HSNO: Request to Delay the HSNO Act

Below is important, relevant information as to why I am writing to urge all New Zealanders to support a delay the HSNO Amendment Bill and subject it to proper scrutiny, full public consultation, and independent economic, trade, and environmental impact assessments before proceeding.

The amendments appear to be driven primarily by organisations that stand to profit from faster approvals of genetically engineered products, or by groups like Federated Farmers citing a “fear of missing out.” This is not a sound basis for weakening long-standing safeguards that have protected New Zealand’s environment, export reputation, and premium non-GMO positioning.

The main product likely to be fast-tracked as a direct result of these changes is AgResearch’s High Metabolisable Energy (HME) ryegrass a 20-year, ~$100 million taxpayer and levy-funded project.

The rush to amend HSNO seems heavily influenced by the desire to commercialise this technology.

1.Genetically Engineered HME Ryegrass

• HME Ryegrass (Summary attached of Methane Science Accords research utilising AgResearch’s own documentation that shows HME ryegrass has failed to deliver on its modelled benefits)

• HME ryegrass has failed to deliver on its modelled benefits and performs worse than standard perennial ryegrass in critical areas:

Rumen and Animal Performance: HME redirects carbon from sugars (WSC reduced 15–69%) to lipids (increased to 5–7.38% DM). This starves rumen microbes and creates an “oil slick” effect on fibre. The key 2020 in vitro study showed significantly lower butyrate (5–7 percentage points), exceeded milk fat depression thresholds (RUFAL), incomplete biohydrogenation, and trends of reduced feed intake. Methane reductions (7–11%) result from impaired digestion, not improved efficiency.

Pasture Performance: Spaced-pot gains in photosynthesis and biomass do not translate to dense swards or actual field trials. US trials showed no significant increase in gross energy yield per hectare. Thinner leaves, higher water loss, reduced drought resilience, and weakened endophyte protection (30–40% lower alkaloids) make it less robust than conventional ryegrass.

Environmental Impacts: Mesocosm trials claiming N₂O reductions showed major trade-offs — drier soil (27% less moisture), 34.5% drop in microbial biomass, 53% reduction in ammonia-oxidising archaea, and stalled nitrogen cycling with ammonium accumulation. Benefits are highly conditional and fail in representative NZ loam soils. Leaching risk in high-rainfall pastures is a serious concern.

After two decades: The project relies on optimistic modelling that real-world data has not validated.

The concerns raised about HME ryegrass are not theoretical — they are drawn directly from AgResearch’s own published trial data and official reports. The 2020 in vitro rumen study, 2023 soil mesocosm trials, and US field experiments provide concrete measurements showing reduced WSC, excessive lipids, impaired fermentation, and soil microbial impacts. This evidence-based critique, supported by peer-reviewed papers and OIA documents, demonstrates that HME has failed to deliver the promised productivity and environmental gains under realistic conditions, despite two decades of investment.

2. GMO Trade Barriers

New Zealand’s greatest strength is our clean, grass-fed, non-GMO pastoral systems that command premium prices internationally. Adopting GM technologies like HME ryegrass risks triggering trade barriers and market discounts. A 2003 NZ Treasury report modelled that widespread GM adoption could lead to a 43% drop in producer returns for meat and dairy due to consumer and market resistance. Even today, many key buyers prefer non-GMO products. Weakening HSNO could damage our hard-earned reputation and premium positioning for little or no productivity gain.

3. RNAi Gene Silencing Risks

The Bill opens the door to emerging technologies such as RNA interference (RNAi) — a method that uses double-stranded RNA to “silence” or switch off specific genes in pests, plants, or animals. In plain language, it’s like sending molecular instructions that tell cells to stop making certain proteins. While promoted as precise, RNAi can have off-target effects, spread unintentionally through the environment, persist longer than expected, and affect non-target insects, soil organisms, or even livestock. These risks are poorly understood in New Zealand’s unique ecosystems and require far stronger safeguards than the current Bill provides.

4. Labelling and “Invisible” GM Products

Alarmingly, some GE/GMO products enabled by these amendments will not require labelling and will be treated as normal. A clear example is Vadescana, a Varroa mite control product that introduces double-stranded RNA into cells. It does not work effectively on heavy infestations, yet under the proposed changes it is not classified as genetic modification. Farmers and consumers will have no way of knowing they are using or consuming products derived from these technologies, undermining transparency and choice. Given farmers are required to be accountable for their products, this legislation currently does not hold manufacturers to the same standards of responsibility or liability.

5. Export Markets

New Zealand’s competitive advantage lies in our clean, grass-fed, non-GMO pastoral systems — delivering premium phytonutrients, omega-3s, and CLA that cannot be easily replicated by industrial GM approaches. Weakening HSNO puts this at risk for marginal or negative gains.

Allowing GMOs or gene-edited products could threaten New Zealand’s agricultural export premiums. Because key markets (e.g., the EU) demand non-GMO verification, introducing GMOs risks losing organic/non-GMO certifications, increasing compliance costs, and undermining NZ’s "clean and green" brand reputation.

Specific potential impacts for each sector include:

• Honey: High risk. New Zealand honey commands massive premiums globally based on its pristine, natural image. The presence of GMO crops could contaminate pollen sources, stripping organic status and destroying export value in health-conscious markets.

• Meat (Venison and Beef): Moderate-to-high risk. Many high-paying European markets require livestock to be fed non-GMO diets. If GMO feed is introduced or cross-contamination occurs, processors may have to separate supply chains or lose access to premium markets.

• Kiwifruit: Moderate risk. While Zespri utilizes conventional breeding, the introduction of GMOs could impact consumer perception in strict markets like Japan, where GM foods face heavy consumer resistance.

• Milk: High risk. Major exporters like Fonterra have raised concerns that gene-editing and GMO regulations must align perfectly with strict overseas compliance standards to avoid having dairy shipments rejected.

The Bill shifts risk and liability onto farmers while reducing transparency, traceability, public oversight, and New Zealand-specific assessments. A comprehensive risk analysis, trade impact assessment, and cost-benefit analysis are essential. The risks are currently unacceptable.

I strongly recommend:

• Immediate delay of the HSNO Amendment Bill.

• Full independent review including trade/market impact assessments and long-term NZ field trials.

• Release of all HME trial data for proper scrutiny.

• Rejection of rushed amendments driven by vested interests or FOMO.

I can provide a fuller HME scientific summary, and the 2020 in vitro study details, or Scientific AI analysis of the above HME Summary would verify its accuracy.

To the farmers amongst the team: Would you be prepared to plant HME Ryegrass on your own farm?

New Zealand farmers and exporters deserve better than rushed legislation that could undermine our greatest strengths. I urge you to pause and protect our premium pasture-based advantage.

Thank you for your time.

Yours sincerely