Submission on proposed amendments to the Gene Technology Regulations 2001

We have made a submission to proposed amendments by the Office of Gene Technology Regulation (OGTR) to the cost recovery, traceability, and remediation provisions of the Gene Technology Regulations 2001.

Our submission addresses the downstream impact of the proposed amendments on Australia's organic sector—specifically, the effect of the new authorisation pathways (Non-notifiable Dealings, Notifiable Dealings, Permits, Licences, and the GMO Register expansion) on supply chain traceability for industries that must exclude all gene technology outputs to maintain certification and market access.

This submission is one of three related submissions by OOA: a separate DAFF CRIS submission addresses organic export regulatory services and whole-of-DAFF cost recovery, and a separate APVMA submission addresses agricultural and veterinary chemical externalities.

OOA's submission addresses both the environmental stewardship dimension and the export market access dimension of the organic sector's relationship to the OGTR's regulatory framework.

• All certified organic operators—whether exporting or selling domestically—are required by their certification standards to internalise environmental management obligations that fall within the scope of the OGTR's environmental protection mandate. These include the maintenance of defined biodiversity conservation areas (a minimum of 5% of total farm area under the domestic voluntary standard AS 6000:2015 and the export mandatory National Standard, currently 2.65 million hectares of the total 53 million hectares under organic management with a replacement cost valued at $273 million annually (based on the NSW BCT median of $103/hectare)), the prohibition on synthetic chemical and synthetic nitrogen inputs, and documented management of soil health, water resources, and ecological connectivity. These are auditable conditions of certification, not voluntary commitments.
• When gene technology contamination—whether from intentional release, NND-classified dealings, or undisclosed gene technology-derived ingredients in agricultural inputs—degrades land managed under these environmental obligations, the consequence is both environmental (loss of a documented, auditable environmental management function) and commercial (loss of certification).

Gene technology contamination threatens organic operators' taxonomy alignment and access to sustainable capital flows—a consequence that is distinct from, and additional to, the environmental and market access consequences addressed in this submission.

OOA's submission also addresses the sustainable finance dimension of the organic sector's relationship to the OGTR's regulatory framework, which requires taxonomy-aligned activities to not undermine biodiversity, water resources, or pollution prevention objectives. Gene technology contamination threatens organic operators' taxonomy alignment and access to sustainable capital flows.

Read the full submission

Become a member today