FAQs related to Requirements for the Audit of Sea Containers

MAF will include additional controls in the harvest process to minimise the probability of the formation of a self-sustaining population of GM Zea mays. Protocols covering these controls will be written and distributed to growers.

MAF will also perform follow-up visits to sites.

If it is determined that it is contaminated this seed will be destroyed or re-exported.

There is no cross-pollination risk because the crops have only just germinated.

The documentation that accompanied these consignments only indicated the presence of promoter or terminator sequences, not a specific construct. MAF’s investigations will seek to identify the nature of any GM constructs.

It is unlikely, but possible, that consignments of lucerne seed could contain very low levels of GM seed. In the USA, the proximity of GM crops to non-GM crops is not regulated.  For example, lucerne is pollinated by bees.  Bees could carry pollen from GM fields to non GM fields.  Also mixing of small amounts of GM seed could occur via harvesting equipment, seed cleaning plants, and seed storage facilities.

The seed sample will be tested using a DNA (deoxyribonucleic acid) test called the polymerase chain reaction (PCR), which detects specific DNA sequences unique to the genetic modification.  The GM lucerne varieties contain the herbicide tolerant gene (CP4 EPSPS) and a promoter gene (FMV) from the Figwort Mosaic Virus, which conventional varieties do not have.  A positive result for either of these genes indicates the presence of GM in the seed sample.

The three MAF-approved testing laboratories supply a test that will detect Round-up Ready GM lucerne, by specifically targeting a part of its gene construct which is virtually identical with the construct in other glyphosate-tolerant crops. If any GM lucerne is detected during testing, MAF will deny the consignment of seed entry into New Zealand.  The laboratories will monitor the test’s effectiveness as part of normal validation procedures.

To date, only the US has approved the commercial production of GM lucerne. However, seeds are traded world-wide.  Seed from this year’s harvest in the US may be sold to other countries and the ensuing seed crop may enter New Zealand next year. Furthermore, New Zealand growers decide which countries they source seed from according to the end use for their products.  The lucerne and alfalfa breeding industry in the US is large, and provides growers with access to specialised varieties.

Implementation of a testing protocol can provide assurances that imports do not contain GM seeds, while still allowing trade to continue. Banning all imports of lucerne and alfalfa seed would not be justified, given that a GM test is available. 

In the US, genetically modified lucerne could cross-pollinate with non-GM lucerne, and the modified traits may be inherited by the next generation.  Lucerne is a perennial species and feral plants grow along field edges and roadsides in the main seed production areas in the US. Consequently, wild plants containing GM genes may persist in these environments.

Little is known about the potential for persistence of these GMOs in the New Zealand environment. However, GM lucerne is not approved by the Environmental Risk Management Authority (ERMA New Zealand) for release into the New Zealand environment.

The GM lucerne varieties have been modified to be tolerant to glyphosate herbicides (the principle ingredient of Roundup^TM  and several other herbicides) , to assist with weed management for the production of hay and forage in the field. The varieties contain the glyphosate tolerant gene (CP4 EPSPS) and a promoter from the Figwort Mosaic Virus (FMV).

Testing typically takes two to seven days, depending on laboratory workloads. Most importers arrange for testing to be conducted offshore prior to shipment of seeds, so delays at the border are not anticipated.

The importer is required to meet the costs of testing. The testing costs between $340 and $560, depending on which of the three MAF approved laboratories conduct the testing (USA, France or Australia).

The MAF-approved test, which requires a sample size of 3200 seeds, will detect GM if it is present in the sample 99.9% of the time. A sample size of 3200 seeds (required by all of the MAF testing protocols) provides a 95% confidence that GM seed will be sampled from a seed lot if it is present in concentrations of 0.1% or more (greater than or equal to 1 in 1000 seeds).

GM lucerne/alfalfa was approved by the USDA (US Department of Agriculture) in July 2005 for wide-scale cultivation. In the same year it was assessed and approved for human food in Canada and Mexico in 2005, and in 2006, Japan.

Although GM lucerne/alfalfa is intended primarily as an animal feed, its safety for human consumption has also been assessed in case some inadvertently enters the human food supply.

Food produced from Roundup-ready corn, soybean, canola and sugar beet, which all contain the same modified gene as GM lucerne, have already been approved as safe for consumption by Food Standards Australia New Zealand (FSANZ). FSANZ are currently conducting an initial assessment of GM lucerne as food, and if it is approved for human consumption, all products containing GM must be labelled as genetically modified in accordance with the Australia New Zealand Food Safety Code, Food Standard 1.5.2. This provides consumers with choice as to whether or not they purchase foods containing GM ingredients.

