix Three
13
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14
Appendix Five: Talking points to support your conversations on gene technology
reform
Regulation
•
Our current gene technology regulatory system was designed when the technologies
were less predictable and precise than what is available now, and we took a much
more cautious, risk-averse approach.
•
This has resulted in a regulatory regime that is now overly prohibitive and is holding
New Zealand back while overseas competitors reap the benefits that modern gene
technologies have to offer.
•
The Government is committed to updating New Zealand’s gene technology rules to
enable our growers to safely access these technologies while also protecting those
who opt not to use these tools.
•
Our intention is to establish a new regulatory regime that allows New Zealand to
benefit from technological advancements while balancing strong protections for the
health and safety of people and the environment, modelled on Australia’s successful
approach.
•
This Government’s goal is to ensure gene technology regulation works in a way that
supports the horticulture sector to respond to changing consumer preferences, market
dynamics, and advances in technology.
•
The new reforms propose to manage the risks associated with gene technologies,
rather than prevent their use all together.
•
We also want to ensure that New Zealand growers can hold their own with our
international competitors in terms of productivity.
•
For our horticulture sector, this will mean enabling industry access to new tools to
produce sustainable, climate-friendly food, access to new cultivars, and ways to lift
productivity.
under the Official Information Act 1982
•
The Government’s role will be providing oversight where necessary, focussing on
managing risks rather than preventing the use of genetic technologies all together.
•
Unnecessary regulatory barriers will be eased, and the gene tech regulator will ensure
products of gene technology are regulated in a risk proportionate way with appropriate
protections for the heath and safety of people and the environment.
•
It is expected that a Bill will be introduced to the House by the end of this year. Once
Released
the Government has introduced legislation, I would encourage you to provide
feedback on the changes during the select committee process.
AM24-0754
Page 1 of 3
Appendix Five
15
Reputation, trade, and maintaining market access
•
We need to update our legislation in a way that provides new market opportunities
while ensuring New Zealand retains its reputation as one of the world’s most
sustainable provider of high-value food and primary products.
•
Gene technology can have a range of important benefits. For the horticulture sector, it
could mean giving the sector further tools to produce sustainable, climate-friendly food
to boost exports in our key export markets, and new technology to reduce climate
impacts from production – maintaining our reputation for sustainability.
•
We can use gene technologies to create higher value products that are more nutrient
dense, or that are without allergens, opening up the market to a wider range of
consumers.
•
This will add value to New Zealand’s food and fibre products and the provenance
stories that are an integral part of our export industry, particularly as we look to
increase the value of New Zealand’s exports now and into the future.
•
One way to ensure upwards consumption and market access with gene technology is
by ensuring that we match our approach to our trade partners as closely as possible.
Organics
•
Gene technology is not a silver bullet, but it can be another tool in our kit as we face
environmental and food security challenges.
•
We are giving food producers the option to create new products that are better suited
to changing conditions and consumer preferences, if they choose to.
•
We don’t expect to see a complete shift towards the use of gene technology - there
will always be demand for foods produced using the same, traditional methods we use
now.
•
It is not uncommon for GMO and non-GMO supply chains to coexist in the same
country for example Australia and USA. This is achieved through implementing
under the Official Information Act 1982
assurance and supply chain separation programmes, which minimise unintentional
crossover and help manage trade risks.
Biosecurity
•
Gene technology solutions could help to control exotic pests or diseases. They could
also help improve resilience of native species in the face of climate change.
•
Regulatory oversight would be maintained for gene technology activities that may
Released
present a known or unknown risk to the environment, allowing proportionate risk
management for exports or products we consume domestically. This will allow risk
management effort to be focused on the areas of highest risk or greatest uncertainty.
AM24-0754
Page 2 of 3
Appendix Five
16
Engagement with reforms during Select Committees
•
The Government welcomes feedback on the proposed legislation through the select
committee process.
•
The select committee process is likely to be held mid-2025 and the public and
interested groups will be able to make submissions to the committee.
