Risk Management Proposal:  
Amendments to the Import Health Standard  
Seeds for Sowing  
155.02.05 
 
 
 
 
 
 
 
 
 
 
 
Prepared for public consultation  
by Plant Germplasm Imports  
Animal and Plant Health Directorate 
 
 
 
 
 
 
 
 
 
June 2022 
 
 
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/   
 
 
© Crown Copyright – Ministry for Primary Industries  
i Contents Page 
 
Submissions 1  
1 General information 3  
1.1 Purpose 3  
1.2 Background 3  
1.3 Timing and consultation 3  
1.4 Background and context to consultation 3  
2 Proposed amendments to the standard 4  
2.1 Regulatory changes to the standard 4  
2.2 Non-regulatory changes to the standard 4  
3 Proposed amendment 1: Changes to the testing requirements for Capsicum  
(capsicum), Solanum melongena  (eggplant), Solanum lycopersicum  (tomato) and 
Zea mays  (corn) small seed lots 5  
3.1 Background 5  
3.2 Rationale 7  
3.3 Feasibility of the proposed change to the standard 10  
4 Proposed amendment 2: Addition of specific import requirements for Raphanus 
sativus with a requirement for a phytosanitary certificate 10  
4.1 Background 10  
4.2 Rationale 12  
4.3 Feasibility of the proposed change to the standard 13  
5 Proposed amendment 3: Addition of Matthiola incana  and Cyperus papyrus  to 
Appendix 4 of the standard (approved species for import as pelleted seed) 13  
5.1 Background 13  
5.2 Rationale 14  
5.3 Feasibility of proposed change to the standard 15  
6 Proposed amendment 4: Addition of a seed testing option for pests with specific 
requirements on the Phaseolus  and Pisum schedules 15  
6.1 Background 15  
6.2 Rationale 16  
6.3 Feasibility of proposed change to the standard 17  
7 Proposed amendment 5: Removal of measures and specific requirements for 
fungal pests 19  
7.1 Background 19  
7.2 Rationale 20  
7.3 Feasibility of proposed changes to the standard 21  
8 References 23  
Appendices 26  
Appendix 1: Species, pests and measures 26  
Appendix 2: Technical advice on sampling of imported seed consignments 28  
Appendix 3: Example calculation of composite sample size 30  
Appendix 4: Importer declaration template 38  ii 
 Appendix 5: Phaseolus /Pisum testing options technical advice 39  
 41 
Appendix 6: Technical advice on  Panicum  49  
Appendix 7: Excerpts showing changes in the standard 64   
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  1 Submissions 
The Ministry for Primary Industries (MPI) invites comment from interested parties on the 
amendments to the import health standard (IHS) Seeds for Sowing  (the standard).  
 
An import health standard (IHS) “specifies requirements to be met for the effective 
management of risks associated with importing risk goods, including risks arising because 
importing the goods involves or might involve an incidentally imported new organism.” 
(section 22, Biosecurity Act 1993) 
 
MPI would like feedback on the following proposed changes to the standard. 
 
 The specific requirements for small seed lots of Capsicum , Cucumis, Cucurbitaceae , 
Solanum lycopersicum , Solanum (Solanum melongena  only) and Zea will be amended. 
 A new schedule for Raphanus sativus  (radish) will be added to the standard, with a 
requirement for a phytosanitary certificate. 
 Matthiola incana  and Cyperus papyrus  will be added to the list of approved species for 
import as pelleted seed (Appendix 4 of the standard). 
 A seed testing option will be added for pests with specific requirements on the Phaseolus  
and Pisum schedules. 
 The fungal pests Peronosclerospora sorghi  and Sclerospora graminicola  will be removed 
from the Panicum schedule. 
 The fungal pests Rhizopus maydis  and Phaeocytostroma ambiguum  will be removed from 
the Zea schedule. 
 The fungal pest Cercospora loti  will be removed from the Lotus schedule. 
 
Include the following in your submission:  
 The title of the consultation document in the subject line of your email 
 Your name and title 
 Your organisation’s name (if applicable)  
 
Send submissions to plantimports@mpi.govt.nz  by the 26th of July. 
  2 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Feel free to include any technical information you have that supports your submission. While 
we prefer email, if you would like to send your submission by post, you can mail it to: 
 
Plant Germplasm Imports 
Animal and Plant Health Directorate 
Biosecurity New Zealand  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Submissions received by the 26th of July will be considered as we develop the amended 
standard. Submissions received after the closing date may be held on file for consideration 
when the issued standard is next revised/reviewed.  
 
 
Official Information Act 1982 
Please note that your submission is public information, and it is MPI policy to publish 
submissions and the review of submissions on the MPI website. Submissions may also be the 
subject of requests for information under the Official Information Act 1982 (OIA). The OIA 
specifies that information is to be made available to requesters unless there are sufficient 
grounds for withholding it, as set out in the OIA. Submitters may wish to indicate grounds for 
withholding specific information contained in their submission, such as information being 
commercially sensitive or personal. Any decision to withhold information requested under the 
OIA is reviewable by the Ombudsman.    
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  3 1 General information 
1.1 Purpose 
 The purpose of this document is to:  
 Provide relevant background information about the import health standard Seeds 
for Sowing  (the standard); 
 Outline the proposed amendments to the standard;  
 Provide the rationale for the proposed amendments and how they manage risk; 
and 
 Ask for feedback on the proposed amendments. 
1.2 Background  
 The current version of the standard was issued and came into effect on 21 February 
2022. The standard was issued under section 22 of the Biosecurity Act (1993) and 
applies to seeds for sowing that are imported into New Zealand from foreign countries 
and territories. 
1.3 Timing and consultation 
 The proposed amendments to the import health standard Seeds for Sowing  were 
released for consultation on the 14th of June and will remain open for consultation 
until the 26th of July. 
1.4 Background and context to consultation 
1.4.1 International regulation of risk goods 
 “The World Trade Organization Agreement on the Application of Sanitary and 
Phytosanitary Measures (SPS Agreement) sets in place rules that protect each 
country’s sovereign right to take the measures necessary to protect the life or health of 
its people, animals, and plants, while at the same time facilitating trade. It embodies 
and promotes the use of science-based risk assessments to manage the risks associated 
with the international movement of goods. The SPS Agreement guides how 
New Zealand sets standards and makes decisions related to biosecurity.” (MAF et al., 
2009, p. 1)  
 “In particular, [it is] important to maintain the standards of transparency and scientific 
rigour required by the SPS Agreement and to make decisions as quickly as possible. 
This will encourage other countries to comply with the rules of the SPS Agreement 
and also demonstrate that New Zealand’s strict controls are justified to countries that 
challenge them.” (MAF et al., 2009, p. 13)  
1.4.2 Domestic regulation of biosecurity risks associated with craft arrivals 
 The New Zealand biosecurity system is regulated through the Biosecurity Act 1993 
(the Act). Section 22 describes an import health standard and requires all risk goods 
entering New Zealand to be managed by one. MPI is the New Zealand government 
ministry responsible for maintaining biosecurity standards for the effective 
management of risks associated with the importation of risk goods and craft into 
New Zealand (Part 3, Biosecurity Act 1993). MPI is committed to the principles of 
transparency and evidence-based technical justification for all phytosanitary measures, 
new and amended, imposed on importing pathways. MPI periodically reviews all 4 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries import health standards, related documents and other standards so that the legal 
requirements are clear, and information is consistently presented and as easy as 
possible to understand. 
2 Proposed amendments to the standard 
2.1 Regulatory changes to the standard 
 
 MPI proposes the following changes. 
 MPI will define small seed lots of capsicum, eggplant, tomato and corn species as 
lots of 15,000 seeds or less. 
 MPI will add the option for small lots to be tested as a composite sample for the 
presence of quarantine pests to the specific requirements for Capsicum , Solanum (for 
Solanum melongena  only), Solanum lycopersicum  and Zea. 
 MPI will require importers who test small seed lots as composite samples on arrival 
in New Zealand to provide an importer declaration confirming the place of 
production or production site of the small lots in their consignment. 
 MPI will add a new schedule for Raphanus sativus  to the standard, with a 
requirement for a phytosanitary certificate. We will update the Plants Biosecurity 
Index (PBI) to reflect this.  
 MPI will add Matthiola incana  and Cyperus papyrus  to the list of approved species 
for import as pelleted seed, found in Appendix 4 to the standard. 
 MPI will add the following seed testing option for pests with specific requirements to 
the Phaseolus  and Pisum schedules: 
“officially tested, on a representative sample of a minimum of [insert relevant sample 
size]1 seeds officially drawn according to the ISTA or AOSA sampling 
methodology, using an NPPO-approved methodology, and found free from [insert 
pests with specific requirements]”. 
 MPI will remove measures for the following fungal pests, along with specific 
requirements relating to these pests: Peronosclerospora sorghi  and Sclerospora 
graminicola  from the Panicum schedule, Rhizopus maydis  and Phaeocytostroma 
ambiguum  from the Zea schedule and Cercospora loti  from the Lotus schedule. 
2.2 Non-regulatory changes to the standard 
 
 MPI proposes including the following guidance in the specific requirements for 
Capsicum , Solanum and Solanum lycopersicum  on the calculation of sample size from 
each lot to form a composite sample for testing: 
The sample size from each lot forming the composite sample should be calculated 
as follows:  
a) The proportion of each lot in the total consignment (seed number) is calculated 
using the following equation:  
𝑃𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑡𝑜𝑡𝑎𝑙 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡 𝑠𝑖𝑧𝑒 = ே௢.  ௢௙ ௦௘௘ௗ ௜௡ ௘௔௖௛ ௟௢௧
்௢௧௔௟ ௡௨௠௕௘௥  ௢௙ ௦௘௘ௗ௦ ௜௡ ௖௢௡௦௜௚௡௠௘௡௧  
 
