Submissions
Submissions
Reassessment of Chlorpyrifos
February 2025
HortNZ supports the EPA’s proposed ban on chlorpyrifos due to potential risks to people and the environment, and to align with similar international regulators, on the proviso that the EPA actively prioritises the registration of new chemistry and label claims.
PDF, 351 KB.
Resource Management (Consenting and Other System Changes) Amendment Bill
February 2025
HortNZ supported the bill with amendments to enable the supply of fresh fruits and vegetables, protect highly productive land and reform the consenting process.
PDF, 555 KB.
Gene Technology Bill
February 2025
HortNZ sought pragmatic changes to the regulation of gene technology, to ensure that it is risk proportionate and mitigates against potential trade and market access risks.
PDF, 462 KB.
Proposed changes to the seeds for sowing Import Health Standard
January 2025
HortNZ opposes the proposed removal of import requirements and quarantine status for Plum pox virus on imported Prunus seeds
PDF, 286 KB.
Second Nationally Determined Contribution
December 2024
HortNZ supported a strong international climate change target which supports diversification to horticulture as a low emissions land use.
PDF, 396 KB.
Biosecurity Act 1993 Proposed Amendments
December 2024
HortNZ broadly supports the proposals, but calls for detailed impact analysis, equitable cost-sharing between government and industry, modernized enforcement, fair compensation, and improved collaboration, while raising concerns about financial impacts and GIA changes.
PDF, 548 KB.
Call for information on oxadiazon
November 2024
HortNZ submitted information to the EPA regarding the use of oxadiazon in horticultural sectors, specifically blackcurrants and onions, emphasizing its importance in effective weed control.
PDF, 469 KB.
Building Resilience to Hazards Long-term Insights Briefing
November 2024
HortNZ described the effects of natural hazards on horticulture for domestic food security and resilient exports, while calling for national spatial planning to prioritise infrastructure investment.
PDF, 303 KB.
Accredited Employer Work Visa
October 2024
HortNZ supported strengthened accreditation requirements with a simplified system for trusted employers.
PDF, 628 KB.
Health and Safety Regulatory Reform
October 2024
HortNZ advocated for enhanced, industry-specific guidance, greater flexibility within regulations to accommodate varied business sizes and seasonal operations, and a more balanced, educational approach from WorkSafe.
PDF, 317 KB.
ACC Levy Proposed Increases
October 2024
HortNZ opposed increases to the motor vehicle and employer liable earnings levies.
PDF, 257 KB.
Inquiry into banking competition
September 2024
HortNZ discussed how horticulture’s low emissions and industry assurance should be recognised in bank’s sustainability accounting.
PDF, 300 KB.
Grocery Supply Code Review
September 2024
HortNZ advocated for the Code to include all first-point-of-sale transactions and for the Commerce Commission to require supermarkets to report on their margins.
PDF, 504 KB.
Vocational Education Proposal
September 2024
HortNZ advocates for a nationally consistent, system-level approach to vocational education that is strongly connected to industry, and values workplace-based and strategically important provision.
PDF, 483 KB.
Agricultural and Horticultural Products Regulatory Review
September 2024
HortNZ supported the review and proposed regulatory reforms and immediate actions to help growers balance environmental protection, food security, and export growth.
PDF, 933 KB.
Definitions for gene technology and new breeding techniques
September 2024
HortNZ indicated that we are still actively consulting with growers on GE, so we could not comment specifically on this proposal.
PDF, 245 KB.
Making it easier to build granny flats
August 2024
HortNZ recognised that granny flats can support workers accommodation but expressed concern over the implications of this policy for shifting general housing into the rural environment.
PDF, 383 KB.
Occupation Classification
August 2024
HortNZ supported creating an independent New Zealand occupation classification system.
PDF, 264 KB.
New Zealand's second emissions reduction plan
August 2024
HortNZ advocated for horticulture's place in New Zealand's emissions reduction strategy as a low-emissions land use.
