Call to Action!! 

Submission - A1139 - GE potatoes.

Food Standards Australia New Zealand

Template below and suggested points to make.  Please cut and paste into a new document.
Please personalise your submissions with your own words and add other points (further below).
Submissions (instructions here) can be  sent to
You can also lodge your submission online. 
Submissions close 7 July at 8pm (NZ time)

Submission To FSANZ       Application A 1139

Name of submitter

Contact details

(address, email phone)

I ask that FSANZ decline the approval of application A1139 - Food derived from Potato Lines E56, F10, J3, W8, X17 & Y9.

  • I strongly object to FSANZ approving application A1139 - Food derived from Potato Lines E56, F10, J3, W8, X17 & Y9. I ask that FSANZ decline the application
  • There is no comprehensive data showing evidence of unintended effects of the transgenic potato lines. It makes it mandatory for FSANZ to decline the approval.
  •  It is necessary for FSANZ to require whole genome sequencing to identify off-target mutations and also essential to ascertain the effects of unintended changes on global patterns of gene function.
  • FSANZ must require sequencing using molecular profiling analyses or “omics”-

◦      transcriptomics — gene expression profiling,
◦      proteomics — protein composition profiling,
◦      metabolomics — profiling of metabolites,
◦      miR-omics – microRNA profiling

  • The best evidence available for effective safety assessment also requires long-term toxicity studies in established animal model systems. In the absence of these data to inform FSANZ, there can be no legal approval of A1139
  • The APHIS documentation shows that these GE potato lines offer no nutritional advantage, as there are non-GE potato varieties that are naturally low in the desired profiles.  This demonstrates that there is no need for approval of the GE potatoes.
  • Instead of approving this application, FSANZ could instead recommend non-GE potato varieties that have naturally-occurring low levels of compounds responsible for acrylamide production. They could also educate food businesses on storing and cooking procedures that minimize acrylamide production..
  • The FSANZ assessment is compromised with respect to rigorous scientifc procedure.  These GE potato lines cannot be approved for the human or animal consumption, without the provision of comprehensive information regarding compositional differences to their non-GE counterparts.  Compostional analyses are very limited in that they can only assay for known compounds. Any novel compounds would not be detected in such analyses. 
  • FSANZ must provide evidence of safety, when eaten, in the lines that have significant variations in nutrients, or more importantly anti-nutrients. Anti nutrients such as glycoalkyloids can be highly toxic for consumers. 
  • The afore-mentioned studies have not been carried out and in their absence, there should be no legal approval of the A1139 application. 



Other risks from an approval by FSANZ that must be recognised as unacceptable to the public.

  • There is no consumer benefit or nutritional benefit from the GE potatoes listed in this application to outweigh known and unknown risks, compared to existing potato varieties that industry can use.
  • Whole or even very small parts of any uncooked (raw) tubers endanger New Zealand’s biosecurity. GE potatoes could either potentially be planted without regulation or establish themselves as wild populations.
  • Approval will constitute a total disregard for the health of consumers,  by denying them their right to know what they are eating. There is no requirement for GE foods sold by fast food and other restaurants to be labelled as such, so as to inform consumers.This would leave the public in the dark and result in unwilling and unwitting consumption of GE potatoes.
  • The GE potato lines’ compositions are significantly different to their parent line. This shows that the GE process has disrupted the cellular metabolism. As there are no feeding studies to evaluate these effects, it is not possible  to conclude that there are no biologically relevant differences. 


The NES -PF has been in front of Minister for Primary Industry since 27 July 2016.  Update information says it is going to be considered in August 2017 - the GE clause still stands.
National Environment Standard on Plantation Forestry (NES-PF). GE Free NZ Stop GE Trees principles align to the Global Justice Ecology Project.  We need to protect native forests, and to defend the rights of forest dependent communities and Indigenous Peoples against the uncontrollable and irreversible threats posed by the release of genetically engineered (GE) trees.