1 See Table 3 for sample sizes  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  5 b) Calculate the sample size for each lot (number of seeds) using a total composite 
sample size of 3,000 seeds:  
𝑆𝑎𝑚𝑝𝑙𝑒 𝑠𝑖𝑧𝑒 𝑜𝑓 𝑒𝑎𝑐ℎ 𝑙𝑖𝑛𝑒 = 3000 seeds  𝑥 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛  𝑜𝑓 𝑡𝑜𝑡𝑎𝑙 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡  𝑠𝑖𝑧𝑒  
c) Take the sum of the sample size for each lot to check that the total composite 
sample for the consignment is at least 3,000 seeds. 
 MPI proposes including the following guidance in the specific requirements for Zea 
on the calculation of sample size from each lot to form composite samples for testing: 
The sample size from each lot forming the composite samples should be calculated 
as follows:  
a) The proportion of each lot in the total consignment (seed number) is calculated 
using the following equation:  
𝑃𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑡𝑜𝑡𝑎𝑙 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡 𝑠𝑖𝑧𝑒 = ே௢.  ௢௙ ௦௘௘ௗ௦ ௜௡ ௘௔௖௛ ௟௢௧
்௢௧௔௟ ௡௨௠௕௘௥  ௢௙ ௦௘௘ௗ௦ ௜௡ ௖௢௡௦௜௚௡௠௘௡௧  
b) Calculate the sample size for each lot (number of seeds) using a total composite 
sample sizes of a) 3,000 seeds and b) 400 seeds:  
 
𝑆𝑎𝑚𝑝𝑙𝑒 𝑠𝑖𝑧𝑒 𝑜𝑓 𝑒𝑎𝑐ℎ 𝑙𝑖𝑛𝑒 = 3000 seeds  𝑥 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛  𝑜𝑓 𝑡𝑜𝑡𝑎𝑙 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡  𝑠𝑖𝑧𝑒  
𝑆𝑎𝑚𝑝𝑙𝑒 𝑠𝑖𝑧𝑒 𝑜𝑓 𝑒𝑎𝑐ℎ 𝑙𝑖𝑛𝑒 = 400 seeds 𝑥 𝑝𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛  𝑜𝑓 𝑡𝑜𝑡𝑎𝑙 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡  𝑠𝑖𝑧𝑒  
 
c) For the first composite sample, take the sum of the sample size for each lot to 
check that the total composite sample for the consignment is at least 3,000 seeds. 
For the second composite sample, take the sum of the sample size for each lot to 
check that the total composite sample for the consignment is at least 400 seeds.  
 
 The non-regulatory changes do not alter the intent of or the requirements within the 
standard. The inclusion of guidance is considered a minor amendment in accordance 
with section 24B(2) of the Act and, as such, do not require consultation under section 
23(2) of the Act. Please note that these minor amendments have only been included 
for clarity and transparency purposes, and they do not form part of the consultation. 
The inclusions in guidance as they will appear in the standard can be found in 
Appendix 7 of this risk management proposal. 
 This risk management proposal covers eight amendments. 
3 Proposed amendment 1: Changes to the testing 
requirements for Capsicum  (capsicum), Solanum melongena  
(eggplant), Solanum lycopersicum  (tomato) and Zea mays 
(corn) small seed lots 
3.1 Background 
 
 Access to imported vegetable seeds for sowing is critical to sustain and grow the 
vegetable seed industry within New Zealand. And access to imported vegetable seeds 
is needed to produce vegetables in New Zealand for domestic consumption and for 
export markets.  6 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries 
 In 2020, vegetable seeds were exported from New Zealand to 58 countries and earned 
NZ$112 million. Fresh and process vegetable exports earned $300 million and $424 
million. The domestic sales value of capsicum was $35 million, eggplant $12 million, 
tomato $128.5 million and sweetcorn $27.5 million. The export earnings from 
capsicums were $24.7 million (Plant & Food Research, 2020). 
 Fresh capsicum, eggplant, tomato and corn are commercially grown in New Zealand 
from imported seeds. These species are frequently imported as small lots (i.e., lots 
comprising relatively small numbers of seeds). At least half of all capsicum and 
tomato seed lots imported into New Zealand between 2015 and 2020 comprised 
15,000 seeds or less. At least a quarter of all corn seed lots imported into New Zealand 
between October 2020 and February 2022 comprised 15,000 seeds or less. These lots 
often contain high-value genetic material that is important for the development of 
New Zealand’s horticulture industry. Small lots may be breeder seeds, parental seed 
lines, seeds for commercial vegetable production or seeds for variety trial evaluation.  
a) Between October 2020 and February 2022, approximately 1,300 kg of 
capsicum seeds (288 lots), 673 kg of tomato seeds (465 lots), 96 kg of eggplant 
seeds (61 lots) and 240 t of corn seeds (691 lots) were imported into 
New Zealand. These species are frequently imported as small lots (i.e., lots 
comprising relatively small numbers of seeds). 
 Imported capsicum, eggplant, tomato  and corn seeds are required to meet the general 
phytosanitary requirements and the respective specific phytosanitary requirements for 
Capsicum , Solanum, Solanum lycopersicum and Zea in the standard. The specific 
phytosanitary requirements prescribe measures to manage risk from quarantine pests 
associated with these seeds (Table 1, Appendix 1).  
 The measures are: 
 sourcing seeds from a pest free area; or  
 sourcing seeds from a pest free place of production; or  
 testing a minimum of 3,000 seeds from each lot for virus and viroid pests2 and a 
minimum of 400 seeds from each lot for bacterial pests.  
 The standard requires these minimum numbers of seeds to be tested per lot regardless 
of the size of the lot in the consignment. The New Zealand Grain & Seed Trade 
Association (NZGSTA) made MPI aware that the requirement to test 3,000 seeds from 
capsicum, eggplant and tomato small seed lots is prohibitive in terms of the proportion 
of the lot that is destroyed for testing and the associated costs. NZGSTA asked MPI to 
develop alternative import requirements for small seed lots of these species.  A trading 
partner also asked MPI to establish an alternative testing procedure for small corn seed 
lots as this would facilitate trade of smaller quantities of material used for breeding 
and variety development.  
 Testing 3,000 seeds randomly sampled from a homogenous large3 lot provides 95% 
confidence to detect a 0.1% infestation of pests in the lot (Appendix 3, FAO, 2008). 
An alternative testing requirement for small lots should minimize the proportion of 
each lot that is sacrificed for testing but manage risk to the same extent. Hence, an 
 
2 For corn, testing a representative sample of a minimum of 2,000 seeds per lot is required for Maize dwarf mosaic virus  and Sugarcane 
mosaic virus . Testing a representative sample of a minimum of 3,000 seeds per lot is required for all the other quarantine virus and viroid 
pests associated with capsicum, eggplant, tomato and corn, as detailed in Appendix 1.  
3 ‘Large’ in this case is lots of > ~30,000 seeds, given a 0.1% level of detection.   
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  7 alternative measure would require fewer than 3,000 seeds to be tested per lot but still 
provide 95% confidence to detect a 0.1% infestation of pests in the lot.  
 MPI proposes defining small seed lots of capsicum, eggplant, tomato or corn as 
15,000 seeds or less. This threshold will allow importers to utilise the alternative 
import requirements as these species are frequently imported into New Zealand in lots 
of 15,000 seeds or less. This threshold also allows for sampling sizes to be taken that 
reflect the required sensitivity for pest detection. 
 An alternative sampling methodology for small lots could be based on clustering small 
samples of different lots for testing (FAO, 2017). The standard already provides the 
option for small seed lots of cucurbitaceous species to be tested as a composite sample 
for the presence of quarantine pests (MPI, 2016; MPI 2021a). MPI proposes adding 
the option for small seed lots of capsicum, eggplant, tomato and corn species to be 
tested as composite samples for the presence of quarantine pests. 
3.2 Rationale 
 
 It is practical for MPI to define ‘small lots’ as lots of 15,000 seeds or less, for the 
purpose of testing these species as composite samples.   
 Between 2015 and 2020, approximately 49% and 66% of imported capsicum and 
tomato seed lots comprised of 15,000 seeds or less. Approximately 44% of corn seed 
lots imported between October 2020 and February 2022 comprised of 15,000 seeds or 
less.4 15,000 seeds is near the median for the distribution of lot sizes of these species 
imported into New Zealand, so it is likely that many importers could utilise an 
alternative sampling and testing option based on this definition.   
 The New Zealand Grain & Seed Trade Association (NZGSTA) asked MPI to consider 
Solanum seed lots of <15,000 seeds ‘small’ (NZGSTA, 2020). 
 
 Testing composite samples, formed from multiple ‘small lots’ of the same species in a 
consignment for the presence of virus and viroid pests, and for the presence of 
bacterial pests respectively, provides the same level of assurance of pest freedom as 
testing each individual seed lot according to the requirements in the standard, as long 
as all lots of the species that form the composite sample were produced at the same 
place of production or production site. 
a) MPI uses statistically based methods to make inferences about the phytosanitary 
status of a consignment, to detect quarantine pests specified in the standard and 
verify compliance with phytosanitary requirements. 
i. Testing a representative sample size of a minimum of 3,000 seeds from a large 
lot, using a sensitive and specific test method5 provides 95% confidence to 
detect 0.1% infestation of quarantine pests in the lot. Testing a representative 
sample size of a minimum of 400 seeds from a large lot, using a sensitive and 
specific test method provides 95% confidence to detect 0.75% infestation of 
quarantine pests in the lot. (FAO, 2008).  
 
4 Approximately 44% of corn seed lots imported during this period were less than 5 kg (i.e., comprised <15,000 seeds per lot, assuming a kg 
of corn contains 3,000 seeds). 
5 MPI assumes close to 100% efficacy of detection when testing is done using sensitive and specific molecular or serological methods that 
are validated to detect 0.1% infestation of quarantine pests in the sample. The efficacy of detection is the probability that an inspection or test 
of an infested unit will detect a pest (FAO, 2008). 8 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries ii. MPI assumes a 0.1% infestation level for virus and viroids and a 0.75% 
infestation level for bacteria in a lot (Lane et al., 2018; MPI, 2021b).  
iii. Testing a 3000-seed composite sample for the presence of virus and viroid 
pests and a 400-seed composite sample for bacterial pests, formed by 
aggregating proportionate samples from small lots of the same species in a 
consignment can provide a similar level of confidence6 to detect these pests in 
the lots at the same infestation level (Appendix 2 and 3) (MPI, 2022b). 
b) Testing a composite sample is valid if all the lots that form the sample are 
relatively similar (i.e. of the same species and produced at the same place of 
production or production site7). 
i. The lots should have “homogeneity in factors such as: - origin - grower - 
packing facility - species, variety, or degree of maturity - exporter - area of 
production - regulated pests and their characteristics - treatment at origin - type 
of processing.” (FAO, 2017). If the lots have some of these factors in common, 
they are similar enough to combine in one sample. 
ii. MPI assumes that lots of the same species from the same place of production 
or production site will have a similar level of infection. Although different 
species have different susceptivity to infection, seeds from the same species 
and the same place of production or production site are expected to have a 
similar level of viruses or viroids. This is because the seeds are harvested from 
plants that are likely to have been exposed to the same pest and disease 
pressures during production.  
iii. The quality control measures that are typically employed in commercial 
production of small seed lots mean that the infection levels in lots of a species 
that are produced in the same place of production or production site are likely 
to be similar.  
i. Quality control in tomato seed production can include crop inspections 
during each production cycle by field supervisors and plant 
pathologists employed by the seed company, crop inspections by 
quarantine inspectors or plant pathologists affiliated with the national 
plant protection organisation (NPPO) and pre-export testing of seed 
lots by the seed company (IIGB, 2016).  
ii. Quality control in corn seed production can include field inspections 
for pests and diseases, weed control, application of pesticides and seed 
health testing of lots prior to export (MacRobert et al., 2014; Gowda et 
al., 2017). These measures are likely to be applied consistently across 
harvests at the same place of production or production site. 
 