PDF, 392 KB.
Proposed regulatory regime for Carbon Capture, Utilisation, and Storage (CCUS)
August 2024
HortNZ described how greenhouse growers use carbon dioxide to boost plant productivity.
PDF, 395 KB.
Proposal to suspend unused and out-of-date IHSs for nursery stock
August 2024
HortNZ commented that MPI suspends species and genera irrespective of whether industry has plans to import, and requests review and reactivation of these pathways.
PDF, 362 KB.
Application to import or manufacture Sivanto Prime
August 2024
HortNZ supported the approval of this new mode of action insecticide and requested that EPA’s controls remain proportionate to the low risks it poses.
PDF, 807 KB.
Climate Change Response (Emissions Trading Scheme Agricultural Obligations) Amendment Bill
July 2024
HortNZ called for further action on agricultural emissions and raised challenges greenhouse growers still face with the ETS, including a proposed reduction in the allocative baseline.
PDF, 429 KB.
Resource Management (Freshwater and Other Matters) Amendment Bill
June 2024
HortNZ supported amendments to speed up changes to national direction. We also sought freshwater policy changes through the RMA related to discharges, Te Mana o te Wai and freshwater farm plans.
PDF, 620 KB.
NZ ETS Unit Settings and Annual Regulatory Updates 2024
June 2024
HortNZ called for the government to take the Climate Change Commission’s advice and establish regulatory certainty for participants in the Emissions Trading Scheme.
PDF, 262 KB.
Proposed imports of mangosteen and rambutan plants for planting
January 2024
HortNZ submitted on the proposed changes to the import requirements of mangosteen and rambutan plants for planting.
PDF, 292 KB.
NZFS Import requirements for frozen berries
January 2024
HortNZ welcomed the recognition by NZFS that third-party certification programmes can provide food safety assurance for international trade and regulatory bodies.
PDF, 530 KB.
Review on whether emissions from international shipping and aviation should be included in the 2050 target
May 2024
HortNZ argued that New Zealand should not include international transport emissions in our net-zero target until green shipping and aviation alternatives are domestically available.
PDF, 521 KB.
Primary Industries Regulatory Amendment Bill
May 2024
HortNZ largely supported the omnibus bill to make multiple minor amendments to multiple Acts, with two recommendations for details of the amendments proposed for the Biosecurity Act 1993.
PDF, 272 KB.
Science System Advisory Group
May 2024
HortNZ stressed the importance of end-user focused research and innovation for horticulture industries and society.
PDF, 298 KB.
Risk Index Tool
May 2024
HortNZ provided feedback on the Risk Index Tool Implementation Guidance with a focus on highlighting the risks of using it for Commercial Vegetable Use.
PDF, 482 KB.
Import Health Standard for tapa mats
December 2023
HortNZ opposed MPI’s proposed changes to import requirements for Pacific-style tapa mats.
PDF, 351 KB.
ACVM requirements for agricultural chemical registration
December 2023
HortNZ reminded ACVM that unnecessarily restrictive registration processes can effectively restrict the crop protection tools available for NZ growers.
PDF, 530 KB.
Preliminary consultation for reassessment of synthetic pyrethroids
April 2024
HortNZ rationalises the critical use of synthetic pyrethroids (SP) for the horticulture industry following the EPA's call for information on potential reassessment.
PDF, 674 KB.
Targeted changes to the RMA
April 2024
HortNZ responded to Hon Chris Bishop's letter requesting short-term amendments to the RMA. We called for recognition of the national importance of fresh fruits and vegetables.
PDF, 596 KB.
Fast-track Approvals Bill
April 2024
HortNZ sought amendments to enable projects that support horticulture and ensure efficiency, transparency and fairness in the fast-track process.
PDF, 425 KB.
Helping nature and people thrive – Exploring a biodiversity credit system
November 2023
HortNZ supported a biodiversity credit system that rewards the kinds of biodiversity projects possible for horticultural businesses.