For any questions about food safety, please contact the New Zealand Food Safety Authority :

New Zealand Food Safety Authority
68-86 Jervois Quay
PO Box 2835
Wellington

If this testing protocol were not established, the likelihood of inadvertent import and planting of GM lucerne/alfalfa into New Zealand may increase. Little is known about the potential for persistence of these GMOs in the New Zealand environment, therefore existing lucerne hay and alfalfa/lucerne seed markets may be affected.  Additionally, growers of these seeds may find themselves in breach of the HSNO Act, as GM lucerne/alfalfa has not been approved for planting in New Zealand.

The key cost is that of the test itself.  Testing costs between $340 and $560 NZD depending on which laboratory conducts the test. Importers are likely to pass any increased costs from testing on to their consumers, so lucerne hay and alfalfa sprouts may cost slightly more as a result.

MAF and ERMA New Zealand have the ability to prosecute under the both the HSNO and Biosecurity Acts.  This is considered on a case-by-case basis.

Working closely with ERMA New Zealand, MAF would work to ensure that the GM lucerne, and commodities likely to harbour it, were isolated and devitalised so that no seeds could germinate.

ERMA New Zealand supports the Environmental Risk Management Authority in its decision making role for applications to import, develop, or field test new organisms; or to import or manufacture hazardous substances. These applications are made under Part V of the Hazardous Substances and New Organisms Act 1996.

Most imported seed is grown into pasture or lucerne hay for feeding livestock. A smaller proportion is sprouted as alfalfa sprouts for human consumption.

In 2005, New Zealand imported approximately 37,000 kg of lucerne seed for sowing and approximately 9, 000 kg seed for sprouting.

Production of lucerne for livestock and alfalfa sprouts in New Zealand relies on seed imported from large breeding programmes in the US, Australia and Europe. New Zealand’s own lucerne and alfalfa seed production industry is small, and is localised in areas of Canterbury and Otago where climatic and soil conditions are favourable. Overseas specialised breeding programmes offer growers a wider range of seed selections not otherwise available to the New Zealand industry.

Medicago sativa is the Latin name for lucerne, also called alfalfa. The seeds may be grown as a forage crop or lucerne hay for feeding livestock, or sprouted to produce alfalfa sprouts for human consumption.

The protocol will require importers to have consignments of viable lucerne/alfalfa seed tested for the presence of GM seed at one of the three MAF approved testing laboratories located in Australia, France or the US.

Importers of viable lucerne seed for producing animal feed and alfalfa seed for human consumption will be affected.

MAF would like to hear feedback from people who have an interest in, or would be affected by, the seed testing protocol. The protocol would be put in place by amending the existing Import Health Standards for Medicago sativa ( Seed for Sowing and Importation of Grains/Seeds for Consumption, Feed or Processing – Plant Health Requirements).

The purpose of a seed testing protocol is to minimise the likelihood that GM seed will inadvertently be imported into New Zealand within consignments of conventional seed. MAF already has seed testing protocols in place for maize and sweet corn, oilseed Brassica, and soybeans, which were implemented in 2001 and 2002. MAF intends to extend these requirements to lucerne/alfalfa because two varieties of genetically modified (GM) lucerne are entering commercial production in the US for the first time this year.

MAF is responsible for enforcing the ‘new organism’ provisions of the Hazardous Substances and New Organisms Act 1996 (the HSNO Act). GM lucerne is considered a ‘new organism’ under the HSNO Act and cannot legally be imported or grown in New Zealand. The HSNO Act prohibits the importation, field-testing or release of any ‘new organism’ without approval from the Environmental Risk Management Authority (ERMA). To date, no GM organisms have been approved for release in New Zealand.

If you wish to take any animal or plant matter out of New Zealand, please contact the Consulate of the country of destination for up to date information on import requirements.

If the goods require a PC (Phytosanitary Certificate) Plants Phytosanitary Certification, you must bring the produce to the MAF Aircargo Clearance Centre.
Phone + 64 9 256 8691 or + 64 9 256 0145 for Plant/Produce enquires, or + 64 4 473 8996 for Animal/Animal Product enquires. These goods will be inspected and, if in acceptable condition, you will receive an IPC signed by an authorised Quarantine Officer to show to the Agriculture Department upon arrival in the country of destination.

New Zealand is party to the Convention on International Trade in Endangered Species (CITES) . Some animals listed in Schedule 1 of this convention can still be exported, but this requires a certificate from the Department of Conservation.

Export Certifications are the public access versions of the export certificates and outline overseas country requirements for the animal and animal germplasm (semen and embryos).

Growers should discuss costs with the IVAs, as charges will depend on the circumstances of the production sites to be registered.

This provides additional assurance to MAF that the information is correct. MAF is willing to look at alternative arrangements for implementation of the exemption. We will discuss this with MAF over the next few months, but at the moment the requirement remains.