•
When the proposed Bill is introduced later this year, information will be published on
the Ministry of Business, Innovation and Employment website.
under the Official Information Act 1982
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AM24-0754
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Appendix Five
17
To: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Red seaweed, Asparagopsis taxiformis detection
Date 19 August 2024
Reference
AM24-0802
Purpose
•
This aide-memoire informs you of the detection of red seaweed,
Asparagopsis
taxiformis, in New Zealand.
Situation
1. A new-to-mainland New Zealand red seaweed confirmed as
Asparagopsis taxiformis
(
A. taxiformis) has been detected at two locations in the North Island (Iris Shoal near
Kawau Island, and Whangārei Harbour).
2. During a biodiversity assessment associated with the dredging project to manage
exotic caulerpa in April, red seaweed was collected at Iris Shoal by the s 9(2)(a)
. On 31 July Northland Regional
Council (NRC) staff collected a sample of red seaweed after large volumes washed
ashore in Whangārei Harbour. In conjunction with Biosecurity New Zealand (BNZ),
NRC sent the sample to s 9(2)(a) for testing
3. s 9(2)(a) tested both red seaweed samples using taxonomic and molecular tests. s 9(2)(a)
notified BNZ the confirmed identification of
A. taxiformis lineage 2 on 9 August.
Background
under the Official Information Act 1982
4. There are six distinct genetic lineages of
A. taxiformis and determining the lineage
requires molecular testing. Lineage 2 has been detected at both Iris Shoal and
Whangārei Harbour.
A. taxiformis lineage 5
is native to the Kermadec Islands.
5. Lineage 2 is present at many locations around the world and is considered invasive in
the Mediterranean Sea where it grows to high densities under those environmental
conditions.
A. taxiformis meadows have been found to have less abundant and
diverse organisms associated with it compared to meadows of native seaweeds.
Released
18
6. Lineage 2 can survive water temperatures of 9 to 23 degrees Celsius, compared to
17 to 31 degrees Celsius of other tropical lineages.
A. taxiformis can grow in shallow
waters and up to a depth of 30 metres. There are two main life phases of
A. taxiformis,
and both can be spread via fragmentation.
New Zealand situation
7. A New Zealand native seaweed
Asparagopsis armata is present throughout
New Zealand waters and looks very similar to
A. taxiformis, requiring laboratory
testing to confirm which species of red seaweed is present.
8. It is likely that
A. taxiformis entered New Zealand on a vessel either associated with
biofouling or ballast water, on an anchor, anchor chain, or dirty equipment. These
pathways can also spread this species domestically.
9. Due to the distance of approximately 75 kilometres between Iris Shoal and Whangārei
Harbour,
A. taxiformis may well be present at additional locations and
may have been
established in the North Island for several years.
10.
A. taxiformis is likely to survive throughout the waters of the North Island, South Island
and Stewart Island. However, it is too early to understand whether
A. taxiformis will
affect biodiversity in New Zealand waters.
11. Natural spread via water currents cannot be prevented within New Zealand. Domestic
pathway management will reduce large scale spread. Boaties, fishers, and divers can
help stop the spread of invasive seaweeds by keeping their gear clear of any seaweed
before moving locations and keeping hulls clean.
Next steps
12. A risk assessment on
A. taxiformis is being undertaken to better understand impacts
on New Zealand coastal waters and biodiversity. We wil advise on options for next
steps once this is completed, which is expected in the next few weeks.
13. BNZ will continue to sample as part of regular surveil ance for marine pests at 12 of
New Zealand’s busiest ports to understand if it is present elsewhere.
under the Official Information Act 1982
Released
19
Communications
14. BNZ has updated Northland Regional Council on the situation and notified Ngātiwai,
the iwi with mana whenua over Whangārei Harbour. Northland Regional Council has
also reached out to two Ngātiwai hapu in the Whangārei Harbour area to inform them
of the situation. Ngāti Manuhiri and Auckland Council have been notified about the Iris
Shoal detection. At this point all stakeholders informed were pleased to receive early
notification and are awaiting further information.