PDF, 718 KB.
Proposed National Policy Statement for Natural Hazard Decision-making
November 2023
HortNZ advocated for a risk-based decision-making framework for natural hazards that recognises the differences in rural risk.
PDF, 1.8 MB.
Advancing New Zealand's energy transition
November 2023
HortNZ advocated for green hydrogen shipping and trucking and called for accessible energy options for covered cropping and new rural electricity connections.
PDF, 475 KB.
Inquiry into climate adaptation and community-led retreat
November 2023
HortNZ advocated for a climate adaptation and retreat risk-accounting framework that recognises that horticulture has a different risk profile than other land uses.
PDF, 1.2 MB.
Proposed risk measures to manage phytoplasmas on ornamental plants for planting
March 2024
HortNZ opposed MPI’s proposed risk measures to manage phytoplasma on ornamental plants for planting.
PDF, 280 KB.
Cost recovery proposal to maintain and expand NZFS core regulatory services
March 2024
The horticulture industry viewed this cost recovery proposal as unfair duplication for a sector that is already heavily investing in food safety standards.
PDF, 544 KB.
Import Health Standard for fresh citrus
October 2023
HortNZ is concerned that key risk assessment documents were not provided
PDF, 403 KB.
Annual Review 2024: Proposed changes to MPI’s cost recovery settings
March 2024
On behalf of 25 product group and grower associations, HortNZ firmly opposed the proposal for large increases in the fees and levy charged by MPI’s Agricultural Compounds and Veterinary Medicines group.
PDF, 472 KB.
Changes to MPI's Level 3B post-entry quarantine fees and services
October 2023
HortNZ requested that MPI fully assesses and mitigates the adverse impacts of the proposed substantial increases in PEQ fees for horticulture growers.
PDF, 360 KB.
Changes to phytosanitary requirements for imported fresh fruit and vegetables
October 2023
HortNZ requested that the standard provides more guidance on how to select an appropriate sample size for phytosanitary inspections.
PDF, 388 KB.
Amendments to the NPS-HPL
October 2023
HortNZ compiled evidence to support allowing greenhouses on highly productive land through an amendment to the National Policy Statement for Highly Productive Land.
PDF, 2 MB.
GMO Regulations for Laboratory
August 2023
HortNZ recommends a simplification of the regulatory process for genetically modified organisms with a risk tier approach.
PDF, 489 KB.
Import Health Standard for fresh pineapples
August 2023
HortNZ supported MPI's approach and made recommendations to ensure changes to the IHS do not increase biosecurity risks to horticulture.
PDF, 341 KB.
Import Health Standard for importing grain and seeds
July 2023
HortNZ made recommendations to ensure changes to the IHS do not increase biosecurity risks to horticulture.
PDF, 188 KB.
National Organic Standard Regulations Proposals: Phase two
July 2023
HortNZ called for inclusivity and the adoption of the internationally-recognised IFOAM principles in the National Organic Standard.
PDF, 299 KB.
Grocery Supply Code of Conduct
July 2023
HortNZ advocated for stronger protections for growers in supply agreements and called for ongoing training to ensure suppliers and retailers understand their legal rights and obligations.
PDF, 547 KB.
ETS Price Settings and Controls 2023
June 2023
We advocated for the importance of industrial allocations and argued that the government should "let the market decide" on ETS outcomes rather than employing price controls.
PDF, 260 KB.
Draft Advice for the Second Emissions Reduction Plan
June 2023
HortNZ sought support for horticulture as a low emissions land use and for decarbonising covered cropping/horticulture-related transportation.
PDF, 830 KB.
Burning Cyclone and Flood Waste
June 2023
HortNZ, representing growers affected by Cyclone Gabrielle, requested an Order in Council to provide a legal pathway (through a permitted activity status) for landowners to burn mixed waste resulting from the disaster on their properties.