c) Capsicum, eggplant and tomato seeds only need to be tested for viruses and/or viroids. 
Corn seeds need to be tested for viruses and bacteria (Appendix 1). For small lots of 
corn seeds in a consignment, one 3,000-seed composite sample will be required for 
virus testing and a second 400-seed composite sample will be required for bacteria 
 
6 Testing a 3,000-seed sample from a 15,000-seed lot provides 95.6% confidence to detect 0.1% infestation of pests in a lot. This sample size 
is considered appropriate as it is close enough to a sample size of 2,880 seeds, which provides 95% confidence to detect a 0.1% infestation of 
pests in a lot.  
7 A place of production is any premise or collection of fields operated as a single production or farming unit. A production site is part of a 
place of production that is managed as a separate unit for phytosanitary purposes (FAO, 2021).  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  9 testing. Virus and bacteria testing cannot be performed on the same 3,000-seed 
composite sample.  
i. For virus testing, the lab scientist grinds the seed sample, extracts nucleic acid 
from the sample, and then performs PCR or ELISA assays. For bacteria testing, 
the lab scientist first soaks the seeds in liquid, then plates serial dilutions of the 
extracts on selective media and then identifies suspect colonies of bacteria using 
morphological, chemical or molecular methods. The testing protocols can differ 
depending on the bacterial species. The nucleic acid extracted for virus and 
viroid testing cannot be used to test for bacteria. This is why 3,400 seeds need 
to be tested for small corn seed lots in a consignment. One composite sample of 
a minimum of 3,000 seeds must be proportionally aggregated from the small 
corn seed lots in the consignment and tested for viruses or viroids. A second 
composite sample of a minimum of 400 seeds must be proportionally aggregated 
from the same small corn seed lots in the consignment and tested for bacteria.   
 The proposed option aligns with the option in the standard for testing small lots of 
cucurbitaceous seed species as a composite sample for quarantine pests, if the lots that 
form the sample are of the same species and are produced in the same place of 
production or at the same production site. 
 MPI proposes that small lots can be tested as composite samples offshore prior to 
export or on-arrival in New Zealand. For small lots that are tested offshore, MPI gains 
an assurance from the exporting competent authority that the small lots tested as a 
composite sample offshore were all produced in the same place of production or 
production site. The standard requires that pre-export testing is endorsed by the 
exporting NPPO on the phytosanitary certificate. However, for small lots that are 
tested as composite samples on arrival in New Zealand, the phytosanitary certificate 
will not provide assurance that these lots were produced in the same place of 
production or production site.  
 MPI proposes that importers who choose to test small lots as composite samples on 
arrival in New Zealand must provide MPI with a signed importer declaration form that 
confirms the following information. 
a) Lot numbers for the small seed lots in the consignment,  
b) The name of the seed species in each lot 
c) The weight of each seed lot 
d) The number of seeds in each seed lot 
e) The specific small seed lots in the consignment to be tested on arrival as a 
composite sample 
f) The name of the place of production or production site of each small seed lot that 
is to be tested on arrival as a composite sample 
 This information will enable MPI to verify that the requirements of the standard are 
met and facilitate faster processing of these consignments at the New Zealand border. 
MPI may, from time to time, verify the information in these declarations with the 
exporting countries during audits of offshore pathways.  
 The proposed requirement for an importer declaration is included in the specific 
requirements for Capsicum , Solanum, Solanum lycopersicum , Cucumis, 
Cucurbitaceae and Zea. There is a template for the importer declaration form in 
Appendix 4 of this risk management proposal. The importer will have to sign the form 
and assume legal responsibility for the declaration. However, the details of the form 10 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries may be completed by the importer or the exporter, as sometimes it is the exporter who 
has this information. 
3.3 Feasibility of the proposed change to the standard 
 
 Sampling and testing of composite samples can be performed either offshore before 
export or onshore on arrival in New Zealand. MPI proposes including guidance in the 
standard on how capsicum, eggplant, tomato and corn small seed lots are to be 
sampled to form a composite sample. This guidance can be used by exporting NPPOs 
if testing occurs offshore and by MPI inspectors at the border if an importer opts to 
test on arrival in New Zealand. The guidance in the standard should ensure that the 
lots are sampled correctly for testing.  
 Sensitive and specific tests, such as PCR and ELISA, are available to detect 
quarantine pests in capsicum, eggplant, tomato and corn seeds. Laboratories use 
different seed subsampling rates (depending on the test method) to ensure the correct 
level of detection (0.1% or higher). These protocols are published, are validated as 
providing high efficacy for detecting quarantine pests and are used internationally for 
phytosanitary testing of seeds.  
 Testing can be performed offshore using methods approved by the NPPO of the 
exporting country or on arrival in New Zealand at an MPI-approved testing laboratory. 
A negative test result from a composite sample will mean all the small seed lots that 
formed that sample are eligible for clearance, if all the other requirements of the 
standard are met. However, if there is a positive result for a quarantine pest in the 
composite sample, none of the seed lots that formed that sample will be eligible for 
clearance. 
 The standard already provides the option for small seed lots of species that are eligible 
to import under the specific requirements for Cucumis and Cucurbitaceae  to be tested 
as composite samples. These requirements were introduced in the standard in January 
2017 and have worked well to manage the risks of entry of quarantine pests on these 
pathways while at the same time facilitating importation of small lots. The testing 
requirements for solanaceous small seed lots outlined in this proposal are similar to 
the existing testing requirements for cucurbitaceous small seed lots in the standard.  
4 Proposed amendment 2: Addition of specific import 
requirements for Raphanus sativus  with a requirement for a 
phytosanitary certificate 
4.1 Background  
 
 Raphanus sativus  (radish) seeds can currently be imported into New Zealand under the 
basic requirements of the standard. The quantity of radish seeds for sowing entering 
New Zealand has increased from 47,218 kg in 2010 to 136,135 kg in 2020, mainly 
imported from European countries such as Hungary, Italy, the Netherlands and 
Germany (QuanCargo). The counter-season multiplication of radish seeds from these 
countries is a rapidly developing industry in New Zealand, as shown by the increased 
export value of radish seed from NZ$21.4 million in 2010 to $40.6 million in 2020 
(Plant & Food Research, 2020).  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  11 
 Imported seeds for sowing can pose the risk of introducing contaminant seed into 
New Zealand. MPI maintains a schedule of regulated quarantine weed seeds for 
New Zealand that is incorporated by reference in the standard. All seeds for sowing 
imported into New Zealand must meet basic requirements of the standard. Under these 
basic requirements, quarantine weed seed contamination in consignments must not 
exceed a maximum pest limit of 0.01% at a 95% confidence level (see “Schedule of 
quarantine weed seeds”). Imported seed can also contain regulated pests such as 
regulated fungi that produce visual symptoms of disease on seeds. Under the basic 
requirements of the standard, an infestation of a visually detectable regulated pest in a 
consignment must not exceed the maximum pest limit of 0.5% at a 95% confidence 
level. 
 MPI inspects representative samples from imported seed consignments at the border to 
verify contamination does not exceed the maximum pest limit and that the basic 
requirements of the standard are met. This measure reduces the likelihood of 
quarantine weed seeds and regulated pests entering New Zealand on this pathway and 
then becoming established here to a very low level. 
 Under basic measures, a phytosanitary certificate is not mandatory for radish seed, so 
the exporting country’s national plant protection organisation (NPPO) (the equivalent 
of MPI in the exporting country) is not required to certify that the seeds meet 
New Zealand’s phytosanitary import requirements prior to export. In the past, basic 
measures have been sufficient to manage the risk from regulated pests entering and 
establishing on this pathway. 
 Interceptions of a wide range of regulated weed seeds and fungal pests in  Raphanus 
sativus consignments have increased in recent years, as shown in Table 1. This 
includes a wide range of fungal pathogens that MPI has identified as significant 
biosecurity risks to New Zealand. This data suggests that the likelihood of these 
contaminants entering New Zealand has increased and that the risk profile of the 
pathway has changed. 
 Table 1 also shows the increase in Ablution theophrasti (velvetleaf) contamination 
from 2018 to 2020. Velvetleaf is a regulated quarantine pest of serious concern for 
New Zealand. It proliferates quickly, does not respond to normal weed control 
methods and has the potential to cause severe economic damage by outcompeting crop 
species. A 2016 incursion of this pest into New Zealand demonstrated the cost and 
effort required to eradicate this pest (MPI, 7 January 2021). As radish seeds are 
primarily imported for multiplication, weed seeds such as velvetleaf that are imported 
incidentally have the potential to grow and become established in fields of this crop. 
This has export implications for New Zealand growers involved in counter-season 
multiplication, as many countries have strict requirements around the prevalence of 
weed seeds in imported seed consignments.  
 Given the nature of the risk from velvetleaf and regulated fungi, MPI proposes 
strengthening the way we manage risk on the pathway offshore to reduce the 
likelihood of these pests arriving in radish seed consignments at the border. 
 12 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Table 1. Velvetleaf seed and fungal pest contamination in Raphanus sativus  consignments from 1/1/2018–1/1/2020 
Year No. of radish 
consignments 
imported No. of radish 
lines imported No. of radish lines 
contaminated with 
velvetleaf No. of radish lines 
contaminated with 
regulated fungal 
pests 
2018 155 226 0 (0%) 10 (4.4%) 
2019 172 253 1 (0.39%) 12 (4.7%) 
2020 196 305 3 (0.98%) 65 (21.5%) 
2021 (to Nov 2021)  157 303 6 (2.0%) 87 (29%) 
Total 680 1087 10 (0.9%) 174 (16%) 
 
