Food Standards Australia New Zealand (FSANZ) is seeking feedback on Proposal P1055, which aims to redefine how genetically modified (GM) foods are classified. We urge the organic sector to unite in requesting an extension to the submission deadline and advocating for an open forum with civil society organisations and the broader community. This will allow for a transparent discussion of the full implications of the draft proposal, which has not been given adequate time for thorough public scrutiny.
We are concerned that FSANZ is not considering the broader implications that may undermine the due process required for such a significant regulatory change. You can make your own HERE (by 5pm September 10th, 2024)
P1055: The FSANZ Proposal
Proposal P1055 is FSANZ’s effort to update and clarify the definitions of GM foods within the Food Standards Code. FSANZ argues that the current definitions, which distinguish between “food produced using gene technology” and “gene technology,” are outdated and do not adequately cover the variety of modern techniques, including New Breeding Techniques (NBTs). To address this, FSANZ proposes a single, streamlined definition of “genetically modified food” and suggests exempting certain NBT foods and refined ingredients from pre-market assessment. The organic sector is concerned that exempting NBT foods could mean that some GMO foods would no longer need to be labelled. This could mislead consumers relying on clear labelling to make informed decisions about their eating choices.
What Are NBTs, and Why Do They Need to Be Labelled?
New Breeding Techniques (NBTs) are advanced genetic methods that alter the DNA of plants and animals. Although NBTs are sometimes marketed as different from traditional GMOs, they still involve genetic modification. The organic sector insists that food products produced using NBTs must be clearly labelled because they involve artificial genetic changes that consumers have the right to know about. Clear labelling ensures transparency and allows consumers to make informed choices aligned with their values, especially in maintaining the integrity of organic and natural food standards.
Why Is the Organic Sector Concerned About P1055?
The organic sector is deeply concerned about the rapid pace of the P1055 proposal and the potential consequences it poses for the organic sector in Australia and New Zealand. The proposal’s shift from a “process-based” to an “outcome-based” definition of GM foods that could lead to reduced transparency, making it harder for consumers to determine whether their food has been produced using gene technology. FSANZ’s decision to exclude NBT foods and refined ingredients from pre-market assessment, claiming they pose no greater risk than conventional foods, is particularly troubling. This approach risks undermining consumer trust and the integrity of organic labelling, which depends on full traceability and clear labelling of all GM ingredients. Despite public demand for labelling GM and gene-edited foods, FSANZ has stated that GM labelling is “out of scope” for this proposal, though some changes to labelling provisions are proposed.
Take Immediate Action: FSANZ P1055 Deadline of September 10th (no extensions)
The FSANZ Proposal P1055 poses a significant threat to the transparency and integrity of our organic standards. To ensure thorough public consultation, we must act now. We urgently need you to complete this survey and/or register a submission with FSANZ before September 10th.
Here’s How You Can Help:
Register your own submission directly with FSANZ (prior to Sept 10th) – HERE
Complete this Survey below – Share widely with your networks and friends
Review the webinar hosted by FSANZ: This session provided an overview of the proposal to attendees.
The organic sector depends on strong, clear regulations to maintain the integrity of our products and the trust of our consumers. Your participation is crucial in ensuring that these standards are not compromised.
Excellent resources are HERE (thanks to OANZ) for those that are seeking more information.
Thank you for your continued support and commitment to protecting our organic community.
FSANZ is proposing to exempt certain foods made through gene technologies like gene editing food. These foods derived from New Breeding Techniques (NBTs) / gene edited, genetically engineered or vat fermented foods will escape regulation and labelling as they will be considered the same as conventional foods (novel). The exempted GE foods will be released into the food chain untested, unlabelled and potentially unhealthy for the dietary needs of consumers. This could damage health and lead to illnesses that are misdiagnosed due to the lack of oversight and diagnostic methods for Health Professionals.
Please look at suggestions in the template below and re-write your submission in your own words.
FSANZ has a Consultation Hub where you can directly submit your comments or email submissions@foodstandards.gov.au or postal address ,which can be found on their site.
Letter Template
Re: Second Call for submission: P1055 Definitions for gene technology and new breeding techniques
Email to: submissions@foodstandards.gov.au I object to the FSANZ proposal P1055 to exempt gene edited and GM food processes and ingredients from notification, assessment, regulation, and labelling.
