1. Comments on the Bill
In this section, you can make comments on the Gene Technology Reform bill. Here are some potential comments you could use:
Section 1: Lack of Precautionary Measures
No Precautionary Principle
- The Bill abandons the precautionary principle, replacing it with a risk-proportionate framework. This fails to prioritise the prevention of harm to nature, public health, and the rural economy, risking long-term environmental and economic damage.
No Liability for Gene Technology Users
- Clause 187 provides immunity from civil and criminal liability for users of gene technology, enabling irresponsibility without accountability for mistakes or risks.
No Standards for Safety or Ethics
- The Bill fails to mandate safety standards or ethical guidelines to prevent harm to humans, animals, or ecosystems. There is no consideration of animal welfare or long-term ecological impacts.
No Labelling Requirements
- Products resulting from gene editing that are exempt from regulation will not require labelling, denying consumers and farmers the ability to make informed choices and violating the principle of consent.
Section 2: Risks to Farming and Exports
Threat to Non-GMO Farming
- The Bill prevents regional or district councils from enacting precautionary measures or declaring GMO-free zones, undermining the protection of non-GMO farming and local food systems.
Loss of Clean-Green Reputation
- Deregulation and the introduction of unlabelled gene-edited products risk damaging New Zealand’s global reputation as a clean, green, and sustainable producer, negatively impacting export markets.
Economic Impact on Farmers
- GE farming relies heavily on patents, increasing costs for farmers and reducing profitability. This corporate-driven approach undermines the traditional, diverse agricultural practices of New Zealand.
Unrecoverable Contamination
- Once gene-edited organisms are released, their genetic material can spread through natural processes like pollination, making contamination irreversible and unmanageable.
Section 3: Bodily Autonomy and Public Consent
Mandatory Authorisations Based on Overseas Approvals
- The Bill allows “mandatory medical activity authorisations” for gene technology-based medicines or therapies that have been approved by two overseas regulators. This bypasses New Zealand’s own regulatory scrutiny and poses significant risks:
- Loss of Local Oversight: These authorisations remove the opportunity for New Zealand to independently assess the safety, efficacy, and appropriateness of these technologies for its unique population.
- Safety Concerns: Different populations and environments may respond differently to medical interventions. Without local trials and reviews, risks specific to New Zealanders may go undetected.
- Transparency Issues: The lack of public consultation or oversight for these fast-tracked authorisations undermines public trust and prevents meaningful scrutiny of the safety and effectiveness of such technologies.
- Ethical Violations: Without labelling or traceability, individuals may unknowingly be subjected to treatments they might otherwise choose to avoid, violating principles of informed consent.
- Sovereignty Erosion: By relying on foreign decisions, the Bill cedes control over New Zealand’s health and safety standards to international authorities whose priorities may differ from New Zealand’s values and needs.
- Lessons from the COVID-19 mRNA Vaccine Rollout: The COVID-19 mRNA gene therapy vaccines, fast-tracked under emergency authorisations and heavily influenced by overseas regulators, have caused significant harm in New Zealand. Thousands of Kiwis have reported injuries, and there have been deaths linked to these vaccines. This tragic experience underscores the critical need for rigorous local oversight and safety assessments before approving gene technology-based medical interventions. It is irresponsible and dangerous to allow foreign regulators to dictate the introduction of similar technologies in New Zealand without robust scrutiny.
- This provision represents a step towards deregulation that undermines public safety, autonomy, and trust, particularly in light of recent experiences with rushed medical authorisations.
Removal of Labelling and Traceability
- Without labelling, New Zealanders are subjected to a de facto experiment with gene-edited food and medicines. This violates the right to informed consent and prevents individuals from monitoring and managing their exposure to these technologies.
Section 4: Weak Oversight, Overreach, and Sovereignty Concerns
Centralisation of Authority
- The establishment of a central Gene Technology Regulator concentrates decision-making power in a single entity, removing the ability of regional councils and communities to implement precautionary measures or protect their local environments. This undermines local decision-making and the ability to address region-specific risks.