Minister / Minister’s Office
Seen / Referred
/ / 2024
under the Official Information Act 1982
Released
20
To: Hon Todd McClay, Minister of Agriculture
Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Import health standard development and prioritisation
Date 21 August 2024
Reference
AM24-0812
Purpose
•
This aide-memoire provides information on import health standard development and
prioritisation frameworks.
Regulatory framework for import health standards
1. The Biosecurity Act 1993 (the Act) prohibits the importation of biosecurity risk goods1
into New Zealand unless there is an import health standard (IHS) in place. The IHS
must specify effective rules for managing the risks associated with that good so it can
be cleared for entry into New Zealand.
2. The process for developing an IHS is set out in the Act. The key steps are:
a) a risk assessment to determine the pests and diseases that could be associated
with the goods, and the potential impacts if they were to establish in
New Zealand;
b) identifying measures (actions) that wil be effective in managing the risks posed
by those pests and diseases;
c) preparing a draft IHS that sets out those measures;
d) consulting on the draft IHS; and
under the Official Information Act 1982
e) finalising the IHS, including responding to any requests for an independent
review (a process provided for in the Act).
3. The Act requires the same process for IHS amendments, although consultation is not
required for a minor or urgent amendment.
4. For some commodities, for example, some grains and seeds, trade can start once an
IHS is in place. For others, for example, all fresh produce and most animal products,
once an IHS
Released is in place, the exporting country can start negotiating with the
Ministry for Primary Industries (MPI) about the export protocol and/or export certificate
on the details of how it wil meet our import requirements.
1 A biosecurity risk good is anything that it is reasonable to suspect constitutes, harbours or contains an
organism that may cause unwanted harm in New Zealand.
21
under the Official Information Act 1982
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22
under the Official Information Act 1982
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23
Initiatives to speed up delivery of import health standards
Operational improvements
11. Since 2020, MPI has made several operational improvements that have:
a) reduced fresh horticulture IHS development from ~seven to ~two years;
b) strengthened regulatory practice to ensure IHSs are fit for purpose (and no more
restrictive than necessary); and
c) invested in technology to support importers, exporters, quarantine officers and
foreign counterparts easily access and understand biosecurity rules (the product
import and export requirements (PIER) tool).
12. There is more MPI can do to improve IHS development processes and efficiency. The
most time-consuming activities in IHS development are the risk assessment and
stakeholder consultation processes. MPI is trialling different approaches to risk
assessment to suit dif erent types of IHS projects. A recent trial reduced risk
assessment time from an estimated several years (using standard international
practice) to 13 months. Trials of other approaches are also returning good results.
13. The other focus area is to improve communication and engagement with domestic
stakeholders. Domestic horticulture producers do not typically welcome increased
horticulture imports as they can perceive that they bear the negative impacts of pest
and diseases risks associated with imports for the other sectors to gain from.
14. MPI has been putting more effort into its communication tools and products, and into
engaging early with domestic producers. The aim of this work is to help stakeholders
better understand how our proposed measures manage pest and disease risks. This
work does take significant technical and other resources, but it is hoped it will
eventually lead to more trust and confidence from domestic producers resulting in
fewer issues needing resolution after formal public consultation.
15. A large amount of planning, gathering information from trading partners, assessment
and technical resource goes into developing an IHS. It is important for the IHS
development system to be responsive to changing needs. It is also important, once an
IHS is in development, that MPI complete it to avoid damaging trade relationships or
under the Official Information Act 1982
losing the investment made.
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24
Legislative proposals
16. In addition, MPI is proposing changes to the Biosecurity Act 1993 to streamline IHS
development. If approved, these changes would be made through a Biosecurity Act
Amendment Bil . Hon Andrew Hoggard, Minister for Biosecurity, is considering lodging
a Cabinet paper seeking agreement to launch public consultation on policy proposals
during Q4 2024. The changes being proposed in the amendment Bil would enable:
a) technical amendments to an IHS without consultation;
b) a rapid amendment process for an IHS during the first year of trade without
consultation;
c) the authority to issue one-off import permits without an IHS;
d) the authority to issue permits to allow trade to continue while a suspended IHS is
reviewed; and
e) the authority to consult on risk management proposals, rather than the draft IHS
itself.