I therefore strongly insist on –
Rigorous Regulation of all food ingredients derived from NBTs (New Breeding Techniques) and other biotechnologies (GM and gene edited), entering the human food supply.
My right to be fully informed and to choose what my family eats – for cultural and personal reasons – through the full labelling of all Gene Edited and GM foods, whole foods, food ingredients, processing aids, additives, flavours, colours, etc;
Notification, case-by-case assessment of all Gene Edited foods, ingredients, and production processes used in NBTs, without the exemptions that P1055 proposes. with the claims that refining and ultra-processing remove all foreign DNA and proteins;
Rigorous and precautionary assessment of all materials and processes used in food fermentations to produce artificial meat, simulated milk and all other synthetic food-like substances that industry may in future propose;
Post market assessment and ongoing monitoring of all NBT-derived food stuffs that may enter the food supply. Unregulated, exempted NBT developed foods do not have a history of healthy dietary safety that conventional foods do;
Putting the public interest, the right to know, ahead of trade and industry issues, when the costs and benefits of biotech food manufacturing methods and products are assessed;
Requiring the food industry to submit published, peer reviewed, and independent scientific evidence that all NBTs used to produce food stuffs are, in the short and long term, efficacious for the safety, health, and wellbeing of the all consumers;
All food produce, products and supplies regulated and protected from the unlabelled and unwelcome intrusion of whole and ultra-processed foods, made using NBTs and other new food production methods that may in future be developed.
Reference material regarding the risk to the organic sector of this decision
Located on Wiradjuri Country in Peak Hill in Central New South Wales lies two farms belonging to seasoned biodynamic farmers Ray and Judi Unger. Named Waratah and Marylyn, these farms feature unique characteristics that make them suitable for different forms of agricultural activity. Marylyn is formed of heavy clay loam soil packed with rich minerals, making it the perfect medium to grow cereal crops like spelt, wheat, oats, lupin and pasture.
The fenced tree lines border most of the paddocks on Waratah and create wildlife corridors, reduce wind erosion, attract bird life and provide fodder to stock during droughts. Waratah comprises a lighter red ironstone soil type more suited to running their livestock of Merino sheep for wool and White Suffolk cross for lambs as well as Hereford cattle stock. These distinct but complementary farm types allow Ray and Judi to run a diversified mixed-farming broadacre enterprise that offers long-term climatic resilience.
“We have 3,500 acres, and we could nearly crop all that, but we never do,” says Judi. “We only ever crop about a third as the maximum every year because we do crop rotations, so we try to crop about one [rotation] every eight years, so we’re sparing the country, we’re not flogging the soil in the process of growing healthy biodynamic crops and pastures. We’re trying to build up the organic matter and put it into the pasture phase and use it for grazing. It’s all quite entwined.”
When Ray’s father bought the farm several decades ago, farming systems were rather exploitative and heavily reliant on chemical inputs, extracting a considerable toll on the already marginal agricultural land.
“The farm was heavily impacted by cropping and heavy stocking rates,” recalls Judi, prompting the Ungers to consider ways in which they could improve the quality and health of their land and in turn, their crops and livestock.
At a conference in Cowra in 1993, Ray heard an organic farmer speak about organic principles and practices and was immediately drawn to the concept. Organic agricultural methods could help produce high-quality agricultural products in a way that protects and improves the natural environment while safeguarding the health and welfare of all farmed species. Without hesitation, Ray and Judi decided to “go cold turkey” on synthetic fertilisers, insecticides and herbicides in the mid-90s and start the journey towards organic certification and farm management. “I felt this immense weight off my shoulders; we were now in charge of our own destiny,” says Judi.
“We didn’t need an agronomist. We didn’t need people telling us what chemicals need to be applied and when and where.”
Instead, by adopting the organic philosophy and mindset, Ray and Judi committed to learning and observing their land, soil and biology to grow healthier food more sustainably. Following the completion of a TAFE course in organic agriculture, the process of conversion took the Ungers three years, becoming fully accredited with Australian Certified Organic in 1996 and receiving A-grade certification for the crop they grew that year. Shortly afterwards, they began looking into biodynamic practices.
