National Beekeepers’ Association v MAF
The 2007 Court of Appeal decision, National Beekeepers' Association of New Zealand v Chief Executive of the Ministry of Agriculture and Forestry [2007] NZCA 556 (the Beekeepers' Case) concerned the importation of honey from Australia in 2006.
For many years prior to this, New Zealand had prohibited the importation of honey and other bee products from Australia. This prohibition was lifted in August 2006 when the Director-General of the Ministry of Agriculture and Forests (MAF) issued an Import Health Standard (IHS) under the Biosecurity Act which allowed the importation of such honey.
The importation of Australian honey in December 2006 was opposed by the National Beekeepers' Association which brought an application for judicial review in the High Court, contending that the imported honey contained a potentially harmful bacterium Paenibacillus alvei (P. alvei) not previously identified as being present in New Zealand. The risks posed by P. alvei and other potentially harmful bacteria had been assessed by MAF before the IHS was issued.
The key issue in the case was whether P. alvei was a "new organism" which could not lawfully be brought into New Zealand without an approval under the HSNO Act.
In the High Court, Simon France J rejected the Beekeepers' Association's submission that approval under HSNO was required, accepting the submission by MAF that an approval under HSNO was not required for new organisms which were merely "passenger" organisms associated with the importation of other goods. The Judge said that approval under HSNO was only necessary where the new organism was itself the intended import. Any risks associated with passenger organisms were to be dealt by MAF under the Biosecurity Act alone. The issuing of the IHS by MAF was therefore lawful.
The Beekeepers' Association appealed the matter to the Court of Appeal which allowed the appeal after a careful examination of the two statutes, concluding that " ... honey or other bee products from Australia containing P. alvei may not be imported without both biosecurity clearance under the Biosecurity Act 1993 and an approval granted for new organisms under the Hazardous Substances and New Organisms Act 1996"
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National Beekeepers' Association of New Zealand v Chief Executive of the Ministry of Agriculture and Forestry [2007] NZCA 556 (the Beekeepers' Case) therefore " ... clarified the scope of the two Acts in its finding that all new organisms imported into New Zealand must have prior approval under the HSNO Act"
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The clarification of policy following the Beekeepers' case
The Bill amends both the Biosecurity Act and the HSNO Act to " ... make it clear that:
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risks from all non-genetically modified organisms imported incidentally in association with imported goods will be managed by MAF [the Ministry of Agriculture and Forestry] under the Biosecurity Act;
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risks from non-genetically modified new organisms imported other than incidentally in association with imported goods, and risks from all genetically modified new organisms, will be managed by ERMA [Environmental Risk Management Authority] under the HSNO Act"
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Additional amendments are made to both Acts to ensure that the legislation " ... operates as intended"
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