PDF, 321 KB.
National Organic Standard
June 2023
We argued that the National Organic Standard should align with existing standards to reduce compliance costs and stay in accordance with our trading partners.
PDF, 364 KB.
Fast track consents and Te Mana o te Wai
February 2024
HortNZ called for a defined purpose for the Fast Track Consents Bill to prioritise projects that promote the health of the nation, climate change and economic development.
PDF, 357 KB.
Grocery Industry Dispute Resolution Scheme
February 2024
HortNZ advocated for a fair dispute resolution scheme designed to mitigate the power imbalance between retailers and suppliers.
PDF, 355 KB.
Importing requirements for hop plants for planting
September 2023
HortNZ advocated to MPI to ensure that the proposed requirements for the importation of Humulus plants will not put other crops within New Zealand at undue risk.
PDF, 327 KB.
Deferral of NZ ETS reporting obligations for animals-farmer activities
September 2023
HortNZ supported deferring the ETS backstop for animal farmers.
PDF, 252 KB.
Consenting improvements for renewable electricity
May 2023
HortNZ argued that the National Policy Statement for Electricity Transmission should explicitly align with the National Policy Statement for Highly Productive Land to avoid inappropriate development of elite soils.
PDF, 275 KB.
New Zealand's Approach to International Climate Negotiations
May 2023
Our submission to the Ministry for Foreign Affairs and Trade (MFAT) advocates for horticulture as both a low emissions food source and a solution for reducing world hunger.
PDF, 583 KB.
Measures for Yellow Peach Moth
May 2023
HortNZ wrote a submission on the government proposals to manage the yellow peach moth on lychee, longan and pear from Australia, the Republic of Korea, Taiwan and Thailand.
PDF, 271 KB.
Hazards from Trees Regulations
May 2023
These regulations cover the trimming of trees and rules limiting where growth of trees can occur near powerlines infrastructure.
PDF, 392 KB.
EV Charging Strategy
May 2023
HortNZ described the importance of on-farm vehicles and expressed support for an electric vehicle charging strategy and national framework.
PDF, 226 KB.
Plant Germplasm for Propagation
May 2023
HortNZ wrote a submission on the government proposals on changes to the requirements for plant germplasm for propagation.
PDF, 304 KB.
Proposed amendments import requirements for fresh fruit and vegetables from Australia
May 2023
In a joint submission with seven product groups, HortNZ argues for more transparency, consultation, and analysis before decisions are made on Australian fresh produce imports.
PDF, 235 KB.
ACVM levy
April 2023
HortNZ wrote a submission on the government proposals to increase the Agricultural Compounds & Veterinary Medicines (ACVM) levy.
PDF, 275 KB.
Ministerial Inquiry Land Use
April 2023
The Ministerial Inquiry into Land Use (MILU) is an investigation into why damage from woody debris and silt was so terrible after Cyclone Gabrielle in Tairāwhiti Gisborne and Wairoa.
PDF, 2.5 MB.
Enhancing economic resilience of industries and communities to persistent supply chain disruptions
April 2023
HortNZ welcomes efforts to identify policies and interventions that can enhance New Zealand’s economic resilience to supply chain disruptions.
PDF, 326 KB.
Biosecurity (Information for Incoming Passengers) Regulations
April 2023
HortNZ wrote a submission on the Biosecurity (Information for Incoming Passengers) Bill. The bill clarifies the biosecurity requirements that all incoming passengers must adhere to upon arrival in New Zealand.
PDF, 269 KB.
Proposed changes to HSNO fees
April 2023
HortNZ wrote a submission on the government proposals to increase the fees for various Hazardous Substances & New Organism (HSNO) applications.
PDF, 271 KB.
Severe Weather Emergency Recovery Legislation Bill
March 2023
HortNZ called for emergency measures in the cyclone response to support recovery for growers.
PDF, 1.1 MB.
