Risk Management Proposal:  
Hulled hemp seed a mendments to the import health 
standard G rain and Seeds for Consumption, Feed, or 
Processing   
GCFP.IHS  
 
 
 
 
 
 
 
 
 
 
 
Prepared for  public consultation   
by Plant Product Imports   
Animal and Plant Health Directorate  
 
 
 
 
 
 
 
 
November  2023 
 
 
Disclaimer  
 
While every effort has been made to ensure the information in this publication is accurate, the  Ministry  for Primary Industries 
does not accept any responsibility or liability for error of fact, omission, interpretation or opinion that may be present, nor for 
the consequences of any decisions based on this information.  
 
This publication is also available on the Ministry for Primary Industries  website at  
http://www.mpi.govt.nz/news -and-resources/publications/   
 
 
© Cro wn Copyright – Ministry  for Primary Industries   
i Contents  Page 
 
1 General information  1 
1.1 Purpose  1 
1.2 Submissions  1 
2 Proposed changes and rationale  1 
2.1 Background  1 
2.2 Summary of risk assessment  1 
2.3 Conclusion  3 
3 Feasibility and consequences of the proposed changes  3 
4 References  4  
Ministry for Primary Industries   RMP: Amendment to GCFP.IHS  • 1 1 General information  
1.1 Purpose  
(1) Import health standards  (IHS)  outline the requirements to effectively manage biosecurity risk . 
(2) The purpose of this document is to  outline how the proposed  changes to the requirements for hulled hemp 
seeds will manage the biosecurity risk .  
1.2 Submissions  
(3) Information on making a submission can be found at the followi ng hyperlink : 
2 Proposed changes and rationale  
(4) We propose removing phytosanitary measures in the Grain and Seeds for Consumption, Feed, or 
Processing Standard  for the following fungal pathogens for import ed hulled  hemp seeds:  
a) Curvularia cymbopogonis  
b) Leptosphaeria woroninii  
c) Septoria cannabis  
2.1 Background  
(5) Cannabis sativa  (hemp) seeds , both whole and hulled,  have been imported into New Zealand for 
consumption, feed , or processing  for many years .  
(6) Hulled hemp seed , also known as hemp heart, refers to the soft  inner part of the hemp seed with the outer 
shell (hull or sheath) remo ved. Hulled hemp seeds are imported into New Zealand for use in the food and 
health industries.  
(7) Hulled hemp  seeds are imported under Option 1 of the Cannabis sativa  schedule in the IHS. The existing 
measure s require  a phytosanitary certificate issued by the National Plant Protection Organization ( NPPO ) 
of the exporting  country . This certificate should include an additional declaration affirming that the seeds 
have been hulled and a re free of  three specified fungal pathogens through ‘pest free area’, ‘pest free place 
of production’, or ‘negative laboratory test results’.  
(8) MPI has conducted a review of the three spec ified fungal pathogens associated with  hulled seeds. 
Consequently, we propose t o remov e these phytosanitary requirements due to insufficient evidence 
supporting their association with hulled hemp seeds.   
2.2 Summary of risk assessment  
2.2.1 Curvularia cymbopogonis  
(9) Curvularia cymbopogonis  (synonym:  Cochliobolus cymbopogonis ) is a plant pathogen causing  Curvularia  
leaf spot in hemp 1 & 5). Typically , the pathogen overwinters in plant debris near the soil surface (6). 
(10) There is one report of the pathogen found in Cannabis sativa  seeds in  Nepal, claiming that seed infection 
is likely external to the seed coat  (6). Apart from this report, no additional studies have  linked  this 
pathogen to seed s. We conclude that  the pathogen is either found only on the seed  coat,  or possibly not 
on seeds  at all. Considering the hulling process removes the seed coat, it is unlikely  the pathogen can 
enter New Zealand associated with hulled hemp seeds, posing no risk.  
(11) No new reports or studies on this pathogen, demonstrating adverse effects on hemp, have emerged since 
the 1960s, which described a Curvularia  sp. causing leaf spots on Cambodian Cannabis  spp (7et al, 
2000 ). This  indicates that , even if the pathogen could establish, it would have no adverse effect . 2 • RMP: Amendment to GCFP.IHS  Ministry for Primary Industries   
Key q uestion for submi tters  
Do you have any additional evidence regarding  the association  of this pathogen with hulled hemp seed s?  
2.2.2 Leptosphaeria woroninii  
(12) Leptosphaeria woroninii  is a plant pathogen causing Leptosphaeria blight  in hemp ( 4 & 10). This pathogen 
is listed as a leaf, stem, and root hemp disease (7). 
(13) We could not  find sufficient evidence confirm ing the association of this pathogen with Cannabis sativa  
seeds. A single  study from Romania report ed L. zuoroninii  from Cannabis sativa  seeds ( 71). While some 
Leptosphaeria  species (such as L. maculans ) are known to survive mostly as dormant mycelium in the 
seed coat and sometimes in the embryo ( 11), there is no evidence  supporting that L. woroninii can survive  
in hemp seed s. Consequently,  we consider  the likelihood  of this pathogen to enter and establish in 
New Zealand through hulled hemp seeds to be  negligible .  
(14) There is little information available on the pathogen's impact , and we were unable to find any published 
literature on this  topic . The absence of  internati onal reports , including those from regions  where the 
pathogen  is present , suggests  that the impact of the pathogen is negligible.  
 