17. In addition, under Section 24 of the Biosecurity Act 1993, a person can request a
review of how scientific information was used during IHS development if they are
concerned that evidence did not receive sufficient consideration. This process not only
delays IHS review or development, but also diverts staff time from progressing other
IHSs, adding to the backlog of IHS work4. The Biosecurity Act Amendment Bil
proposals include options to improve the efficiency of the review process under
Section 24, or to remove it.
under the Official Information Act 1982
Minister / Minister’s Office
Seen / Referred
/ / 2024
Released
4 In the last three years, every large horticulture IHS and several others have either been subject to a s24
request, request for judicial review, or threat of s24 request (which delays work). Each request was eventually
dropped, or declined, as none met the necessary legal tests.
25
To: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Tomato Brown Rugose Fruit Virus in South Australia
Date 22 August 2024
Reference
AM24-0822
Purpose
•
This aide-memoire provides information about Tomato Brown Rugose Fruit Virus and
the recent detection of the virus in South Australia.
Background
1. Tomato Brown Rugose Fruit Virus (the virus) affects tomatoes and capsicums. It was
first identified in 2014, in Israel, and has spread to many other countries. It causes
significant production losses and negatively impacts the marketability of fruit but does
not present a risk to human health. More information about the effects of the virus on
tomato fruit is contained in the attached fact sheet produced by Tomatoes NZ. If the
virus were to establish in New Zealand, it could result in trading partners imposing
restrictions on our exports.
2. The virus is mainly transmitted to new sites via seeds for sowing but can also be
transmit ed via infected sap entering the tomato plant (for example, via machinery or
hands). Any object capable of spreading infected plant sap from one plant to another
can spread the virus. The virus is very stable and persistent outside of its host plants.
3. There are no treatments available for the virus. Control is through removing plants,
usually from the whole glasshouse, and disinfection.
under the Official Information Act 1982
4. The virus has previously been found in New Zealand, in 2020. The virus was present
at very low levels and the incident was managed. Seed testing methodology
requirements were tightened in light of this incident to reduce the possibility of a failure
to detect the virus at very low levels.
Detection in Australia
5. On Monday 19 August, Biosecurity New Zealand (BNZ) was notified by Tomatoes NZ
Released
(the industry representative body) of a detection of the virus in the North Adelaide
Plains, South Australia. We immediately contacted the Australian Department of
Agriculture, Fisheries and Forestry (DAFF) who confirmed, later on Tuesday, that the
26
virus had been detected for the first time in Australia, in two indoor production
facilities.
6. DAFF also confirmed that the South Australian Department of Primary Industries and
Regions has initiated a response, put in place quarantine measures and commenced
activities to trace movements from the affected facilities, test for the virus, and
ascertain to what extent (if any) it has spread.
7. No decision has been made as yet on whether to attempt to eradicate the virus from
Australia. We understand that, globally, few attempts to eradicate the virus have been
successful.
Tomato imports into New Zealand
8. Australia is the only country that New Zealand imports fresh tomatoes from. The
volume of imports has decreased significantly since 2011 following the ban of the
chemical dimethoate and increased glasshouse production in New Zealand. In recent
years imports have been confined to the June to October period. The total volume of
imports in 2023 was 524 tonnes. This year’s imports started in mid-July and total
156 tonnes to date. Since 2021, our import records show all imports have been of fruit
produced in Queensland.
9. Fresh tomatoes from Australia are subject to irradiation as a measure to manage the
risk from fruit flies. In addition, tomato imports are subject to a pre-export inspection by
the Australian authorities and certification as to freedom from pests and diseases, and
a verification inspection by BNZ on arrival in New Zealand.