Resource Management (Freshwater Farm Plans) Regulations 2023
February 2023
HortNZ summarised our concerns with the Freshwater Farm Plan Regulations, including the lack of public consultation.
PDF, 336 KB.
Import Health Standard for fresh lychee from Taiwan
February 2023
HortNZ wrote a submission on the government proposed changes to the importation requirements of fresh lychee from Taiwan.
PDF, 365 KB.
Water Services Legislation Bill
February 2023
The Water Services Legislation Bill clarifies the functions of water services entities and defines small rural mixed-use water schemes as part of the Three Waters reforms.
PDF, 433 KB.
Future for Local Government Report
February 2023
HortNZ submitted on a report imagining the new role for local government as their powers change under RMA reform.
PDF, 382 KB.
Changes to the Biosecurity System Entry Levy and other services charged to importers for clearing cargo
February 2023
HortNZ wrote a submission on the government proposed changes to the Biosecurity System Entry Levy and other services charged to importers for clearing cargo.
PDF, 261 KB.
Market Governance of Emissions Trading Scheme
February 2023
HortNZ submitted on the market governance of the Emissions Trading Scheme (ETS) to support efficiency, integrity and confidence in the market.
PDF, 321 KB.
Natural and Built Environment Bill and Spatial Planning Bill
February 2023
The Natural and Built Environment and Spatial Planning Bills are the first two of three pieces of legislation replacing the RMA.
PDF, 633 KB.
Amendments to Alstroemeria Nursery Stock Schedule
January 2023
HortNZ wrote a submission on the government proposed changes to the import requirements of Alstroemeria tissue culture.
PDF, 398 KB.
Actara® Reassessment
January 2023
HortNZ wrote a submission on the government proposed changes to the controls for the insecticide Actara.
PDF, 350 KB.
New Zealand Grocery Industry Competition Bill
December 2022
The two main tools highlighted in HortNZs original submission have been addressed. These tools will protect growers and support them in their negotiations with grocery retailers.
PDF, 427 KB.
Worker Protection (Migrant and Other Employees) Bill
December 2022
HortNZ supported the intention of the bill to improve compliance and deter exploitation of migrant workers. We asked for reasonable grounds for inspection, regulatory recognition of assurance schemes like GAP, and right of appeal.
PDF, 354 KB.
Import Health Standards for Fresh Lychee from Thailand
December 2022
HortNZ wrote a submission on the government proposed changes to the import requirements for fresh lychee from Thailand.
PDF, 250 KB.
Additional import requirements on table grapes from Chile, Republic of Korea, and the USA
December 2022
HortNZ wrote a submission on the government proposed changes to the import requirements for table grapes from Chile, Republic of Korea, and the United States of America.
PDF, 327 KB.
Increased Penalty for Breach of Biosecurity Bill
November 2022
HortNZ supports efforts to increase passenger compliance with New Zealand’s strict biosecurity requirements.
PDF, 382 KB.
Defining Food Waste in New Zealand: Background briefing
November 2022
HortNZ made a submission to the Ministry for the Environment to seek feedback on the proposed technical definition of food waste.
PDF, 348 KB.
Proposed additional import requirements for small seed lots
September 2022
HortNZ wrote a submission on the government proposed changes to the import requirements for small seed lots.
PDF, 349 KB.
Minimum Wage Review
September 2022
HortNZ surveyed growers to ask about the impact of minimum wage increases on their businesses. We submitted a discussion of the results to MBIE.
PDF, 464 KB.
MPI standard for places of first arrival
September 2022
HortNZ wrote a submission on the government proposed changes to the standard for Places of First Arrival (PoFA).
PDF, 347 KB.
Horizon Scan to Support the Strategic Direction of the Binational Food Regulatory System for 2023-2026
August 2022
HortNZ advocated for a strong food system with minimal regulatory burden.
PDF, 178 KB.