 MPI proposes requiring a phytosanitary certificate for consignments of Raphanus 
sativus imported into New Zealand. This phytosanitary certificate would be issued by 
the exporting country’s NPPO. It would certify that the consignment is free from 
quarantine pests and that it conforms with the current phytosanitary requirements in 
the standard. The phytosanitary certificate will be required to comply with the 
requirements of section 1.5.2 of the standard.  
4.2 Rationale 
 
 Adding a requirement for a phytosanitary certificate for Raphanus sativus seeds for 
sowing will help reduce fungal pathogens and weed seeds in consignments of this 
species. This has obvious biosecurity benefits, because less potentially harmful pests 
are arriving at the border, but also it benefits importers because it reduces the 
probability that a consignment will be contaminated and require destruction, 
reshipping or treatment.  
 The associated official inspection and certification required for the issuance of a 
phytosanitary certificate compliant with the standard will also manage the risk of 
contamination with these pests offshore. MPI aims to manage risk offshore as much as 
possible, and phytosanitary certification is one way that MPI gains assurance that 
appropriate risk management measures have taken place before the goods are 
exported. 
 ISPM 12 says, “Phytosanitary certificates are issued to attest that plants, plant 
products or other regulated articles meet the phytosanitary import requirements of 
importing countries and are in conformity with the certifying statement.” (FAO ISPM 
12, 2014) Phytosanitary certificates issued with seed being imported into New Zealand 
are required to be compliant with section 1.5.2 of the standard, including the standard 
wording certifying that inspection has occurred: 
“This is to certify that the plants, plant products or other regulated articles 
described herein have been inspected and/or tested according to appropriate 
official procedures and are considered to be free from the quarantine pests 
specified by the importing contracting party and to conform with the current 
phytosanitary requirements of the importing contracting party, including those 
for regulated non-quarantine pests.”  
 Visual inspection is an appropriate means of detecting pests such as weed seeds and 
fungi that cause visual symptoms of disease in seed consignments. As no testing is 
required for radish seeds, the past interceptions listed in Table 1 have been the result  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  13 of official inspection by MPI on the consignments’ arrival at the border. This confirms 
that visual inspection is a valid method for the detection of these pests. Exporting 
nations would likely use a similar inspection regime to certify compliance, including 
an ISTA, AOSA or other NPPO-approved sampling methodology to ensure that the 
sample inspected is statistically representative of the consignment. 
 Any official sampling and inspection method employed by an exporting NPPO would 
need to ensure that the MPL set by MPI for weed seeds (0.01%) and visually 
detectable pests (0.5%) at 95% confidence is not exceeded. Detection of regulated 
pests during the offshore inspection means no phytosanitary certificate can be issued 
until the consignment is made compliant with New Zealand regulations. If 
contamination is detected in on-arrival inspection of a consignment that has already 
been inspected offshore and certified, MPI can follow this up with the exporting 
country’s NPPO and work with them to prevent future contamination.  
 The additional measure of offshore inspection, combined with the existing on-arrival 
verification requirement, strengthens risk management on the pathway and reduces the 
risk to a level that is acceptable for New Zealand, while continuing to facilitate trade.  
4.3 Feasibility of the proposed change to the standard 
 
 The proposed requirement for a phytosanitary certificate to accompany radish seed 
consignments is feasible for importers. Many consignments of these seeds are already 
imported with phytosanitary certificates despite certificates not being a requirement 
(QuanCargo, 2022). Phytosanitary certificates are relatively inexpensive (MPI charges 
NZ$51.11 for an export ePhyto), and all the countries that export radish seeds are 
obligated to offer them under international trade rules. This approach is the least trade-
restrictive measure that MPI can offer, and this measure will still significantly reduce 
contamination. This measure is less restrictive than alternatives such as fungicides. 
 MPI will continue to monitor levels of seed contamination and may implement more 
restrictive measures if contamination continues. 
5 Proposed amendment 3: Addition of Matthiola incana  and 
Cyperus papyrus  to Appendix 4 of the standard (approved 
species for import as pelleted seed) 
5.1 Background 
 
 Pelleted seed for sowing is currently eligible for import under the requirements of 
section 1.9 of the standard. Only species listed in Appendix 4 of the standard can be 
imported as pelleted seed and a certain subset of species listed in 1.9(2) require testing 
on arrival or other specific measures. When pelleted seed requirements were added to 
the standard in 2019, Appendix 4 was based on species that had a history of import as 
pelleted seed. As part of the consultation for these new requirements, MPI indicated 
that it would assess adding new species to the list if this was requested, based on the 
outcome of a risk evaluation.  
 MPI has received requests from importers to add the ornamental flower species 
Matthiola incana  and Cyperus papyrus  to the approved pelleted seed species listed in 14 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Appendix 4 of the standard. Expanding the pelleted commodities eligible for import is 
in line with New Zealand’s international and domestic obligations to facilitate trade. 
 Other similar ornamental flower species currently eligible for import as pelleted seed 
do not have specific requirements. MPI inspectors may verify consignments to 
confirm that consignments of pelleted seed of any species are free from quarantine 
weed seeds.  
 MPI proposes adding  Matthiola incana  and Cyperus papyrus  to the approved pelleted 
seed species (listed in Appendix 4 of the standard). These species will not have any 
specific measures like those required for other species under section 1.9.  
5.2 Rationale 
 Allowing these species to be imported as pelleted seed aligns with MPI’s commitment 
to facilitate trade where the biosecurity of New Zealand is not compromised. Under 
the guidelines in the International Standards for Phytosanitary Measures (ISPMs), 
MPI may only implement measures on a commodity if there is a demonstrable risk to 
New Zealand (FAO ISPM 1, 2006 and FAO IPSM 12, 2014). 
 Contamination on the unpelleted seed pathway is a reasonable proxy for projected 
contamination on the pelleted seed pathway, especially for basic species like these 
where inspection, certification or treatment is not required pre-export. The table below 
shows the import histories of these species as unpelleted seed between 1/1/2018 and 
the 31/12/2022. 
Table 2: Number of unpelleted seed consignments imported (2018–2020) 
Species Year 
 2018 2019 2020 2021 Total 
Matthiola incana  53 43 55 77 228 
Cyperus papyrus  0 0 0 1 1 
 
 None of the Matthiola incana  consignments have quarantine weed seed or regulated 
pest interceptions, which implies a low level of risk on this import pathway which 
would likely extend to pelleted seed imports. Only one (uncontaminated) Cyperus 
papyrus consignment has been imported, so it is difficult to extrapolate the level of 
contamination on this pathway.  
 Ornamental seed pathways generally have stringent quality control measures for 
commercial reasons. Pesticides and insecticides are often applied during the growing 
season to control disease, using weedkiller to eliminate any weeds in the 
greenhouse. The seeds are then generally cleaned and sorted from contaminating 
material. In the pelleting process, the pelleting machine should be cleaned after each 
production run, and some seeds from each lot are kept for grow-out tests to check the 
purity and viability of the seeds. While the exact measures vary by exporter, the 
application of these commercial quality control measures help reduce the level of risk 
on these pathways (NZ Seed Industry Personal Communication, March 2022).   
 The 2020 risk management proposal for the pelleted seed pathway used data collected 
by MPI that assessed the risk profiles of imported seeds for sowing by several metrics, 
including country of export and seed species (MPI, 2020). Most ornamental species 
are in the lowest risk category for pelleted seed, having less than 2% contamination 
overall. Because Matthiola incana and Cyperus papyrus  seeds generally go through 
similar production processes and quality control measures, they have a similar risk  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  15 profile to other ornamental commodities, so MPI expects a low level of contamination 
(NZ Seed Industry Personal Communication, March 2022).  
 Pelleted ornamental seeds are likely to be cultivated in nurseries rather than open 
fields once imported into New Zealand. Commercial practices in nursery production 
involve measures such as roguing and monitoring of individual plants, which can help 
manage any residual risk once the seeds are in New Zealand, as it is likely that any 
contaminant weeds germinating will be detected and removed. 
 MPI can audit these pathways if consignments of pelleted seeds are contaminated or 
as a preventative measure on pelleted seed pathways that MPI considers high risk. As 
outlined by the guidance in section 1.9 of the standard, “ For pelleted seed lots of 
flowering plants and ornamental species listed in Appendix 4, MPI reserves the right 
to undertake validation audits to confirm that imported consignments are free from 
quarantine weed seeds. Audits may be conducted on a random basis and it will be 
conducted at an MPI approved facility at the expense of the importer. ” This gives MPI 
additional capability to monitor the performance of the pathway and make adjustments 
to the risk management options if required.   
 Testing pelleted seeds for purity is destructive. Given the low likelihood of 
contaminants entering on Matthiola incana and Cyperus papyrus  together with the 
risk mitigation that nursery cultivation practices provide, MPI has decided not to add 
specific measures for these pelleted species, but will conduct validation audits on this 
pathway if required.  
 The combination of the above factors gives MPI confidence that imports of  Matthiola 
incana and Cyperus papyrus  as pelleted seed will pose very little biosecurity risk to 
New Zealand while providing economic benefit.   
5.3 Feasibility of proposed change to the standard 
 It is feasible to allow these species to be imported under section 1.9 of the standard 
because the requirements in the section have been successful so far in facilitating trade 
for other ornamental commodities and have exposed New Zealand to negligible 
biosecurity risk. Given the lack of contamination on the unpelleted pathway to date, 
the quality control measures and supply chain inherent to ornamental seeds, it is likely 
that these species are comparable in terms of risk to other pelleted ornamental species. 
MPI analysed the risks of Matthiola incana  and Cyperus papyrus  and found no 
evidence that importing these species as pelleted seed will increase the biosecurity risk 
to New Zealand (MPI, 2020). MPI also concluded that specific measures are not 
needed.  
6 Proposed amendment 4: Addition of a seed testing option for 
pests with specific requirements on the Phaseolus  
and Pisum schedules  
6.1 Background 
 Phaseolus and Pisum species are currently eligible for import under the basic 
measures in section 1.4 of the standard, along with specific measures in sections 2.61 
and 2.64 of the standard (respectively). Currently, these schedules only have ‘pest-free 
area’ and ‘pest-free place of production’ options available for the pests in Table 3. The 
approved countries for each are: 16 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries 
 Phaseolus —Australia, Austria, Belgium, Canada, Denmark, Finland, France, 
Germany, Greece, Ireland, Italy, Luxembourg, the Netherlands, Portugal, Spain, 
Sweden, United Kingdom, United States of America 
 Pisum—Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Finland, 
France, Germany, Greece, Hungary, Ireland, Italy, Luxembourg, the Netherlands, 
Portugal, Spain, Sweden, Taiwan, United Kingdom, United States of America 
 The Phaseolus (bean) and Pisum (pea) species are a major component of New Zealand 
vegetable production. In 2020, processed pea exports reached NZ$115 million and 
domestic sales exceeded $25 million. Processed bean exports exceeded $32 million 
(Plant & Food Research, 2020). Growers’ ability to continue importing quality seed, 
especially new varieties with greater yields and more desirable characteristics, is 
important for the continued success of this industry. 
 Providing as many equivalent phytosanitary options as possible facilitates the trade of 
these commodities, particularly in cases where one or several measures are not 
available. Other schedules in the standard offer testing as an equivalent measure to a 
‘pest free area’ or ‘pest free place of production’ additional declaration. MPI 
commissioned technical advice on this subject for the import health standard Grain 
and Seeds for Consumption, Feed or Processing . This advice stated that commercial 
tests are widely available for these viruses (Appendix 5). 
 MPI proposes adding an offshore testing option for pests listed in Table 3 on the 
Phaseolus and Pisum schedules. This will facilitate trade with countries that cannot 
endorse a ‘pest-free area’ or ‘pest-free place of production’ on phytosanitary 
certificates.   
Table 3. Pests of Phaseolus  and Pisum requiring a ‘pest-free area’ or ‘pest-free place of 
production’ declaration 
Commodity  Pest  
Phaseolus Curtobacterium flaccumfaciens  pv. flaccumfaciens  
Bean common mosaic virus [blackeye cowpea mosaic strain]  
Broad bean mottle virus  
Cowpea severe mosaic virus  
Pea early-browning virus  
Peanut mottle virus  
Southern bean mosaic virus  
 