Key question for submitters  
Do you possess  additional information about this pathogen , or its association with hulled hemp seeds  that 
may not have been included in our review ?  
2.2.3 Septoria cannabis  
(15) Septoria  (yellow) leaf spot is one of the most frequent diseases of hemp cultivars ( 8). The pathogen mostly 
overwinters  as conidia  in plant debris near the soil surface  and spread s locally through rain and water  (2). 
(16) Septoria  cannabis  has not been implicated in seed -borne infection  (3). Upon thorough literature  review , we 
found no studies reporting the presence of  S. cannabis  on seed s. Additionally, Septoria  leaf spot rarely 
spreads to fruit, making it unlikely to spread to Cannabis  flowers ( 9 2017 ). On this basis , we consider  it 
unlikely  for the pathogen to reach Cannabis  seed s.  
(17) There are no quantitative estimations of crop losses in the literature, but crop damage s were  reported in 
Italy in 1935 , and Pakistan  in 1978  (3). However, no recent outbreaks  have been documented . Given its 
foliar nature , it is likely that implementing good practices , such as avoiding overhead irrigation, covering 
the growing area with mulch , and burying/disposing plant debris , has controlled the disease successfully  in 
affected areas .  
(18) As this pathogen is not associated with hemp seeds, and seed -borne transmission is not known to occur 
(2), the likelihood of the pathogen entering New Zealand through hemp seeds, especially hulled seeds, is 
negligible . 
 
Key question for submitters  
Considering that  Septoria cannabis  is neither seed -borne nor seed -transmitted, can you identify any 
rationale for maintaining the additional phytosanitary measures specified for the import of hulled Cannabis  
sativa  seeds?  
2.3 Conclusion  
(19) There is no evidence to support the establishment of the three pathogens in New Zealand from imported 
hulled hemp seeds. Our assessment indicates insufficient justification for retaining additional phytosanitary 
measures for these fungal pathogens when importing hulled hemp seeds .  
 
1 the original paper (Negru et al., 1972 ) is not in English .  
Ministry for Primary Industries   RMP: Amendment to GCFP.IHS  • 3 3 Feasibility and consequences of the proposed change s 
(20) We expect that these changes will facilitate trade , making it easier for importers to bring in  hulled hemp 
seeds.  
(21) These changes  are not expected  to have any negative impacts on domestic production .  
(22) The proposed changes do not affect other requirements of the standard and will not impose additional 
costs on New Zealand importers.  
  4 • RMP: Amendment to GCFP.IHS  Ministry for Primary Industries  4 References  
 
1. American Phytopathological Society - APS (2023) Diseases of Hemp ( Cannabis sativa  L.). 
https://www.apsnet.org/edcenter/resources/commonnames/Pages/Hemp.aspx . Last update 04.08.2003.  
 
2. CABI Compendium (2019) Septoria cannabis (yellow leaf spot). 
https://www.cabidigitallibrary.org/doi/10.1079/cabicompendium.49641 . Published online: 20 November 2019.  
 
3. CABI, Plantw isePlus Knowledge Bank (2019) Septoria cannabis  (yellow leaf spot). 
https://plantwiseplusknowledgebank.org/doi/10.1079/PWKB.Species.49641 . Published online: 20 November 
2019.  
 
4. CABI Compendium  (2021) Leptosphaeria woroninii  (leptosphaeria  blight). 
https://www.cabidigitallibrary.org/doi/full/10.1079/cabicompendium.77205763 . Published online: 23 February 
2021.  
 
5. Manamgoda, D; Cai, L; Bahkali, A; Chukeatirote, E; Hyde, K (2011). Cochliobolus : An overview and current 
status of species. Fungal diversity,  51: 3-42.  
 
6. McPartland, J M; Cubeta, M A (1997) New species, combinations, host associations and location records of 
fungi associated with hemp ( Cannabis sativa ). Mycological Research , 101(7): 853 -857.  
 
7. McPartland, J M; Clarke, R C; Watson, D P (2000)  Hemp diseases and pests : management and biological 
control: an advanced treatise . 
 
8. Rahnama, M; Szarka, D; Li, H; Dixon, E; Castlebury, L; Ward Gauthier, NA (2021) Reemergence of Septoria  
Leaf Spot Caused by Septoria  cannabis  on Hemp in Kentucky. Plant Disease  105:9 : 2286 -2289.  
 
9. Royal Queen Seeds  - RQS  (October 2017) Leaf Septoria  (Yellow  Leaf Spot) On Cannabis  Plants. 
https://www.royalqueenseeds.com/blog -leaf-septoria -yellow -leaf-spot-on-cannabis -plants -n678 . 
 
10. Wang S. H (2021 ) Diagnosing hemp and Cannabis  crop diseases: in Diagnosing stem diseases, CABI Books.  
 
11. West, J S; Kharbanda, P D; Barbetti, M J; Fitt, B D (2001) Epidemiology and management of Leptosphaeria 
maculans  (phoma stem canker) on oilseed rape in Australia, Canada and Europe.  Plant Pathology , 50(1):10 -
27.