Submission on the Proposed Amendments to the New Zealand Food Notice: Maximum Residue Levels for Agricultural Compounds

Rock The Vote NZ -

(Discussion Paper 2025/01, closing date 16 May 2025)

Recommendation: Do not implement the glyphosate MRL (Maximum Residue Levels) proposed increase to 10 mg/kg (grains) and 6 mg/kg (peas). Retain the current MRL or pursue a significantly lower MRL, and reinforce measures to ensure that glyphosate residues in our food remain minimal. This will best protect New Zealand’s public health, align with international best practices, and uphold the integrity of our food supply for present and future generations.

Summary

Rock The Vote NZ appreciates the opportunity to comment on the 17 March 2025 discussion paper proposing amendments to Schedule 1 of the Food Notice. Our comments are provided as a political party committed to creating a healthy nation and maintaining and enhancing the well-being of its people.

For this submission, we focus on the glyphosate component of the proposal. We at Rock The Vote NZ do not support raising the legal limit from 0.1 mg/kg to 10 mg/kg in wheat, barley and oats, or from 0.1 mg/kg to 6 mg/kg in dried field peas. We believe that a 60- to 100-fold increase over current limits poses unacceptable risks.

This proposal:

• Puts public health at greater risk

• Undermines food safety and trust in our regulatory system

• Threatens soil health, biodiversity, and long-term sustainability

• Disadvantages organic and regenerative farmers

• Damages New Zealand’s international reputation as a clean, green food producer

As a political party, we believe we should be working to reduce chemical residues in food, not raise limits to suit current usage among ourselves and international trade partners. The justification that these higher residues reflect “good agricultural practice” warrants critical scrutiny, and the associated dietary-risk assessment appears to downplay potential long-term health effects and risks.

Evidence of Existing Residue Issues

MPI has indicated that recent residue monitoring found glyphosate levels in some New Zealand wheat samples exceeded the default 0.1 mg/kg limit:

“Results from 2015/16 survey:

• We tested for glyphosate residues in pea and wheat crops in the 2015/16 survey. No glyphosate residues were detected in 60 pea samples. Glyphosate residues were detected in 26 out of 60 wheat samples. Twenty of these samples contained glyphosate above the MRL of 0.1 mg/kg.

• The results were assessed and indicated no food safety concern. At the highest level detected (5.9 mg/kg), the average adult would have to eat 14kg of wheat-based products every day for their entire life to reach the WHO "Acceptable Daily Intake" for glyphosate.”

That is 1/3 of the wheat samples which is a critical failure.  It looks as though we are increasing the limits in response to being unable to keep it down. We submit that this approach of raising the limit to suit current practice is fundamentally flawed. If prevailing agricultural practice results in such high glyphosate residues, this practice itself should be re-evaluated – not simply given a higher legal threshold.

Further to that we have the following recommendations:

• We believe in strengthening the oversight of glyphosate use rather than accommodating it’s excess.  Consider supporting farmers in adopting practices to keep residues low.  If GAP truly yields residues above 0.1 mg/kg then GAP itself needs to be re-evaluated for example adjusting timing, application rates or even just another process entirely.

• Maintain or even reduce the current MRL, this is food we are talking about, a 60-100 fold increase goes way beyond a calibration tweak, it represents a policy approach of tolerating vastly more chemical residue in our food that we eat.

• Ensure the latest and updated scientific research is considered when making these decisions.  And ensure that a first-principles approach is taken to analysing this data, not just taking information at face value and considering cumulative exposure, not just in isolation.

• We further recommend that New Zealand continue and expand its food residue monitoring programs and make as much of the data as possible public so it can be analysed both by academics and by organizations and food advocates.  If residues of concern are detected the default response should be much greater scrutiny, not a simple brush off and further raising of the limit. 

Ultimately this is about the health and well-being of our people for generations to come, Rock The Vote NZ believes in sparing no quarter in minimizing the exposure to such chemicals. The stakes – public health, trust in the food system, and environmental integrity – warrant a very cautious approach. We commend MPI’s overall commitment to food safety and urge that commitment be upheld by declining to proceed with the proposed glyphosate MRL raise.

Thank you for reading

Rock The Vote NZ