10. New Zealand imports all its tomato seeds. While we do import tomato seeds from
Australia, it is a fairly minor supplier. Our import records show that since 2020, we
have imported 153 kilograms of Australian tomato seed, all of which was produced in
New South Wales.
11. The risks from the virus are managed in seed imports by either:
a) requiring that the seeds be produced in an area or place that is free of the virus;
or
b) requiring that the seeds be sampled and tested and found to be free of the virus.
under the Official Information Act 1982
New Zealand’s response
12. BNZ has requested that DAFF certify exports of tomato and capsicum seed for sowing
of Australia origin
only if the seeds have been tested and found free from the virus.
We have advised DAFF that, for the time being, we wil not accept any certification
that seeds are sourced from an area or place that is free of the virus – we require
them to be tested. This wil be reviewed when there is more certainty about the extent
of any spread w
Released ithin Australia.
13. BNZ has temporarily suspended the importation of fresh tomatoes from Australia, with
the exception of tomatoes produced in Queensland. DAFF has advised that tracing
activities have not identified any movement of plant material from the affected
27
properties to Queensland. There have been no reports to date of the virus in
Queensland.
14. The changes to import requirements have been notified to our border clearance
services teams and to importers and have been communicated to DAFF and
Tomatoes NZ.
15. We understand that some New Zealand importers, following contact from
Tomatoes NZ, have cancelled orders for fresh tomato exports from Australia. These
are business decisions taken independently of any official biosecurity measures.
16. We are engaging daily with Tomatoes NZ on this issue and wil continue to do so as
the situation in Australia is worked through and clarified.
17. BNZ needs to understand the source of the infected seed lot in Australia. Both
countries source seed from similar suppliers offshore and New Zealand also receives
third country seed re-exported from Australia (albeit in small quantities). We have
asked DAFF for specific information out of their tracing exercise, and to provide us
on-going updates on the results of the back-tracing to the source of the infected seed
lot.
Other Ministerial interests
18. We understand that Hon Nicola Grigg (Associate Minister of Agriculture) has been
contacted by growers to raise concerns about the detection of the virus in Australia.
You may wish to forward a copy of this aide-memoire to the Minister for her
information.
under the Official Information Act 1982
Minister / Minister’s Office
Seen / Referred
/ / 2024
Released
28
Appendix One: Fact sheet produced by Tomatoes NZ
under the Official Information Act 1982
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29
under the Official Information Act 1982
30
Released
Priority – Low
Security Level – In Confidence
To:
Hon Andrew Hoggard, Minister for Food Safety
From: Vincent Arbuckle, Deputy Director-General New Zealand Food Safety
Update on the Future of Certification Programme
Date
26 August 2024
Reference
AM24-0779
Purpose
•
This aide-memoire provides you a progress update on the Future of Certification
Programme (the Programme). Please refer to AM24-0258
Future of Certification
Programme Update for background information. The programme will replace and
modernise the Ministry for Primary Industries (MPI) existing certification systems and
processes for exports and imports with a new system called MPI Trade Certification.
Key messages
1.
MPI certification systems are essential to enabling the two-way trade of primary
product exports and imports by exchanging the official assurances (usually in the form
of export/import certificates) with overseas governments that accompany those
products. The certification systems enable $33 billion of export trade each year and
help protect New Zealand from harmful pests and diseases.
2.
AM24-0258 advised that Tranche 1 (MPI to digitise a request for a simple export
certificate) was completed. Tranche 2 (Acceptance of electronic import certificates) is
now also complete. The system is performing well.
3.
The Programme has now turned its focus to Tranche 3, which will complete the build
of all core functionality and transition the wine industry into the Trade Certification
under the Official Information Act 1982
System. The first wave of users is due to transition to the new system by the end of
October 2024. This timeframe is tight given the scope of the work that remains. The
Programme is actively working on options for delivery to meet the wine industry’s
priorities.
4.
