STEWARDING: GENE EDITING TECHNOLOGY

The biotechnology industry has exerted an enormous global push from approximately 2016 to the current date, to guide regulatory agencies to believe that if a genetically modified organism (GMO) is gene edited but does not contain a detectable novel protein/s or detectable novel DNA, that that GMO is 'substantially equivalent' or comparative to a conventionally or naturally bred organism and does not require regulation. These sorts of gene edited GMOs are called by various names: new genomic techniques - NGTs (EU), new breeding techniques - NBTs (Australia and New Zealand) and new plant varieties (U.S.). Many of these new terms make it difficult to tell that the organism has been modified (gene edited). I.e. it would not only not be regulated, but it would also not be labelled or tracked as a GMO. The global push in Australia and New Zealand is multi-pronged, at minimum incorporating:

Food Standards Australia New Zealand (FSANZ) P1055, August/September 2024 proposal to amend the definitions for 'food produced using gene technology' and 'gene technology' in the Australia New Zealand Food Standards Code (the Code). (PSGR's response)
Evidence that the biotechnology industry is meeting and working with government sectors to secure greater access through bilateral and multilateral trade agreements (which the public do not have access to).
MBIE's proposed Gene Technology Bill which would deregulate these organisms in New Zealand, potentially ensuring that NZ would have one of the weakest jurisdictions in the world. (Discussed in PSGR's February 2025 Bill submission and further illustrated in our April 2025 Report).

These Australia and New Zealand agencies have not:

1. conducted formal risk assessment to methodically analyse whether their claims that the NBTs are as benign as claimed are correct. PSGR show that: a. FSANZ fail to do this work. FSANZ instead, like a babushka doll, drafted white paper after white paper to build the 'case' or the 'fact' that the NBT is the same - however they never evaluated the scientific literature; and as well - b. MBIE never undertook the work to evaluate the risk in the scientific literature to be able to uphold their claim that the NZ proposed legislation would be 'risk proportionate' as they claimed.

2. Taken any step to consider their obligation to the public, to ensure that the public can know whether the food they are consuming is a GMO (i.e. is gene edited) or not.

The idea that GM/GE plants might not be transparently identified, i.e., not tracked and traced, is unethical as studies consistently demonstrate that people - from France, USA, Japan, Russia, China to Vietnam prefer not to consume GMO food and will pay a premium for GMO. The push is unethical as it also obfuscates knowledge about whether a technology is worthy, whether that technology creates broader risks, or whether that technology should be abandoned. The farmers that are growing the product can't know if it is a brand-new untested variety or an old and trusted variety. It wouldn't be labelled.

This is - let's just call it outrageous - when one considers the purpose of the FSANZ Act 1991 on top of consistent scientific research that shows that the public continue to reject GMO foods. I.e. people actively want transparency - the very thing, that the Act is in place to achieve.

September 2024: FSANZ P1055 2nd Consultation proposal to deregulate (perhaps up to 94%) of GMOs by changing the definition - FSANZ Submission PDF or scrollable on Substack. We consider that mainstream media have inadequately discussed the biosecurity risk presented by scalable GMO technology. Worryingly, neither Australian or New Zealand media discussed the P1055 FSANZ consultation to inform the public that a 'paradigm shift' in GMO/GE regulation, from process-based to outcomes-based was being proposed by the food safety authority. If the public do not know, they cannot comment.

February 2025: Submission to the Health Select Committee on the Gene Technology Bill 2024. PSGR’s submission is in two parts (PDF):

Part I: Deficient Policy Formulation: details ways in which the Bill’s drafters have drafted text to narrowly restrict Regulatory powers and prevent wider regulatory scrutiny. This not only leaves New Zealand vulnerable to slow moving problems, it would result in the Regulator having insufficient scope and inadequate information in emergency situations that would enable the Regulator to assure the health and safety of people.
Part II: Recommendations including critical analysis of Bill text: Makes in-depth recommendations and outlines problems and gaps in the Bill text.

March 2025: Presentation to the Health Subcommittee, on behalf of the Physicians and Scientists for Global Responsibility (PSGR) (2:30:00-2:40:00). PSGR’s presentation concerned the Gene Technology Bill that is currently before that select committee.

April 2025: Release of paper - PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform. Bruning, J.R., Dommisse, E.. Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-1-0670678-0-9

PSGR also emailed Members of Parliament (see also accompanying press release)- because:

'PSGR believe that there is significant evidence that actions of the Ministry of Business, Innovation, and Employment (MBIE) officials and the Minister in charge, Judith Collins may have undermined good process to drive outcomes that would severely restrict the capacity of the new gene technology regulator to safely regulate gene edited technologies and organisms.'

With the evidence that the policy process was deficient and could not be considered to conform with Treasury guidelines, PSGR emailed New Zealand's Chief Ombudsman to request a formal Inquiry. However, this was rejected by the Ombudsman on the basis that PSGR had no personal interest (see our correspondence here).

There is evidence that most gene edited organisms could evade pre-market risk assessment and avoid being labelled a GMO/GE product. A European study showed that 94% of current GM/GE plant applications affected by the European GE (new genomic techniques) proposal would not be classified as a GMO. For more information, please scan our Fact Checking 101 page and consider reading our 2023 review paper which outlines where New Zealand stands currently on biotechnology and gene editing.

New Zealand has a low tolerance for unwanted and invasive species. Wilding or volunteer GMO species are a massive problem in north and south America. It is not easy to estimate how highly scalable GMO technologies could themselves become a biosecurity risk for future generations. This was not considered in FSANZ 2024 consultation, and we are yet to see a risk assessment for the gene technology reform process by the Ministry of Business, Innovation and Employment, who are currently attempting to deregulate many gene editing techniques and organisms.

If you think it is 'over the top' that PSGR state that MBIE are working to deregulate gene editing techniques and organisms, our recent paper PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform reveals how MBIE's problem definition, shown in their Regulatory Impact Statement was focussing on - not the safety of GMOs - but the deregulation of them. MBIE then commenced to use scientists they funded to produce GMOs and gene edited organisms, and people and organisms with biotech investments or partnerships to develop biotech - to act as the 'experts' for the consultation for the new regulations and laws.

PSGR's Hijacking Democracy paper (April 2025) shows the paper trail and reveals the extraordinary conflicts of interest at play.

PSGR Professor Jack Heinemann, Director of the Centre for Integrated Research in Biosafety (INBI); Tessa Hiscox and Andrew McCabe. Centre for Integrated Research in Biosafety (INBI), at New Zealand's University of Canterbury, & some of the co-authors of INBI's Submission to the Parliament Health Committee on the Gene Technology Bill 2024.: Proposed NZ Gene Tech Bill: Scientists say risk tiering framework is not risk proportionate 'scientific case is not made'.

'New Zealand would have the most extreme combination in the world of proposed species breadth (microorganisms, plants, animals) and process (e.g. SDN2) exemptions.'

Stewarding: New gene editing techniques & organisms

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