New Zealand Grocery Code of Conduct
August 2022
HortNZ made a submission to MBIE on the Grocery Code of Conduct. HortNZ supports the development of a clearly defined Code of Conduct for the retail grocery sector appropriate for New Zealand and use of supply agreements to manage relationships between retailers and growers.
PDF, 380 KB.
Import Health Standard for Seeds for Sowing
August 2022
HortNZ wrote a submission on the government proposed changes to the import requirements for the seeds for sowing import health standard.
PDF, 445 KB.
Import Health Standard for importing avocado plants
August 2022
HortNZ wrote a submission on the government proposed changes to the avocado import health standard.
PDF, 416 KB.
Import Health Standard for Seeds for Sowing
July 2022
Access to imported seed is critical to grow vegetables for domestic consumption and export and to sustain and grow the New Zealand vegetable seed industry.
PDF, 321 KB.
National Policy Statement Indigenous Biodiversity
July 2022
HortNZ made a submission to the Ministry for the Environment on the exposure draft of the NPS Indigenous Biodiversity. While HortNZ supports protection of biodiversity, this can be managed through existing good management practice frameworks.
PDF, 1.6 MB.
Managed Retreat consultation
June 2022
HortNZ submitted on consultation relation to legislation to provide for managed retreat. Hort NZ supports a national framework for managed retreat, with clearly defined roles and responsibilities.
PDF, 313 KB.
Emissions Reduction Plan
June 2022
HortNZ made a submission to the Select Committee on the first Emissions Reduction Plan published May 2022.
PDF, 375 KB.
Import Health Standard for SEACO
June 2022
HortNZ wrote a submission on the government proposed changes to the import health standard for sea containers from all countries.
PDF, 354 KB.
Freight and Supply Chain Strategy
June 2022
HortNZ submitted on a proposed strategy that looks to future proof the freight and supply chain networks over the next 30 years.
PDF, 279 KB.
Modern slavery and worker exploitation
June 2022
HortNZ supports the intention of the proposed Modern Slavery and Worker Exploitation legislation and provides the following comments to assist in the development of the legislation.
PDF, 357 KB.
Climate Change Adaptation Plan
June 2022
HortNZ submitted on the proposed plan on how adapting to climate change will be managed in New Zealand.
PDF, 361 KB.
Fair Pay Agreement Bill 2022
May 2022
HortNZ submitted on proposed legislation that would provide a framework for collective bargaining for fair pay agreements across entire industries or occupations, rather than just between unions and particular employers.
PDF, 410 KB.
Restricted Entry Intervals (REIs)
May 2022
HortNZ wrote a submission on the review of plant variety rights fees.
PDF, 447 KB.
Plant variety rights fees
May 2022
HortNZ wrote a submission on the review of plant variety rights fees.
PDF, 414 KB.
Improving the protection of drinking water-sources
March 2022
HortNZ submitted on proposed amendments to the National Environmental Standards for Sources of Human Drinking Water (NES DW) which proposes default source water risk management areas and strengthened regulation.
PDF, 5.3 MB.
A New Zealand Income Insurance Scheme - Discussion Document
April 2022
HortNZ submitted on a discussion document proposing a New Zealand Income Insurance Scheme, which would apply if New Zealanders are made redundant, laid off, or have to stop working because of a health condition or disability.
PDF, 686 KB.
Proposed Amendments to the Post Entry Quarantine (PEQ) Facility Standard
February 2022
HortNZ wrote a submission on the government proposed changes to the post entry quarantine (PEQ) facility standard.
PDF, 232 KB.
Primary production and processing requirements for high-risk horticulture
February 2022
HortNZ wrote a submission on FSANZ’s proposal to amend the primary production and processing requirements for horticulture (berries, leafy vegetables, and melons).
PDF, 178 KB.
Freshwater Farm Plan Regulations Discussion Document
October 2021
HortNZ commented on pathways for industry assurance programmes to facilitate freshwater farm plans.
PDF, 885 KB.