Lack of Independent Oversight
- The regulator operates without clear checks and balances, creating a significant risk of arbitrary or politically influenced decisions. Without robust oversight mechanisms, the regulator could prioritise industry or political interests over public health and safety.
International Influence
- The Bill permits significant deference to international regulatory decisions, particularly through provisions allowing for joint risk assessments with overseas regulators. This approach risks overlooking New Zealand’s unique ecological, cultural, and economic contexts and diminishes the nation’s ability to set its own standards.
International Trade Agreements Undermining Sovereignty
- It has come to light that the Gene Technology Bill may be tied to a trade agreement with the United States. If true, this represents a profound compromise of New Zealand’s national sovereignty.
- Decisions affecting New Zealand’s health, safety, and environment should be made independently and transparently, based on the specific needs and values of New Zealanders—not dictated by the terms of international trade agreements or foreign commercial interests.
- The Bill’s emphasis on aligning with international regulatory frameworks and facilitating trade risks prioritising economic objectives over the welfare of New Zealand’s people, ecosystems, and agricultural economy.
- Such trade-driven policymaking jeopardises the nation’s ability to maintain its clean-green reputation, protect biodiversity, and ensure public trust in regulatory processes.
Overreach Through Regulatory Capture
- By removing many safety and precautionary requirements, the Bill enables the Gene Technology Regulator to act as a facilitator of gene technology rather than a neutral overseer. This raises concerns about potential regulatory capture, where the regulator could prioritise biotech industry interests over public health, environmental safety, and ethical considerations.
Section 5: Scientific and Safety Concerns
Lack of Scientific Certainty
- Gene editing techniques like CRISPR are known to cause unintended genomic disruptions, as noted in recent studies. These long-term risks are ignored in the Bill's regulatory framework.
Bio-Contamination Risks
- Biotech processes are inherently variable and prone to contamination. The removal of traceability provisions increases the likelihood of undetected and unmanaged risks.
Lab Accidents and Oversight
- Global evidence shows that laboratory accidents are common. Deregulating biotechnology in this context heightens the potential for significant and uncontrollable risks.
NZ as a Testing Ground for Unproven Technologies
- The Bill could turn New Zealand into a testing ground for high-risk, unproven genetic technologies. With deregulated oversight, global biotech companies may use New Zealand as a site for experimental trials, taking advantage of looser regulations. This could expose New Zealand’s environment, agriculture, and public health to potentially harmful technologies without proper long-term studies or risk assessments, making it a “dumping ground” for risky genetic experiments.
Section 6: Economic Concerns
New Zealand’s GE-Free Advantage
- New Zealand is one of the last places on earth with a GE-free status—a unique brand value that sets us apart in the global market. This natural, clean-green image is a cornerstone of our economy and a key reason why international consumers choose our products. Tasmania has recognised the value of this position, extending its GE-free moratorium until 2029 to protect its reputation and agricultural economy. New Zealand risks losing a competitive edge if it abandons its GE-free status.
Impact on Exports
- The New Zealand Institute of Economic Research (NZIER) report, commissioned by Organic Aotearoa New Zealand (OANZ), projects a devastating $10-20 billion drop in export demand across the entire agricultural export sector if we lose our GE-free status. This Bill risks undermining our premium positioning and damaging key international markets that value non-GE, organic, and sustainably produced goods.
Job Loss and Rural Impact
- The agricultural sector employs 360,000 Kiwis whose livelihoods depend on New Zealand’s reputation for quality and sustainability. This Bill threatens their jobs, rural communities, and way of life by shifting the costs and liability for GE contamination onto the GE-free sector. Food producers who have built their businesses on New Zealand’s GE-free status could face financial ruin, while rural economies will bear the brunt of this billion-dollar downturn.