Founded on similar principles to organic agriculture, biodynamic agriculture is a holistic, whole-systems approach to bring plants, animals, soil, ecosystems and people together. Biodynamic systems aspire to generate their own on-farm fertility through practices such as crop rotation, composting and integrating animals to enhance on-farm biodiversity, nurture soil fertility and enable greater farm resilience against extreme weather events. The Ungers have been practicing relatively consistent methods for more than 25 years.
But the agricultural sector has changed significantly over this time. The deregulation of agricultural markets, fluctuating government support and investment, the privatisation of infrastructure and agricultural services, rising costs for fuel and machinery, and increasing consolidation amongst farms and across the entire food chain have reshaped Australian agriculture.
“It’s changed a lot in the 28 years we’ve been doing it,” says Ray. “A lot more dairy farmers have gone down the organic track, but then dairying has retracted; there are fewer dairy farms around because they got bigger, just how most farms got bigger. Cost of production has certainly increased, as has machinery. We probably wear more machinery out than conventional farmers. They can spray 1000 acres in a day and I can plough 100 acres in a day. We’ve had lots of problems, but conventional farmers have had lots of problems too.”
Conventional and organic farming methods have a range of different impacts on soil fertility, biological diversity, livestock health and the health of the farming enterprise. “We don’t have issues that conventional farmers have with bloat and worms. They’re in a situation where they go into town to buy something to fix their problem and basically they’re told, “If you don’t use this stuff, the sky is going to fall!” says Ray.
“Well the sky doesn’t fall. I can look back now and see we’ve been used by the chemical companies. I couldn’t even tell you what Round Up costs anymore.” Fluctuating climatic conditions, from the intensifications of droughts and floods, to unprecedented bushfire conditions, have created increasing pressure on Australia’s agricultural systems and can restrict growing seasons or wipe out entire harvests.
“The current market has been tough. There are more organic grain producers around and we’ve had a couple of good years so there’s plenty of organic grain about,” says Ray. “It’s supply and demand: the current prices [for organic wheat] aren’t enough to cover your costs. In comparison to the droughts of ‘18 and ‘19, where [demand was high and] it was very difficult to buy organic grain to feed livestock. That will happen again when there’s another dry spell.”
Ray and Judi have subsequently invested in sealed storage and silos for grain as a form of on-farm insurance. It grants the ability to store grain in good years and to carry that through to market when climatic conditions may impact production, and there is less supply of organic grain. It’s another way in which the Ungers can take control of when and where they market their grain, and into which market they sell.
While grain crops such as cereals, pulses, legumes and oilseeds make up a small percentage of total organic production in Australia, the organic grain industry has a significant opportunity to expand with the right market development and indicators. Demand for organic products in Australia and abroad has been rising over recent years, as consumers are increasingly considering the health benefits and environmental effects of their food choices. This rising demand is also motivating manufacturers to make organic food more accessible to mainstream markets.
The Ungers have been considering new ways to add value to their business and tap into this rising demand, but need to consider the added costs carefully, whether that be in time, machinery, or labour of value-adding activities. Cleaning, processing, growing special items, packaging, milling, storage, or distribution operations can all be considered as “value-adding” to basic farm commodities like grain.
“I’ve looked at trying to value-add products; to clean grain and bag it,” says Ray. “But you’d need a fair amount of capital to get that all organised; you’d need to set up sheds, buy machinery and you’d need to employ someone possibly to run that side of the business. But that comes with more risk.”
“We’re good at what we do, whether that’s wool or sheep or cattle or grain, but we’re flat out running the farm as we are. So there’s no opportunity without spending a lot more money and employing more people to go and value-add.”
The Organic and Regenerative Cooperative Australia (ORCA) pilot project seeks to determine the best and most profitable products for organic grain farmers like Ray and Judi, together with identifying the market, processing and access barriers that could be resolved through better collaboration, producer representation or investment in storage or processing facilities.
“If ORCA was able to set up a plant to clean grain and then bag it, hopefully, we could get a better return and share in the profit from that operation,” says Ray. Increasing the availability of local abattoirs for the organic industry is another opportunity for investment that Ray believes will help farmers in the region. “30 or 40 years ago there used to be an abattoir in most towns, but now there aren’t enough abattoirs,” says Ray. “Sometimes our stock, our lambs and our cattle, as well as our wool, goes into the conventional market.”
