Submissions

In late May 2024 we submitted to the Climate Change Commission on the Draft Advice on New Zealand’s Fourth Emissions Budget.

Our submission focused on nitrous oxide emissions, in particular those associated with fertiliser use.

In late May 2024 we submitted to the Climate Change Commission on the Review of the 2050 Emissions Reduction Target.

Our submission focuses on the Commission’s assessment of significant change since the 2019 target commitments were made. We focus on four of the factors outlined in the Climate Change Response Act 2002 that should be considered before a change to the target is recommended: Global Action; Scientific understanding of climate change; New Zealand’s economic or fiscal circumstances; and technological developments

In May 2024 we submitted to Select Committee on the Regulatory Systems (Primary Industries) Amendment Bill.

Our submission supports the amendment to the definition of agricultural compound in the Agricultural Compounds and Veterinary Medicines Act to cover products whose purpose is mitigation of environmental impacts. We focus on the definition of inhibitor and transitional arrangements, in particular that the definition for inhibitors does not inadvertently exclude the use of urease or nitrification inhibitors.

In March 2024 we submitted to the Environmental Protection Agency on the Amendments to Hazardous Substances (Importers and Manufacturers) Notice.

In our submission we supported the proposal that fertiliser products are to be excluded from the quantity reporting requirements and highlighted that those materials imported as raw materials for the manufacture of fertilisers, as well as materials imported and applied with fertiliser e.g., urease inhibitors, should also be exempt and not inadvertently captured in the reporting requirements.

With a focus on fertiliser, FANZ has submitted on the Climate Change Commission’s '2023 Draft advice to inform the strategic direction of the Government’s second emissions reduction plan'. 

FANZ supports the proposed recommendations for agriculture. The fertiliser industry has supported farmers to contribute to the reductions through increased efficiencies, precision agriculture technologies, improved management and reductions in nitrogen fertiliser use.

Enabling use and recognition of a broad range of emissions-reducing practices and technologies is a key to realising emission reductions. 

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In April 2023 we submitted to the New Zealand Productivity Commission on Improving Economic Resilience.

The key points of our submission were that sourcing materials from around the world is at the heart of the supply of fertiliser ingredients for food production in New Zealand. We focused on two aspects of supply chain risk - sourcing materials globally and getting materials to New Zealand.

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Our first submission of 2023 was on the Natural and Built Environment Bill, to the Environment Select Committee. 

We focused on the provisions relating to soils in the Bill in the context that farming and food production are critically dependent on New Zealand's soils, both now and for the future.

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 We made a submission to the Ministry for the Environment on Te tātai utu o ngā tukunga ahuwhenu - Pricing agricultural emissions.

Our submission outlines why the Association strongly supports the pricing mechanism as originally outlined in the He Waka Eka Noa partnership proposal. The proposal provides a path forward for managing agricultural emissions, while recognising the importance of our primary exports to the New Zealand economy.

We also detail why we support a farm-level levy system which includes nitrogen fertiliser; and oppose an interim processor-level levy in 2025. 

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Our submission to the Ministry for the Environment on Exposure Draft of Amendments to the National Policy Statement for Freshwater Management 2020 was generally supportive of the proposed technical amendments.  The exception was the clause relating to a specific focus on managing nutrients to achieve on-farm outcomes.

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