2026 Hazardous Substances and New Organisms Amendment Bill (304-1)

The Hazardous Substances and New Organisms Amendment Bill (304-1): This assessment provides evidence that it will likely frustrate the legislative intent of the HSNO Act.

Call on the Primary Production Committee. PSGRNZ opposes this Bill and calls on members of Parliament to reject this Bill in its entirety and requests that the Primary Production Committee to pause proceedings and return it for fundamental revision, following genuine consultation extending well beyond the narrowly selected groups engaged to date.

Sections [4-7] highlight specific failings which PSGRNZ explicitly rejects.

PSGRNZ opposes the specific mechanisms this Bill uses to achieve efficiency, because they systematically reduce the scientific rigour, public participation, and independent oversight that the HSNO Act was designed to provide; and submit that the Regulatory Impact Statement (RIS) is unfit, and that the Bill is premature and fundamentally misconceived for the following reasons:

The underpinning policy prioritised industry concerns about process speed, with human and environmental health protection treated as secondary considerations throughout.
The Bill has a deficient basis, as it ‘copies’ and ‘pastes’ the policy foundation from the Ministry for Regulations’ Agricultural and Horticultural Products Regulatory Review (2025).
The Review and RIS directly contradicted the Parliamentary Commissioner for the Environment, by claiming that the current systems are effective for managing risks.
The targeted stakeholder engagement for Bill policy was dominated by organisations with direct commercial interests in its outcomes; human and environmental health considerations not discussed. No independent toxicologists, public health bodies, environmental advocates, or affected communities were included.
The process is upside down. The risk assessment consultation and framework should have been developed prior to the Bill, to then inform development of the Bill.
The process is being shunted through at the same time that the Ministry for the Environment is being disestablished. Participating officials and Ministers would know this.
The process is being shunted through just prior to a new NZEPA CEO commences giving that new CEO to take part in design and scope of any regulatory amendments.
The risk assessment framework, universally acknowledged to be outdated and unfit for purpose, is currently directed for redesign by a consultancy with commercial conflicts of interest, and a preference for maximizing efficiency in navigating regulatory systems.
Faults: The Bill's text, taken as a whole, risks undermining the principles and purposes of the HSNO Act, the very framework it purports to improve.
The Bill invents new terms (denewed), creates new meanings for language (vagrant), and fails to define key terms (low-risk, risk-species, recognised international regulator, significant public interest and risk proportionate).
Faults: The Bill creates a fast-track approval pathway requiring sign-off from just two overseas regulators. The NZEPA has no mechanism to ask whether those two decisions rest on recent high-quality reviews. Two jurisdictions can both trace back to a single unreviewed assessment and New Zealand can view that as sufficient.
Faults: The Bill appears to contradict a 2014 High Court finding by allowing the NZEPA to declare that a genetically modified organism is a ‘denewed’ organism.

2026 Hazardous Substances and New Organisms Amendment Bill (304-1)

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