Industry engagement remains an important part of the Programme. The Programme
has an active Industry Advisory Group which meets every six weeks. This group
includes representatives from all major range sectors. A list of representatives is
Released
included in
Appendix One. There is also bespoke engagement with industry sectors
through well-established MPI-industry sector meetings and Tranche specific
engagement, such as that with the Wine industry in Tranche 3.
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5.
MPI is actively working on cost recovery models and options. At this stage, the cost
recovery process and indicative timeframes have been shared with industry. No detail
of the possible frameworks or indicative costs has been shared with industry at this
stage as they are not yet finalised. You will be briefed fully on cost recovery proposals
in early October.
6.
Independent assurance activities remain an important part of ensuring the Programme
is operating and delivering effectively. MPI and Deloitte have met with the Treasury
New Zealand to initiate the Gateway 4 Review - Readiness for service review planned
for mid-February 2025. It is likely you will be invited to participate in this process as
the responsible Minister. MPI has engaged KPMG to conduct Independent Quality
Assurance and Technical Quality Assurance of the Programme.
7.
The affordability challenges reported to you in AM24-0258 have been managed.
However, the Programme still has over a year to run and a significant amount of work
to deliver in that timeframe. Governance and the Programme are actively working on
options to ensure costs are contained. Officials we will keep you
Programme Update
8.
The Programme Build and Transition plan currently remains to be delivered in six
Tranches, in order to manage risk in both the build and in transition sector. The
Tranches are:
a)
Tranche 1 Digitise a request for a simple export certificate;
b)
Tranche 2 Acceptance of electronic import certificates;
c)
Tranche 3 Core build complete; wine sector transition;
d)
Tranche 4 Phytosanitary build complete; phyto sector transition;
e)
Tranche 5 Animal products build complete; animal products sector transitioned
except for large exporters; and
f)
Tranche 6 Animal products transition for large exporters.
9.
Tranche 1 (MPI to digitise a request for a simple export certificate) was successfully
completed.
10. Tranche 2 (Acceptance of electronic import certificates) is now also complete. The
system is performing well. As at 16 August 2024, 1,619 import certificates had been
under the Official Information Act 1982
collected from 15 different countries. Overall, the feedback received to date has been
consistently positive and encouraging from users. A recent survey concluded the
majority of users found the new system easier to use compared to than the previous
system.
11. The Programme has now turned its focus to Tranche 3, which will;
a)
complete the build of all core functionality; and
Released
b)
transition the wine export, Free Sale and Organics Certificates to Great Britain
into the Trade Certification System.
12. Transitioning the wine industry is the focus of Tranche 3. The first wave of users is
due to transition to the new system by the end of October 2024. The second wave is
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currently due to be transitioned by the end of 2024. This transition is important to
industry as it will enable them to realise the benefits from the NZ-EU and NZ-UK
FTAs.
13. The October 2024 timeframe for the first wave of wine users is tight given the scope of
the work that remains. It is important that the products delivered by the Programme
meet industry expectations. The Programme is actively working on options to ensure
the optimal outcome for the wine industry.
14. Some planning for future Tranches (Tranche 4, Tranche 5, and Tranche 6) has also
occurred, but at this stage remains at a high level.
Affordability
15. AM24-0258 referred to affordability challenges driven by costs which were either not
captured in the Vendor Confirmation Phase costings, or not treated correctly from an
accounting perspective. This affordability challenge has been addressed through a
reduction in support costs, deferral of non-essential elements of solution scope,
reduction in MPI labour costs during the programme, re-allocation of IT licence costs
and accounting treatments. The Programme now has approximately s 9(2)(b)(ii), s 9(2)(i)
contingency.
16. Whilst this is a positive development, the Programme still has four major tranches and
over a year to run. Affordability challenges are likely to emerge during this period. Cost
containment and other measures to address affordability are actively being
implemented.
Engaging with industry stakeholders
17. Industry engagement remains a priority activity for the Programme. Engagement
includes an MPI Trade Certification webpage, regular meetings with industry through
all-industry updates and workshops or focused meetings, workshops with key sector
groups and an Industry Advisory Group. Industry continues to be actively involved in
providing feedback on the design of MPI Trade Certification.