The ORCA project endeavours to unlock some of these barriers and to enable strategic investment into facilities and technology that will lead to better prices for producers. ORCA investigates market trends and opportunities while providing farmers with the technology and data they may need to thrive in the organic grain farming industry. Through a tailored online platform, producers can achieve the transparency and traceability of organic produce now demanded by processors and consumers, as well as achieve fairer pricing along the entire supply chain.
Research, education and innovation are key areas that Ray and Judi believe will help them manage their farm more efficiently and profitably and the long-term sustainability of the organic industry more broadly. They suggest that agricultural drone systems, for example, have an unrealised potential to assist with microbial applications for crops or to support and surveil cattle, all while minimising fuel costs and further impact upon the soil.
Due to the rural isolation that many farmers face, Judi believes that current information and education systems must evolve to meet the needs of organic growers and younger farmers wishing to enter the industry. Different knowledge-transfer activities that are organised by and targeted at the organic farming sector, will help increase knowledge and skills on organic plant and animal production, processing and marketing.
“Organic farming is a process of continual learning,” says Judi. “Part of it is experimentation and trialling new techniques and being able to demonstrate what works. It would be great to get a uni student out on the farm to do a case study and have that research published.”
Judi believes that harnessing the in-depth knowledge acquired through decades of practical experience and translating this into an evidence base that can be shared throughout the organic industry will strengthen the sector. Testing new approaches and technologies, building and compiling rigorous evidence about what works, and disseminating this knowledge widely to farmers, researchers and policymakers can help improve economic and environmental outcomes for producers. Judi also believes that such education is key to equipping future generations of farmers with the skill sets required to prosper in the sector and take full advantage of innovation.
Ray and Judi are taking part in the ORCA project alongside other organic farmers in the Riverina agricultural district in NSW. Together, these farmers are sharing their experiential knowledge, insights and networks to collectively grow together and to diversify and build a better and more resilient organic market. The vision is to strengthen and sustainably grow the entire organic value chain, with shared benefits for farmers, manufacturers and consumers. By collectively working through some of the common barriers faced by organic farmers and unlocking opportunities for greater on-farm profitability, ORCA is committed to improving and amplifying the benefits of organic, regenerative and biodynamic farming across the Riverina and the country.
Written by Eva Perroni, as part of the ORCA project
We are writing to you as constituents, businesses and producers that are involved in the organic industry across Australia. We ask you to support the future of our country’s clean and green reputation, and the urgency in preserving our ecosystems and local food security. The organic industry provides a model for the rest of agriculture, that is localised, transparent and without the additional dependency or high externality costs of conventional agriculture. Our industry needs your support – and we look forward to adding your voice to our charter.
For too long Organics had been thought of as a niche market or component of Agriculture, but if one takes a world view instead of looking at the microcosm of Australia, we have entities such as the EU wanting to transition 25% of their Agriculture to Organics by 2030 via The Green Deal and Farm to Fork initiatives
Organic and regenerative farming systems can:
provide a neutral or positive environmental impact with added benefit of providing co-benefits to the environment and humanity
help to mitigate climate change and adapt to its impacts that are already proven by scientific publications
reverse the loss of biodiversity via organic standard provisions and verified by academia indicating 30% more biodiversity on organic farms
ensure food security, nutrition and public health, making sure that everyone has access to sufficient, safe, nutritious, sustainable food production systems that have been vetted by good science.
preserve affordability of food while generating fairer economic returns, fostering competitiveness of the international supply sector and promoting fair trade
In so doing Organics addresses triple bottom line objectives including:- – Organic Farming enables and accelerates the transition to a fair, healthy and environmentally friendly food system. Government investment is required to address deficiencies in advisory services, financial instrumentsand more importantly participatory research and farmer led innovation are needed instrumentally as they can help resolve tensions, develop and test solutions, overcome barriers and uncover new market opportunities.