Pisum Broad bean mottle virus  
Broad bean stain virus  
Pea early-browning virus  
Peanut mottle virus  
Peanut stunt virus  
 
6.2 Rationale 
 
 MPI is aware that the current requirements for pests of Pisum and Phaseolus  species 
with specific requirements (listed in Table 3) are limited. Other schedules in the 
standard offer seed testing for most viral and bacterial pests that have specific 
requirements, but this option has not been included in the Pisum and Phaseolus  
schedules. MPI’s Plant Health and Environment Laboratory does not yet offer testing  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  17 for these pests on seeds, but the lab is in the process of validating tests for seed tissue 
at the time of writing.  
 MPI is proposing the option for importers to test Phaseolus and Pisum seed 
consignments offshore, prior to export to New Zealand, for the presence of the 
quarantine pests using an NPPO-approved testing method. An endorsement from the 
exporting national plant protection organisation (NPPO) that the pest has not been 
detected will need to be included on the phytosanitary certificate. 
 Seed testing is only an equivalent measure to the current ‘pest-free area’ or ‘pest-free 
place of production’ requirement if the test is validated on seed tissue and has a high 
level of sensitivity and specificity. Appendix 5 (summarised in Table 4) lists ‘generic’ 
(genus-specific) PCR tests, ‘specific’ (virus-specific) PCR tests and commercial 
ELISA test kits that could be applied to seed to test for regulated pests. This is not a 
comprehensive list, and the amendment to the standard will allow any NPPO-
approved method of seed testing if the NPPO is willing to certify this testing on the 
phytosanitary certificate. MPI is not currently aware of any testing methods for these 
pests that are currently validated on seeds, however it is possible an NPPO is aware of 
an unpublished method that they are confident is sufficiently sensitive. Appendix 5 
also includes minimum sample sizes to achieve 95 % probability that infestations of 
0.1% or 0.15% (dependent in the rate of seed transmission of the given virus) are 
detected based on the known level of seed transmission.  
 Seed testing is a measure that allows seeds produced in areas where a pest may be 
prevalent to be traded safely. Some countries have not implemented the ISPM 4 and 
10 measures that allow them to provide PFA or PFPP certification. Offshore testing 
will be limited to the list of approved countries listed in the background section as 
only the exporting countries can issue testing declarations on phytosanitary 
certificates.  
 The standard will specify that this option cannot be completed onshore, and an 
offshore laboratory will need to complete the test prior to phytosanitary certification 
and export.   
6.3 Feasibility of proposed change to the standard 
 The proposed testing options to manage the risk from the pests of Phaseolus  and 
Pisum with specific requirements (listed in Table 3) are feasible in principle as they 
provide an additional option for importers to meet the requirements of the standard. 
However, MPI is aware that at present no seed tissue validated tests for these pests 
have been published (excluding Curtobacterium flaccumfaciens  pv. flaccumfaciens ), 
however unpublished methods may exist which exporting NPPO’s are willing to 
certify. MPI intends to begin the test validation process soon and will offer onshore 
testing as an option on these pathways when this is complete.    
 Table 4 below provides a list of potential tests that an exporting NPPO could use, 
along with a required minimum sample size. The minimum sample size is based on 
the seed transmission rates of the respective pest (Appendix 5) . For viruses with a 
higher rate of seed transmission, MPI assumes that the level of infestation will be 
0.15% or higher in an infested lot. For viruses with lower rates of seed transmission, 
MPI assumes the level of infestation will be 0.1% or higher in an infested lot (Lane et 
al., 2018). The sample needs to provide 95% confidence that the pest is not present at 
0.1% or 0.15%, depending on the pest. Specific information on transmission rates and 
the suggested sample sizes is available in Appendix 5.  18 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Table 4: Tests available for viral and bacterial pests with specific requirements on the Phaseolus  
and Pisum schedules (information from Appendix 5, excluding Curtobacterium ) 
MPI accepts all tests in this table. This list is not exhaustive, and MPI may also accept other tests that 
are not in this table. 
Commodity Pest  PCR Number of 
Commercial 
ELISAs available Proposed 
minimum 
sample size  
Phaseolus Curtobacterium 
flaccumfaciens  pv. 
flaccumfaciens   Specific PCR8 1  4000 
seeds 
Bean common mosaic 
virus [blackeye cowpea 
mosaic strain]   Potyvirus generic 
RT-PCR 3  2,000 
seeds 
Broad bean mottle virus  Bromoviridae 
generic RT -PCR 3  3,000 
seeds 
Cowpea severe mosaic 
virus  Comovirus 
generic RT -PCR  2  3,000 
seeds 
Pea early-browning 
virus  Tobravirus 
generic RT -PCR 2  2,000 
seeds 
Peanut mottle virus  Potyvirus generic 
RT-PCR 
 Specific RT -PCR  1  2,000 
seeds 
Southern bean mosaic 
virus  Specific RT-
qPCR 2  2,000 
seeds 
  
Pisum Broad bean mottle virus  Bromoviridae 
generic RT -PCR 1  3,000 
seeds 
Broad bean stain virus  Comovirus 
generic RT-PCR  
 Specific RT -PCR 1  3,000 
seeds 
Pea early-browning 
virus  Tobravirus 
generic RT -PCR 2  2,000 
seeds 
Peanut mottle virus  Potyvirus generic 
RT-PCR 
 Specific RT -PCR  1  2,000 
seeds 
Peanut stunt virus  Bromoviridae 
generic RT-PCR 
 Specific RT -PCR 2  3,000 
seeds 
 
 The exporting NPPO needs to validate an available test as being able to reliably detect 
a pest infestation on seed tissue before certifying seed for export to New Zealand 
based on phytosanitary testing. The testing must be performed by an NPPO-approved 
laboratory. If seeds intended for export to New Zealand test positive for any of the 
quarantine viruses associated with either commodity, the exporting competent 
authority must not issue the phytosanitary certificate and the consignment not be 
exported.  MPI will accept an assurance from an NPPO of an exporting country on a 
 
8 This PCR was not included in the PHEL technical advice in Appendix 5 but is published in Tegli et al. (2002). For a more detailed 
scientific explanation of the other tests with references to the original papers, see Appendix 5.  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  19 phytosanitary certificate that the seeds have been tested according to the requirements 
of the standard and found free from quarantine pests.  
 Currently, risk from these pests is managed using ‘pest-free area’ and ‘pest-free place 
of production’ declarations on phytosanitary certificates. Testing for pest freedom 
provides an equivalent level of protection. 
7 Proposed amendment 5: Removal of measures and specific 
requirements for fungal pests  
7.1 Background 
 
