February 2026 – TOS issue 204

Key Issues and Sector Concerns

Several critical issues have emerged through the consultation process. The most significant relates to export market access. The sector has strongly advocated for an exemption pathway that would allow export products to meet importing country requirements where these conflict with the Organic Standards Regulations 2025 provisions.

The concern is practical: if the Organic Standards Regulations 2025 prohibits an input or practice that the European Union or United States permits (or vice versa), New Zealand exporters would face double compliance – meeting both the importing country’s requirements and New Zealand’s domestic standard, even where these conflict. This creates additional costs and complexity for exporters who are already fully compliant with their destination market’s organic requirements. Without such flexibility, New Zealand organic exporters could face competitive disadvantages compared to producers in countries whose domestic standards align more closely with importing country requirements.

 

The regulations also affect imports. From 31 March 2028, products imported into New Zealand and sold as organic must meet the Organic Standards Regulations 2025. This requirement may have significant implications for Pacific nations that currently export organic products through New Zealand, potentially requiring these producers to meet New Zealand’s standard or establish alternative trade routes. The impact on Pacific trading relationships and food security considerations remains under discussion. Specific rules for the approval of non-NZ certification bodies certifying products to be imported have not yet been confirmed.

 

International alignment remains a priority. New Zealand exports the majority of its organic production, and the current OOAP framework provides access to major markets including the United States (NOP), European Union, Japan (JAS), Canada (COR), Taiwan, Switzerland, and several other trading partners through bilateral and multilateral equivalency arrangements. Formal assessment of alignment between the Organic Standards Regulations 2025 and IFOAM standards has not yet been undertaken, as the regulations are still in public consultation.

 

However, the current system is complex: New Zealand certification bodies have required accreditation by foreign governments for market access to Canada and Japan, while cooperation agreements between Korean and Chinese certification bodies have been necessary for New Zealand exporters to reliably access those markets. This patchwork of requirements creates significant compliance costs and administrative burden for both certification bodies and exporters.

MPI is working to establish new equivalency arrangements under the Organic Standards Regulations 2025 framework that will maintain and potentially simplify this market access, allowing Organic Standards Regulations 2025-compliant products to enter international markets without requiring multiple certifications or complex bilateral arrangements. However, the details of these arrangements—and their timeline—remain under development, creating uncertainty for exporters who depend on seamless access to these established markets.

 

The consultation process has also highlighted concerns about proportionality and regulatory burden, particularly for smaller operations. While robust standards are essential for organic integrity, the sector has emphasized the need for risk-based approaches and outcomes-focused requirements rather than prescriptive rules that may not suit New Zealand’s diverse production systems.

 

A distinctive feature of New Zealand’s approach is the establishment of a government registry of approved inputs. Unlike most overseas organic regulations, which provide general criteria for allowable inputs, the Organic Standards Regulations 2025 will maintain a list of specific brand name products registered for use in organic production. Only brand name inputs appearing on this government registry will be permitted in organic operations, though this requirement does not apply to farm-produced inputs. MPI-appointed data assessors—initially BioGro and AsureQuality—will evaluate products for inclusion on the registry. This approach provides clarity for operators but represents a significant departure from international norms and creates additional administrative requirements for input manufacturers seeking to serve the New Zealand market.

 

Implications for Certification Bodies

 

The transition creates significant operational changes for New Zealand’s certification bodies—though under the new framework, they will no longer be called certification bodies. Instead, they become ‘Registered Entities’, and operators will be ‘registered’ rather than ‘certified’. This terminology shift reflects a fundamental change in the regulatory model: rather than private certification to voluntary standards, the system becomes one of registration against mandatory national standards.

 

Registered Entities will require accreditation to either ISO/IEC 17065 (product certification) or ISO/IEC 17020 (inspection) to operate under the Organic Standards Regulations 2025 framework. The Organic Standards Regulations 2025 scope is comprehensive, covering production, processing, importing, exporting, retail, and handling of organic products. Wine production, while governed separately under New Zealand’s Wine Act, will need to align with the Organic Standards Regulations 2025 requirements for organic claims.

 

This change has implications beyond semantics. The current system’s complexity with certifiers maintaining multiple international accreditations to serve export markets will be streamlined as MPI assumes responsibility for negotiating international equivalency. This simplification offers cost savings and reduced duplication, though it also requires certification bodies to restructure their operations and fee models.

 

The long-term market structure for organic verification in New Zealand remains to be determined as the system transitions to the new regulatory framework.

 

Looking Ahead

As New Zealand moves toward 31 March 2028 implementation, several questions remain unresolved. The release of Tranche 3 will be crucial for operators to understand their complete compliance obligations. The sector awaits clarity on international equivalency mechanisms, verification frequency requirements, and transitional provisions for existing certified operations. Work is ongoing to determine how operations currently certified under OOAP and private standards will transition to the Organic Standards Regulations 2025 framework.

 

The consolidation of New Zealand’s organic framework under the Organic Standards Regulations 2025 represents a maturation of the sector and alignment with international regulatory practice. Success will require ongoing collaboration between government, certification bodies, and operators to ensure the framework maintains organic integrity while remaining workable and internationally competitive.

 

For an export-dependent sector in a geographically isolated nation, getting this balance right is essential.