Background
Value of the organic sector in Australia $3.65B(AU) and worldwide over $88B(AU)
Urgency of climate change and the direct impact on agriculture sector
Importance of biodiversity value and enhancement on private land
Synergy across different sectors including energy, agriculture, health
Rewarding land stewardship through ecosystem management outcomes
Pioneering industry and independent of Government (historically)
Established Net-Zero pathway for agriculture and business to transition
Key Requests from the Organic & Biodynamic Industry to the Federal Government:-
Endorse domestic regulation in Australia. Knowing it’s direct impact and barrier on domestic and international trade entrants and international equivalency markets
Rewarding producers for their ecological stewardship together with a simple mechanism to ascertain and transition carbon footprint beyond Net-Zero in agriculture and business
Ascertaining a biodiversity value on farmland and conversation area (private & public land)
State recognised Government bodies that support the growth of organic agriculture
Facilitate a Sensitive Site register provided by State Governments as part of ‘right to farm’
Endorse a roadmap in climate resilience, adaptation and long term business resilience planning for regional communities & local economies.
Invest in Research & Development for key biological outcomes across the agriculture sector
Provide regular and rigorous data capture through ABARES with tailored organic data for on-farm production, business, supply and export.
The time is now….
Agriculture in Australia is at a crossroads. Producers are attempting to increase their yields with reducing on-farm profitability while managing higher climate risk exposure than ever before. We need to capture premium markets (like organics) and empower producers with better business profitability and diversified income streams. Our Country needs best in class producers that are resilient against natural disasters and rewarded with better crops, profitable and diversified businesses, healthier and improved natural ecosystems. We need to review the existing farming model that reflects a more sustainable and resilient farming infrastructure that invests in the next generation of producers, better markets with full consideration of the impact on the environment.
Key Considerations:-
True cost of ecosystem services in our waterways, agricultural land, biodiversity and food production should be clearly understood and be a driver of change
Research and Education on the importance of carbon reduction, repurpose and offset to underpin regional resilience and transition agriculture beyond net-zero
Opportunity to strengthen cross sector links between health, education, agriculture & economics
Structures that underpin the food security of our country ahead of dependency on large scale, low value commodity markets that may be affected by external pressures
Add your name HERE to our growing list of supporters, so a bipartisan voice can advocate for healthy agriculture and business production systems for the long term.
If you would like more information or to be kept up to date please subscribe to our blog HERE
We look forward to speaking with you further about how you can support the organic industry more in your region.
The first fully Australian farmer-owned carbon credits, the Eco-Credit, have just been released – with tangible benefits to local farmers, business, communities and the environment.
The Eco-CreditTM scheme was created by the Organic and Regenerative Investment Cooperative (ORICoop), which aims to unite the food value chain and increase the uptake of organic and regenerative practices across Australia by increasing collaboration between farmers, businesses and consumers.
Each Eco-CreditTM represents 1 tonne of CO2 positive emission drawdown, validated annually through rigorous testing, and are provided by ORICoop’s organic, net-positive regenerative farmers who run diverse farm businesses including dairy, cropping, livestock and mixed farming systems.
ORICoop EO Carolyn Suggate said that the Eco-CreditTM concept was developed by ORICoop in conjunction with farmers looking to advance farm system approaches to provide safe, secure and affordable food with a regenerative ecological impact.
‘The scheme links those farmers to external buyers, be that corporate, small business or Mum’s and Dad’s keen to play a role and do their bit in fostering sustainable practices and reducing their own carbon footprints’ Ms Suggate said. To activate carbon drawdown urgently we need all contributors to be empowered to participate.
Victorian farmer Stephen Whitsed is the first ORICoop producer to offer Eco-CreditsTM to the market, and aside from the environmental benefits can see immediate environmental, CSR, and other economic benefits for businesses, producers and local communities.
”It’s an environmentally-friendly credit that rewards organic producers and builds stronger connections between businesses and our on-farm practices that enable carbon benefits to be exchanged. As organic producers we are looking forward to demonstrating our on-farm practices that are increasing carbon drawdown and legitimise better environmental stewardship for the long term,” Mr Whitsed said.
Mr Whitsed said the Eco-Credit process is straightforward for farmers and ‘definitely beneficial’ to his farm and environmental management, and hopes investors will benefit from their transition beyond net-zero and the planetary impact.
“The validation process is through soil testing every year, including GPS points to ensure we soil test in the same place every year. Following that we send the soil samples to a laboratory to be tested, and wait for the results,” he said.