a) Removal of measures for Peronosclerospora sorghi and Sclerospora graminicola on 
Panicum seed 
 Panicum seeds for sowing are eligible for import under the basic measures in section 
1.4 of the standard, along with specific measures in section 2.57. Under these 
requirements, imported Panicum seed must have an additional declaration on the 
phytosanitary certificate stating that the seed has come from either a ‘pest-free area’ or 
‘pest-free place of production’ that is free from the regulated species 
Peronosclerospora sorghi and Sclerospora graminicola . 
 MPI has recently completed a risk assessment of the Panicum pest list in the standard 
Grain and Seeds for Consumption, Feed or Processing  (GCFP.IHS), which shares 
these pests with the Seeds for Sowing . The technical advice indicated that there is no 
evidence of an association between Peronosclerospora sorghi and Sclerospora 
graminicola  and Panicum seed (Appendix 6).  
 MPI proposes removing the regulated pests  Peronosclerospora sorghi and 
Sclerospora graminicola  from section 2.57 of the standard, along with the specific 
requirement for a ‘pest-free area’ or ‘pest-free place of production’ declaration on the 
phytosanitary certificate.  
b) Removal of measures for Rhizopus maydis and Phaeocytostroma ambiguum on Zea 
seed 
 Zea seeds for sowing are eligible for import under the basic measures in section 1.4 of 
the standard, along with specific measures in section 2.86. The pest list for the Zea 
schedule includes Rhizopus maydis and Phaeocytostroma ambiguum , along with a 
requirement for either a ‘pest-free area’ declaration on the phytosanitary certificate for 
this pest, or the application of an approved treatment from MPI’s Approved 
Biosecurity Treatments (MPI-ABTRT) (MPI, 2022a).  
 Zea seed trade is economically important for New Zealand. Processed corn exports 
reached NZ$47.6 million in 2020, and combined fresh/processed corn had a domestic 
market value of $37.5 million (Plant & Food Research, 2020). Counter-season 
multiplication of Zea seed is also a developing industry in New Zealand. Maize/corn is 
also important to the dairy and livestock sectors as silage. Given that Zea is New 
Zealand’s 6th most valuable plant species by GDP, continued access to Zea seed is 
critical (MPI Technical Paper 2016/62, 2016).  
 Scientists generally consider Rhizopus oryzae  (Went & Prinsen Geerligs, 1895) , 
Rhizopus arrhizus (A. Fischer, 1892), Rhizopus japonicus (Vuillemin) and Rhizopus 
maydis (Bruderlein) to be synonyms (Zheng et al., 2007) (BiotaNZ, 2022). MPI 20 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries considers evidence that any of these synonyms are present in New Zealand as 
evidence that Rhizopus maydis  is present in New Zealand. 
 MPI has recently seen evidence that Rhizopus maydis and Phaeocytostroma 
ambiguum are in New Zealand (Morris et al., 2021; BiotaNZ, 2022). Past internal 
technical advice has noted that Rhizopus arrhizus  (a synonym of R. maydis ) needs to 
be removed from the unwanted organisms register and that Phaeocytostroma 
ambiguum , while currently regulated, should be reviewed.  
 MPI proposes removing the regulated pests  Rhizopus maydis and Phaeocytostroma 
ambiguum  from section 2.57 of the standard, along with the requirement for a ‘pest-
free area’ declaration on the phytosanitary certificate for these pests. The fungicide 
treatment requirement will remain to manage the risk from the remaining fungal pests 
on the schedule.  
c) Removal of measures for Cercospora loti on Lotus seed 
 Lotus seeds for sowing are eligible for import under the basic measures in section 1.4 
of the standard, along with specific measures in section 2.49. The specific 
requirements for this commodity include the requirement for one of the following 
additional declarations for the fungus Cercospora loti  to be on the phytosanitary 
certificate of any imported seed: 
 Produced in a crop that has been inspected during the growing season according 
to appropriate procedures and no Cercospora loti  was detected; or 
 Produced in an area where Cercospora loti  is not known to occur 
 Cercospora loti  is a fungal pathogen that was made ‘non-regulated’ (ONZPR) by MPI 
in 2012 based on evidence that it is present and widespread in New Zealand. The 
measures in the standard are no longer required now that the pest is not regulated. 
 MPI proposes removing this pest from the Lotus schedule (2.49) of the standard, along 
with the specific requirements (listed above) that relate to this pest. 
7.2 Rationale 
 
a) Removal of measures for Peronosclerospora sorghi and Sclerospora graminicola on 
Panicum seed 
 Evidence of association between a pest and a commodity is a key part of deciding 
whether MPI regulates a pest. ISPM 38: International Movement of Seeds  states, “In 
PRA for seeds as pathways, the ability of a pest to transfer to a suitable host and 
cause infestation needs specific consideration to identify pests that warrant 
regulation. ” (FAO, 2017) To regulate pests on the seeds for sowing pathway evidence 
of the pest being associated with the seed commodity, along with evidence of seed 
transmission, is needed to justify the application of specific measures. Evidence of 
association is required because without a viable entry pathway, a pest cannot enter and 
become established, and if it cannot do that, measures to manage risk are not justified. 
 In 2021, MPI reviewed the Panicum schedule of the import health standard Grain and 
Seeds for Consumption, Feed or Processing  and determined that Peronosclerospora 
sorghi and Sclerospora graminicola  are not associated with the Panicum species that 
are currently eligible for import into New Zealand (Appendix 6). This technical advice 
can be extrapolated to the seeds for sowing pathway because the commodity is 
virtually identical, although the end use differs. Specific measures for these pests on  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  21 the Panicum schedule are not justified because MPI has no evidence the fungi are 
associated with the commodity.  
b) Removal of measures for Rhizopus maydis and Phaeocytostroma ambiguum on Zea 
seed 
 For an organism to be a quarantine pest in New Zealand, there needs to be evidence 
that the organism is of potential economic importance and is not present in 
New Zealand (or present but not widespread) or is being officially controlled. When 
assessing whether measures are required to manage a pest, IPPC guidance states, “The 
pest should be absent from all or a defined part of the PRA area… If the pest is present 
but not widely distributed in the PRA area, it should be under official control or 
expected to be under official control in the near future.” (FAO, 2013)  
 Rhizopus maydis  is a synonym of Rhizopus arrhizus, which the New Zealand 
Organisms Register (NZOR) lists as present in New Zealand. MPI has no evidence 
that either of these fungi are under any official control measures in New Zealand. 
i. The New Zealand Organisms Register (NZOR) lists Rhizopus arrhizus  as present 
in New Zealand based on the record in the old Manaaki Whenua – Landcare 
Research database Ngā Harore o Aotearoa – New Zealand Fungi and Bacteria 
(NZFungi2). The new Manaaki Whenua – Landcare Research database Biota of 
New Zealand  lists Rhizopus arrhizus as present in New Zealand on the basis of 
Morris et al., 2021. 
ii. NZOR also lists Phaeocytostroma ambiguum  as present in New Zealand based on 
the record in NZFungi2. This database lists the most recent source of the biostatus 
of P. ambiguum  as Introduction to Fungi of New Zealand  (2004). NZFungi2 also 
lists a sample of this fungus isolated in the Bay of Plenty in 2004.  
 Because these fungi are already present in New Zealand and are not under official 
control, MPI cannot justify keeping them on the Zea schedule of the standard.  
c) Removal of measures for Cercospora loti on Lotus seed 
 MPI has made this pest non-regulated as it has been present in New Zealand since 
1988 and has never been officially controlled.  
i. The Biota of New Zealand  database (Manaaki Whenua - Landcare Research) lists 
three samples of this pest, all taken in 1988. These are from Whanganui, Auckland 
and Wellington, representing a wide distribution of this fungus across the North 
Island of New Zealand. 
ii. Introduction to New Zealand Fungi  (2004) also lists this species as present in 
New Zealand. 
 Because this fungus is widespread in New Zealand, is not regulated and is not under 
official control, MPI cannot justify keeping it on the Lotus schedule.   
7.3 Feasibility of proposed changes to the standard 
 
 MPI proposes removing Rhizopus maydis  and Phaeocytostroma ambiguum from the 
Zea schedule, Peronosclerospora sorghi and Sclerospora graminicola from the 
Panicum schedule and Cercospora loti from the Lotus schedule, along with any 
specific requirements. This will make things easier for importers and facilitate the 22 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries continued trade of these seeds. Removing these pests is in keeping with MPI’s 
commitment to maintaining up-to-date and scientifically justified regulations. 
   