18. AM24-0258 referred to the establishment of a MPI Trade Certification Industry
Advisory Group. This Group has now met several times and is proving to be an
under the Official Information Act 1982
effective forum for MPI to engage directly with industry. The Programme is now
investigating how Governance may be able to engage with more senior industry
leadership (Chief Executives). Overall, feedback from industry about Future of
Certification remains supportive.
Cost recovery 19. The costs and the equity of how costs are recovered are important for industry.
Released
The Detailed Business Case presented to Cabinet in 2022 presumed that following
implementation of the new certification system, ongoing funding will be fully cost
recovered. At this stage, the costs, and how these costs are to be distributed between
users, are still being confirmed and are yet to be discussed with industry.
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20. To ensure the costs of the new system costs are recovered transparently, efficiently,
and equitably, MPI is resetting existing cost recovery mechanisms. For example, one
current charge includes a per second charge for system use. As processing time is no
longer a cost driver other charging options are being developed for industry
consultation. MPI will provide a briefing alongside draft proposals to you later this
year, ahead of consultation. New cost recovery arrangements are anticipated to be in
place by 1 July 2025.
Independent Programme Assurance
21. The oversight provided by the Programme’s Governance Group is supported by
Deloitte’s internal assurance, internal MPI assurance and independent assurance.
22. The independent assurance includes:
a)
independent quality assurance (IQA) reviews conducted by KPMG;
b)
technical quality assurance (TQA) also conducted by KPMG;
c)
‘Gateway’ reviews conducted by an independent panel appointed with the
support of the Treasury’s Gateway Review team; and
d)
procurement probity review by McHale Group.
23. MPI and Deloitte have met with Treasury to initiate the Gateway 4 Review - Readiness
for service review planned for mid-February 2025. The review itself is preceded by
several planning activities. The draft timeline is currently as follows:
a)
Gateway Assessment Meeting: between 9 and 16 December 2024.
i.
Planning workshop: 27 January 2025.
b)
The Gateway Review: 10 February to 14 February 2025.
24. Previous Ministers for Food Safety have been involved as interviewees in past
Gateway Reviews for the Programme. You may wish to be involved in the next
Gateway Review to provide Ministerial-level endorsement and assurance for the
programme. Officials can discuss this with you as details are confirmed with Treasury
and engage with your office.
25. MPI has engaged KPMG to conduct Independent Quality Assurance and Technical
under the Official Information Act 1982
Quality Assurance of the Programme. These activities are starting this month. The
Independent Quality Assurance review will focus on Programme structure and
processes. The Technical Quality Assurance review will focus on the Programme’s
ability to deliver the remainder of the IT solution scope and readiness for transition to
business-as-usual.
Programme Risks
26.
Released
The Programme’s Governance Group is currently managing three key high-level risks:
a)
the affordability challenges mentioned earlier;
b)
substantial software configuration remains to be done across the remaining
Tranches, and so delivery risk (time and cost) remains; and
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c)
the amount of change to deliver the programme is greater than the capacity of
both MPI and the sector to absorb.
27. These types of risks are common in delivering a complex, multi-year, Information and
Communications Technology programme across MPI and a diverse primary sector.
AM24-0258 provides detail on the risks and mitigations.
28. MPI officials will discuss this paper with you on 28 August.
Minister / Minister’s Office
Seen / Referred
/ / 2024
under the Official Information Act 1982
Released
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Appendix One: List of Future of Certification Industry Advisory Group
Representatives
1.
Fonterra
2.
Halal
3.
Dairy
4.
Seafood
5.
Meat and meat products
6.
Seed
7.
Forestry
8.
Wine
9.
Organics
10. Horticulture and plant
11. Live animal exports
12. Verifiers
13. Apiculture
14. Custom brokers and freight forwarders
15. New Zealand Food and Groceries Council
under the Official Information Act 1982
Released
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Appendix One
36
under the Official Information Act 1982
Released
37
Document Outline