Farmer and organic industry advocate and researcher, Greg Paynter, sees a range of benefits the Eco-Credit scheme will provide, including environmental and ecosystem functioning, farm viability and improved social and mental health outcomes for farmers where stress is alleviated by the additional revenue stream provided by the scheme as a reward for best practice land stewardship.
“It’s a dividend that doesn’t come from production output, it comes from a different stream, the productive and regenerative capacity of the land,” Mr Paynter said.
“In Australia, we are striving for $100 billion worth of production from agriculture annually, but our understanding of the research that comes out of Canada, a very similar country to Australia, is they produce that amount, but 98% of it goes into the cost of production or services to provide that production, so the net profit or return on investment of effort is not very high,” he said.
“But if you value land stewardship and make it worth something, the production of food or fibre you get from the land is a reward and you do it in a manner of organic and regenerative production systems, that conserves the basis of the production system into the future. There is talk of only 60 harvests left in some places in Europe and the soil will be destroyed, so we need to act with urgency – and what the Eco-CreditTM does is offer an incentive to do something whilst still maintaining a living.”
Fourth generation Western Australian farmer and agroecological farm system advocate Mr David McFall said the Eco-CreditTM project links businesses who want to do better, and rewards practices to adjust to the changing climate that are not seen to be outwardly ‘commercial’, especially natural capital management like tree planting, increasing biodiversity and soil carbon and water works for habitat and land cooling.
“This is one mechanism that is farmer-derived and farmer-led. It ticks the boxes in terms of accessibility and linking people who have capacity with people who want to do things in the landscape,” Mr McFall said.
“It’s a journey we’re doing for very practical reasons, there’s farmers like Stephen Whitsed and myself who want to do better, but the ‘do better’ that’s asked of farmers is not necessarily an upfront conventional outcome. So this mechanism takes the risk out of the investment and becomes a shared journey as it connects people who want to see good done, but are perhaps urban-based or don’t have access to land, develop partnerships with a farmer,” he said.
“Each farmer is motivated at different levels, and the intelligence behind this system is that it’s not just carbon, it’s approaching it from an ecosystems services platform – that’s embracing revegetation, and in time will embrace cleaner water and air, and keeps toxic substances out of our food and agricultural production systems.”
Iain Smale, of Pangolin Associates, feels the release of the Eco-CreditTM will be popular for businesses, providing alternative options for carbon credits. He also expects they will raise awareness of the growing organic and regenerative agricultural industry in Australia working to capture carbon and mitigate the key drivers of climate change, which is especially important given per-capita carbon emissions in Australia are amongst some of the highest in the world.
“With the Eco-CreditTM, you’re having a bigger environmental impact than just a carbon credit,” Mr Smale said.
“Australia as a nation in the developed world has close to the highest per capita emissions. Per person it’s around 23-24 tonnes, NZ is around half that, and a lot of Europe is less than half that. It’s because Australia has two main drivers – we’re heavily reliant on fossil fuel, coal and gas generation and it’s the tyranny of distance – people have a lot of transport miles, including for heavy transport, trains and trucks, and we don’t have any high speed rail, so much of our economy is based on fossil fuel,” he said,
** To follow the Eco-Credit journey of this and other farms click HERE
Eco-Credits is a nationwide scheme open to organic and biodynamic producers. Other ORICoop farmers will shortly be stating their pledges and looking to develop partnerships with businesses and processors associated with their farm.
We know it’s been a rough year for many. We are rallying support in the last days of the financial year towards organisations that continue to ‘do good’ through these tough times. Here is our hot list for any tax deductible donations that align with your values …..
* Invest your funds to enable ethical and sustainable returns that don’t cost the earth
Could your business achieve Net-Zero by EOFY 2021?
We are urgently calling on all ethical, organic, conscious businesses to aim for Net-Zero by the End of this Financial Year. Let’s show some love for our planet! Here is how you can start your journey….
* Calculate your carbon and environmental footprint * Choose credits that align with your business values * Reduce your footprint through best practice sustainability
Our newly released Eco-Credits can help you achieve this – while directly benefiting organic producers that are increasing the carbon across their farm businesses. Key outcomes include:-