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  23 8 References 
 
BiotaNZ (2022) Rhizopus arrhizus A. Fisch. 1892. Biota of New Zealand. Manaaki Whenua – 
Landcare Research; Lincoln, New Zealand. https://biotanz.landcareresearch.co.nz/scientific-
names/bf1a1a8f-0d97-48ea-a016-e49995ed6c90  Accessed 10 March 2022.  
FAO (1995) International Standard for Phytosanitary Measures (ISPM) No. 4.  Requirements 
for the establishment of pest free areas.  Secretariat of the International Plant Protection 
Convention, Food and Agricultural Organization of the United Nations; Rome, Italy.  
FAO (1999) International Standard for Phytosanitary Measures (ISPM) No. 10.  Requirements 
for the establishment of pest free places of production and pest free production sites.  
Secretariat of the International Plant Protection Convention, Food and Agricultural 
Organization of the United Nations; Rome, Italy.  
FAO (2006) International Standard for Phytosanitary Measures (ISPM) No. 1 . Adopted 
International Standards for Phytosanitary Measures . Secretariat of the International Plant 
Protection Convention, Food and Agricultural Organization of the United Nations; Rome, 
Italy.  
FAO (2008) International Standard for Phytosanitary Measures (ISPM) No. 31. 
Methodologies for sampling of consignments.  Secretariat of the International Plant Protection 
Convention, Food and Agricultural Organization of the United Nations; Rome, Italy.  
FAO (2013) International Standard for Phytosanitary Measures (ISPM) No. 11. Pest risk 
analysis for quarantine pests.  Secretariat of the International Plant Protection Convention, 
Food and Agricultural Organization of the United Nations; Rome, Italy.  
FAO (2014) International Standard for Phytosanitary Measures (ISPM) No. 12. Phytosanitary 
certificates.  Secretariat of the International Plant Protection Convention, Food and 
Agricultural Organization of the United Nations; Rome, Italy.  
FAO (2017) International Standard for Phytosanitary Measures (ISPM) No. 38. International 
movement of seeds.  Secretariat of the International Plant Protection Convention, Food and 
Agricultural Organization of the United Nations; Rome, Italy.  
FAO (2021) International Standard for Phytosanitary Measures (ISPM) No. 5. Glossary of 
phytosanitary terms. Secretariat of the International Plant Protection Convention, Food and 
Agricultural Organization of the United Nations; Rome, Italy.  
Gowda, M; Worku, M; Nair, SK; Palacios-Rojas, N; Huestis, G; Prasanna BM. (2017) 
Quality Assurance/ Quality Control (QA/QC) in maize breeding and seed production: Theory 
and Practice. CIMMYT: Nairobi.  
IIGB (2016) IIGB audit report 2015-2016: Effectiveness of biosecurity controls for imported 
of tomato and carrot seeds, 2015-16/04’. Australian Government Interim Inspector-General of 
Biosecurity. https://www.igb.gov.au/sites/default/files/documents/imported-seed.pdf . (PDF) 
Accessed 4 April 2022. 
Lamprecht, S C; Crous, P W; Groenewald, J Z; Tewoldemedhin, Y T; Walter, F O M (2011) 
Diaporthaceae  associated with root and crown rot of maize. IMA Fungus , 2: 13–24. 
Lane, S E; Richards, R S; McDonald, C; Robinson, A P (2018) Sample size calculations for 
phytosanitary testing of small lots of seed. Centre for Biosecurity Research Excellence; 
Melbourne, Australia. https://cebra.unimelb.edu.au/__data/assets/pdf_file/0008/2796290/Att-
A-report-1606A.pdf  (PDF) Accessed 4 April 2022. 24 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries MacRobert, J F; Setimela, P S; Gethi, J; Worku, M (2014) Maize hybrid seed production 
manual. Mexico, D.F.:CIMMYT. 
MAF; MFAT; FSA (2009) Balance in Trade.  Ministry of Agriculture and Forestry, Ministry 
of Foreign Affairs and Trade, New Zealand, Food Safety Authority; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/12576-balance-in-trade  (PDF) 
McKenzie, H C E (2004) Introduction to Fungi of New Zealand . Fungal Diversity Press; 
Chiang Mai, Thailand. 
Ministry for Primary Industries (2022) Schedule of regulated (quarantine) weed seeds. 
Ministry for Primary Industries; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/7111  (PDF) 
Morris, A J; McKinney, W P; Rogers, K; Freeman, J T; Roberts, S A (2021) Antifungal 
susceptibility of clinical mould isolates in New Zealand, 2001–2021. Pathology , 53(5): 639–
644. 
MPI (2016) Risk Management Proposal. Import requirements for Cucurbitaceae seeds.  
Ministry for Primary Industries; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/11899  (PDF) 
MPI (2020) Risk management proposal: Pelleted Seeds.  Ministry for Primary Industries; 
Wellington, NZ. https://www.mpi.govt.nz/dmsdocument/39620-Risk-Management-Proposal-
Proposed-amendments-to-the-IHS-155.02.05-Seeds-for-sowing  (PDF) Accessed 21 April 
2022. 
MPI (2021a) Risk Management Proposal. Measures for Melon necrotic spot virus on 
Cucumis melo (melon), Cucumis sativus (cucumber) and Citrullus lanatus (watermelon). 
Ministry for Primary Industries; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/44818  (PDF) 
MPI (2021b) Risk Management Proposal. Amendment to the testing requirements for Pepino 
mosaic virus in the specific requirements for tomato (Solanum lycopersicum) in import health 
standard: Seeds for Sowing (155.02.05).  Ministry for Primary Industries; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/48232  (PDF) 
MPI (2022a) Approved Biosecurity Treatments . Ministry for Primary Industries; Wellington, 
NZ. https://www.mpi.govt.nz/dmsdocument/1555  (PDF) 
MPI (2022b) Technical advice on sampling of imported seed consignments. Ministry for 
Primary Industries; Wellington, NZ. 
MPI (July 2016) MPI Technical Paper 2016/62: How valuable is that plant species? 
Application of a method for enumerating the contribution of selected plant species to New 
Zealand's GDP . Ministry for Primary Industries; Wellington, NZ. How valuable is that plant 
species? Application of a method for enumerating the contribution of selected plant species to 
New Zealand's GDP (mpi.govt.nz)  (PDF). Accessed 23rd May 2022.   
MPI (7 January 2021) Velvetleaf weed management. Ministry for Primary Industries; 
Wellington, NZ. https://www.mpi.govt.nz/biosecurity/long-term-biosecurity-management-
programmes/velvetleaf/ . Accessed 16 March 2022. 
NZGSTA (2020) Discussion paper on small seed lots. New Zealand Grain & Seed Trade 
Association; Christchurch, NZ. 
NZOR (2022) Rhizopus arrhizus A. Fisch. The New Zealand Organisms Register . 
https://www.nzor.org.nz/names/63f8aab4-eaa4-4744-b332-9e7105491244  Accessed 5 March 
2022.   
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  25 ONZPR (2022) Rhizopus maydis. Official New Zealand Pest Register . Ministry for Primary 
Industries; Wellington, NZ. 
Plant & Food Research (2020) Fresh Facts  Fresh Facts: New Zealand Horticulture.  
The New Zealand Institute for Plant and Food Research Ltd; Auckland, NZ. 
https://www.freshfacts.co.nz/files/freshfacts-2020.pdf  (PDF) Accessed 15 March 2022. 
QuanCargo (2022) QuanCargo (internal database). Accessed 8 March 2022. 
Tegli, S; Sereni, A; Surico, G (2002) PCR-based assay for the detection of Curtobacterium 
flaccumfacie ns pv. flaccumfaciens  in bean seeds. Letters in Applied Microbiology , 35(4): 
331–337. https://sfamjournals.onlinelibrary.wiley.com/doi/epdf/10.1046/j.1472-
765X.2002.01187.x 
Zheng, R Y; Chen, G Q; Huang, H; Liu, X Y (2007) A monograph of  Rhizopus . Sydowia, 
59(2): 273–372. 
  26 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Appendices 
Appendix 1: Species, pests and measures 
Table 1: Capsicum, eggplant, tomato and corn species that are currently eligible for import, their 
associated quarantine pests and the risk management measures for these pests in the standard 
Commodity 
(IHS 
schedule) Species Quarantine pests Measures for quarantine pests 
Capsicum 
(Capsicum) Capsicum annuum 
Capsicum baccatum 
Capsicum cardenasii 
Capsicum chinense 
Capsicum eximium 
Capsicum frutescens 
Capsicum 
microcarpum 
Capsicum pendulum 
Capsicum pubescens Pepper chat fruit viroid 
Potato spindle tuber 
viroid 
Tomato brown rugose 
fruit virus 
Tomato mottle mosaic 
virus Seeds are produced in a pest-
free area;  
OR 
Seeds are produced in a pest-
free place of production;  
OR 
Seeds have been officially 
tested, on a representative 
sample of a minimum of 3,000 
seeds, and found to be free from 
quarantine pests. 
 
Eggplant 
(Solanum*) Solanum melongena Potato spindle tuber 
viroid Seeds are produced in a pest-
free area;  
OR 
Seeds are produced in a pest-
free place of production;  
OR 
Seeds have been officially 
tested, on a representative 
sample and found to be free 
from quarantine pests. 
 
Tomato 
(Solanum 
lycopersicum ) Solanum lycopersicum 
Solanum lycopersicum 
× Solanum 
habrochaites Columnea latent viroid 
Pepino mosaic virus 
Potato spindle tuber 
viroid 
Tomato chlorotic dwarf 
viroid 
Tomato planta macho 
viroid 
Tomato apical stunt 
viroid 
Tomato mottle mosaic 
virus 
Tomato brown rugose 
fruit virus Seeds are produced in a pest-
free area;  
OR 
Seeds are produced in a pest-
free place of production;  
OR 
Seeds have been officially 
tested, on a representative 
sample of a minimum of 3,000 
seeds and found to be free from 
quarantine pests. 
 
Corn  
(Zea mays) Zea mays 
Zea japonica 
Zea gracillima Viruses: 
High plains virus 
Maize dwarf mosaic 
virus 
Maize chlorotic mottle 
virus For viruses: Seeds are produced 
in a pest-free area;  
OR 
Seeds are produced in a pest-
free place of production (only for  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  27 Sugarcane mosaic 
virus 
 
Bacteria: Acidovorax 
avenae subsp avenae, 
Clavibacter 
michiganensis subsp. 
nebraskenis, Pantoea 
stewartii 
 
Fungi: 
Botryosphaeria zeae, 
Cochliobolus 
pallescens, 
Cochliobolus 
tuberculatus, 
Claviceps gigantea, 
Gloeocercospora 
sorghi, 
Ustilago maydis, 
Peronosclerospora 
heteropogoni, 
P. maydis, 
P. philippinensis, 
P. sacchari, P. sorghi, 
Phaeocytostroma 
ambiguum, 
Sclerophthora rayssiae 
var. zeae, Rhizopus 
maydis, Stenocarpella 
macrospora, 
Cephalosporium 
maydis High plains virus  and Maize 
dwarf mosaic virus ) 
OR 
Seeds have been officially 
tested, on a representative 
sample of a minimum of 2,000 
seeds (for Maize dwarf mosaic 
virus and Sugarcane mosaic 
virus) and 3,000 seeds (for High 
plains virus  and Maize chlorotic 
mottle virus ) and found to be free 
from quarantine pests. 
 
For bacteria: Seeds are 
produced in a pest-free area;  
OR 
Seeds are produced in a pest-
free place of production 
OR 
Seeds have been officially 
tested, on a representative 
sample and found free from the 
regulated bacteria 
 
For fungi: Seeds are produced in 
a pest-free area;  
OR 
Seeds are treated with one of 
the fungicide combinations in 
MPI’s Approved Biosecurity 
Treatments . 
Note: The proposed requirements for small seed lots only apply to Solanum melongena  (eggplant) that is eligible 
to import under the specific requirements for Solanum in the standard. The proposed requirements do not apply 
to the other non-vegetable species that are eligible to import under the specific requirements for Solanum, 
namely, Brugmansia arborea , Brugmansia sanguinea , Brugmansia sauveolens , Brugmansia versicolor , 
Brugmansia × candida, Brugmansia × cubensis, Physalis peruviana  and Solanum jasminoides . 
Note: Countries that MPI recognises endorsing “pest-free area” as an additional declaration for Sugarcane 
mosaic virus  are Australia, Austria, Canada, Finland, France, Germany, Greece, Hungary, Japan, the 
Netherlands, Norway, South Africa, Sweden, Switzerland, the United Kingdom and the United States of 
America. 
  28 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
Appendix 2: Technical advice on sampling of imported seed consignments  
 
 
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  29  
  
30 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Appendix 3: Example calculation of composite sample size  
 
Below is an example calculation of composite sample size, using the tool for determining 
sample size for any consignment size and pest infestation tolerance level provided in the 
technical advice. 
 
Description of the consignment 
A consignment contains 10 seed lots of Capsicum annuum (capsicum), 11 lots of Solanum 
lycopersicum  (tomato) and 4 lots of Solanum melongena  (eggplant) (Table 2). The 10 
capsicum seed lots are identified individually by their lot numbers A01 – JO1. The 11 tomato 
seed lots are identified individually by their lot numbers K01 – U01. The 4 eggplant seed lots 
are identified individually by their lot numbers V01 – Y01. Lots of each species were 
produced at the same place of production. 
 
The 10 capsicum lots in the consignment range between 0.0009 kg and 0.125 kg in weight. 
Assuming a 1,000-seed weight of 9g for capsicum, the numbers of seeds per lot range 
between 100 and 13,889 seeds.  
 
The 11 tomato seed lots in the consignment range between 0.001 kg and 0.06 kg in weight. 
Assuming a 1,000-seed weight of 4 g for tomato, the numbers of seeds per lot range between 
250 and 15,000 seeds. 
 
The 4 eggplant lots in the consignment range between 0.039 kg and 0.078 kg in weight. 
Assuming a 1,000-seed weight of 5.2 g for eggplant, the numbers of seeds per lot range 
between 7,500 and 15,000 seeds. 
 