Protect the right of Regions to choose to say NO to GE-Trees 

Date ...

Dear .....,  

I am writing to you regarding the Resource Legislation Amendment Bill (RLA).

I would like to ask you to call for the deletion of the clauses 360D, 43A (3A) and 43(3B).

The clauses, if enacted, remove the democratic process around community protections for the environment through the RMA and would allow GE plants and animals to be a permitted activity if approved by the EPA.   Any Council with precautionary GE provisions placed in their plans would have to remove them.  

The damages from genetically modified organisms on New Zealand's ecosystems, including essential soil organisms, plants, birds and insects, could be both widespread, permanent and economically damaging.  These effects could be detrimental to biodiversity and trophic systems, undermining what the RMA is designed to protect. 

Further, Clauses 43A (3A) and 43(3B) are replicas of the 6.4 clause in the stalled National Environment Standard on plantation forestry (NES-PF).  The Ministry of Primary Industries (MPI) recieved 16,000 submissions calling for the removal of clause 6.4 and supporting councils in their right to regulate land use provisions on GMOs. 

I urge you to ensure that these clauses are removed from the RLA.

 The decision we would like the Minister to make 

1.   Remove clause 360D

2.   Remove clauses 43A (3A) and 43(3B)






!! The  Resource Legislation Amendment Bill (RLA)!!

This action was highly successful and the new wording the Maori Pary carved out in the RMA allows Councils to place precautionary policies on GMO's without the interference of Ministers. (April 17)

E-mail Action 19 -25 March 2017 URGENT
Protect the right of Regions to say NO to GE"
In the week of 19  March 2017 please send an e-mail to Marama Fox and all Parties asking them to ensure that clauses, 360D, 43A (3A) & 43(3B) are removed from the RLA.  This week the Bill will be debated clause by clause.  Below is a template letter for you to use and add any of your own wording. Click here to find the email address of all MPs.  

Resource Legislation Amendment Bill (RMA 2015) - closed 14 March 2016

GE Free NZ submission. 
Local Body and Environment Select committee hearing 

Communities want and should have a say in how their livliehoods will be affected, at the moment they can do this through the Resource Management Act. However, clauses have been added in the proposed RMA, by Minister for the Environment and supported by Federated Farmers, preventing councils and communities from placing precautionary controls on the management of GMO's in their region. Please write, meet with your Labour Party, Green Party, Maori Party, NZ First and United Future MP's to insist on removal of section 360D. Write to the select committee expressing your views. Below is a template you might like to follow. (You can also include other concerns you have with the planned RMA changes). 

Support Wellington Region Precaution on GMO's- This is under consideration.

In relation to your main projects signaled in the proposed Long Term plan around regional flood protection, soil plans and taking a strong leadership in water quality and discharges to land to protect the economic livilehoods and health of communities. We would like to submit on two points- Genetically engineered/ modified organisms (GMO’s)  and all pesticides especially Glyphosate based Herbicides (GBH) and their designations in the Greater Wellington Region council plan.

1.   We believe that the future outdoor use of GMOs should be considered an issue of regional significance and ask if the RWRC can further consultation around this issue through a section 32.

2.   To place a precautionary approach clause looking to implement rules, policies and objectives to the use of GMO’s in the Greater Wellington Region

3.   To prohibit the use Glyphosate based Herbicides (GBH) where their toxic consequences will affect ecosystems,  the environment and animal and human food sources.

Update on Whangarei and Far North District Councils submission rounds, 2014.

This is now in front of the High Court for more information please go to GE Free Northlands page

Information for what to put in your plan to implement a precautionary policy around GMO's

Do you live in Northland or Auckland?  (or do you have an interest greater than the general public?)

Do you want to protect the North's existing valuable GE-Free status? (GE=Genetic Engineering).

Do you support your local councils ensuring that those who may wish to undertake risky GE experiments in our region should be financially liable for any harm caused by their activities?

Do you want a complete ban on the release of all GMOs (Genetically Modified Organisms)?