Table 2: Calculation of sample size per capsicum, tomato and eggplant small seed lot to 
be drawn to form a composite sample 
 
Lot 
number Species Size of 
the lot 
(kg) 1,000-
seed 
weight 
(g) Number 
of seeds 
in the lot Proportion of 
each lot of 
each species 
in the 
consignment  Sample size per 
lot pooled to 
form a 
composite 
sample 
A01 Capsicum annuum  0.01 9 1,111 0.024 73 
B01 Capsicum annuum  0.015 9 1,667 0.037 110 
C01 Capsicum annuum  0.022 9 2,444 0.054 161 
D01 Capsicum annuum  0.005 9 556 0.012 37 
E01 Capsicum annuum  0.045 9 5,000 0.110 329 
F01 Capsicum annuum  0.085 9 9,444 0.207 621 
G01 Capsicum annuum 0.0995 9 11,056 0.242 727 
H01 Capsicum annuum  0.125 9 13,889 0.305 914 
I01 Capsicum annuum  0.003 9 333 0.007 22 
J01 Capsicum annuum  0.0009 9 100 0.002 7 
K01 Solanum lycopersicum  0.0025 4 625 0.009 27 
L01 Solanum lycopersicum  0.0145 4 3,625 0.052 156  
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  31 M01 Solanum lycopersicum  0.02 4 5,000 0.072 216 
N01 Solanum lycopersicum  0.056 4 14,000 0.201 604 
O01 Solanum lycopersicum  0.06 4 15,000 0.216 647 
P01 Solanum lycopersicum  0.032 4 8,000 0.115 345 
Q01 Solanum lycopersicum  0.002 4 500 0.007 22 
R01 Solanum lycopersicum  0.001 4 250 0.004 11 
S01 Solanum lycopersicum  0.015 4 3,750 0.054 162 
T01 Solanum lycopersicum  0.025 4 6,250 0.090 270 
U01 Solanum lycopersicum  0.05 4 12,500 0.180 540 
V01 Solanum melongena  0.039 5.2 7,500 0.184 552 
W01 Solanum melongena  0.04 5.2 7,692 0.189 566 
X01 Solanum melongena  0.055 5.2 10,577 0.259 778 
Y01 Solanum melongena  0.078 5.2 15,000 0.368 1104 
 
Eligibility to test composite samples 
Each lot of each species contains less than 15,000 seeds, therefore are all considered to be 
small lots under the proposed definition for small lots in this risk management proposal. For 
each species, a composite sample of a minimum of 3,000 seeds, formed by aggregating 
proportionate samples from each lot may be tested for the presence of quarantine pests. The 
size of the sample from each lot forming the composite sample must be proportionate to the 
size of the lot within the lots of that species in the consignment. 
 
Determining composite sample size for testing  
The tool provided in the MPI technical advice in Appendix 2 was used to determine the size 
of the composite sample to be tested for eligible small seed lots of capsicum, tomato and 
eggplant in the consignment. The tool was used to determine the sample size required to 
achieve 95% confidence to detect a 0.1% infestation of pests for each species in the 
consignment.  
 
For the capsicum small seed lots in the consignment (A01-J01): 
 In the calculator, the field for the input variable ‘Size of Lot or Consignment (CW) 
(kg)’ was populated with ‘0.41’ kg, which was the sum of the sizes of the capsicum 
small seed lots A01 – J01 in table 2. 
 The field for the input variable ‘weight of 1,000 seeds (SW) (g)’ was assigned the 
value 9 g, which is the 1,000-seed weight for capsicum.  
 The field for the input variable ‘pest infestation tolerance (p) (%)’ was populated with 
‘0.1%’.  
 The field for the input variable ‘sensitivity level or level of confidence (S)%’ was 
populated with ‘95%’. 
 The field for the input variable ‘acceptance level (AL) (whole number)’ was ‘zero’. 
 The field for ‘sensitivity of the diagnostic test (TS) %’ was set at 99%. 
 
The output of the calculator indicated in the figure 1 below, in the field titled ‘number of 
seeds in sample size (combination) (n)’ is 2,916 seeds . Testing a minimum of 3,000 seeds as a 
composite sample will provide the assurance that less than 0.1% of the capsicum seed lots 32 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries from which the composite sample is formed are infested with quarantine pests, with 95% 
confidence. 
 
Figure 1: Calculation of total composite sample size for testing for capsicum small seed lots in 
the consignment (A01 – J01) 
 
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  33 Figure 2: The effect of sample size on confidence level for composite sample for capsicum small 
seed lots in this consignment (A01-J01)  
 
 
For the tomato small seed lots in the consignment (K01-U01): 
 In the calculator, the field for the input variable ‘Size of Lot or Consignment (CW) 
(kg)’ was populated with ‘0.278’ kg, which was the sum of the sizes of the tomato 
small seed lots K01 – U01 in Table 2. 
 The field for the input variable ‘weight of 1,000 seeds (SW) (g)’ was assigned the 
value 4 g, which is the 1,000-seed weight for tomato. 
 The field for the input variable ‘pest infestation tolerance (p) (%)’ was populated with 
‘0.1%’.  
 The field for the input variable ‘sensitivity level or level of confidence (S)%’ was 
populated with ‘95%’. 
 The field for the input variable ‘acceptance level (AL) (whole number)’ was ‘zero’. 
 The field for ‘sensitivity of the diagnostic test (TS) %’ was set at 99%. 
 
The output from the calculator (in Figure 3) in the field titled ‘number of seeds in sample size 
(combination) (n)’ is 2,919 seeds . Testing a minimum of 3,000 seeds as a composite sample 
will provide the assurance that less than 0.1% of the tomato seed lots from which the 
composite sample is formed are infested with quarantine pests, with 95% confidence. 
 
 
34 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Figure 3: Calculation of total composite sample size for testing for tomato small seed lots in the 
consignment (K01 – U01) 
  
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  35 Figure 4: Output of sample size on confidence level for composite sample for tomato small seed 
lots K01 – U01 in this consignment  
 
 
For the eggplant small seed lots in the consignment (V01-Y01) 
 In the calculator, the field for the input variable ‘Size of Lot or Consignment (CW) 
(kg)’ was populated with ‘0.212’ kg, which was the sum of the sizes of the eggplant 
small seed lots V01– Y01 in table 2. 
 The field for the input variable ‘weight of 1,000 seeds (SW) (g)’ was assigned the 
value 5.2 g, which is the 1,000-seed weight for capsicum.  
 The field for the input variable ‘pest infestation tolerance (p) (%)’ was populated with 
‘0.1%’.  
 The field for the input variable ‘sensitivity level or level of confidence (S)%’ was 
populated with ‘95%’. 
 The field for the input variable ‘acceptance level (AL) (whole number)’ was ‘zero’. 
 The field for ‘sensitivity of the diagnostic test (TS) %’ was set at 99%. 
The output of the calculator (in Figure 5) in the field titled ‘number of seeds in sample size 
(combination) (n)’ is 2,935 seeds . Testing a minimum of 3,000 seeds as a composite sample 
will provide the assurance that less than 0.1% of the eggplant seed lots from which the 
composite sample is formed are infested with quarantine pests, with 95% confidence. 
 
Figure 5: Calculation of total composite sample size to test for eggplant seed lots V01 – Y01 in 
the consignment  
 
36 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  37 Figure 6: Output of sample size on confidence level for composite sample from eggplant small 
seed lots V01 – Y01 in this consignment  
 
 
Forming the composite sample for testing 
 
To form a composite sample of 3,000 seeds, proportionate sampling must be carried out 
across all eligible small lots of capsicum, tomato and eggplant imported in the consignment. 
To do this, a sample of seeds must be drawn from each small seed lot of a specific species, 
within a consignment, adding up to 3,000 seeds. The size of the sample from each lot must be 
proportionate to the size of the imported lot within the consignment.  
 
The following equations were used to calculate and populate the last two columns in Table 1. 
 Proportion of each lot of each species within the consignment: 
𝑃𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑡𝑜𝑡𝑎𝑙 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡 𝑠𝑖𝑧𝑒 = 𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑠𝑒𝑒𝑑𝑠 𝑖𝑛 𝑒𝑎𝑐ℎ 𝑙𝑜𝑡 /
𝑇𝑜𝑡𝑎𝑙 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑠𝑒𝑒𝑑𝑠 𝑖𝑛 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡  
 
 Sample size per lot aggregated to form a composite sample of 3,000 seeds: 
𝑆𝑎𝑚𝑝𝑙𝑒 𝑠𝑖𝑧𝑒 𝑜𝑓 𝑒𝑎𝑐ℎ 𝑙𝑜𝑡 = 3000 𝑠𝑒𝑒𝑑𝑠∗𝑃𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑡𝑜𝑡𝑎𝑙 𝑐𝑜𝑛𝑠𝑖𝑔𝑛𝑚𝑒𝑛𝑡 𝑠𝑖𝑧𝑒  
 
  
38 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Appendix 4: Importer declaration template 
 
 
 
 
 
 
 
 
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  39 Appendix 5: Phaseolus /Pisum testing options technical advice 
 
 
 
 
 
40 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  41  
  
42 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  43   
44 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  45   
46 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  47   
48 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  49 Appendix 6: Technical advice on  Panicum  
 
50 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
 
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  51  
 
  
52 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  53  
  
54 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
 
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  55  
 
  
56 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  57  
58 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  59 
 
  60 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  61 
62 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries 
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  63  
64 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Appendix 7: Excerpts showing changes in the standard 
Part 2 Specific requirements for Capsicum in the standard  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  65  
  
66 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  67 Part 2 Specific requirements for Cucumis in the standard  
  
68 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  69 
70 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Part 2 Specific requirements for Cucurbitaceae  in the standard 
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  71  
 
 
 
  
72 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  73  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
74 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Part 2 Specific requirements for Lotus in the standard  
 
 
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  75 Part 2 Specific requirements for Phaseolus  in the standard  
  
76 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  77   
78 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  79  
Part 2 Specific requirements for Pisum in the standard  
 
 
 
  
80 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  81   
82 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Part 2 Specific requirements for Raphanus sativus  in the standard 
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  83 Part 2 Specific requirements for Solanum in the standard 
 
  
84 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  85 Part 2 Specific requirements for Solanum lycopersicum  in the standard 
86 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  87   
88 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries Part 2 Specific requirements for Zea in the standard  
 
 
 
 
 
 
  
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  89   
 
 
 
 
   
90 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
 
 
 
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  91     
92 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
   
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  93    
94 Risk Management Proposal: Amendments to Seeds for Sowing Ministry for Primary Industries  
  
 
Ministry for Primary Industries Risk Management Proposal: Amendments to Seeds for Sowing  95 Appendix 4 to the standard (approved list of pelleted seed species)