Risk Management Proposal:  
Amendment  of the pre-export  phytosanitary 
inspection requirements of the import 
health standards : 
152.02: Importation and Clearance of Fresh Fruit  
and Vegetables into New Zealand,  
Fresh Rambutan for Human Consumption , and  
Fresh Ginger ( Zingiber officinale and Z. zerumbet ) 
for Human Consumption . 
 
 
 
 
 
 
 
 
 
Prepared for  public consultation   
by Horticulture Imports  
Animal and Plant Health Directorate  
 
 
 
 
 
 
 
 
 
Sept ember  2023 
 
 
Disclaimer  
 
While every effort has been made to ensure the information in this publication is accurate, the  Ministry  for 
Primary Industries does not accept any responsibility or liability for error of fact, omission, interpretation or 
opinion that may be present, nor for the consequences of any decisions based on this information.  
 
This publication is also available on the Ministry for Primary Industries  website at  
http://www.mpi.govt.nz/news -and-resources/publications/   
 
 
© Crown Copyright – Ministry  for Primary Industries   
i Contents  Page 
 
Submissions  1 
1 General information  2 
1.1 Purpose  2 
1.2 Background  2 
1.3 Timing and consultation  2 
1.4 Background and context of consultation  2 
2 Proposed changes to the standards  3 
2.1 Regulatory changes to the standards  3 
2.2 Non-regulatory changes to the standards  4 
3 Rationale for the proposed changes to  the standard  5 
4 Feasibility of the proposed changes to the standard  6 
5 References  7  
Ministry for Primary Industries   Amendment  of the pre -export phytosanitary inspection requirements  • 1 Submissions  
The Ministry for Primary Industries (MPI) invites comment from interested parties on 
proposed amendments to three import health standards (IHSs) : 
• Importation and Clearance of Fresh Fruit and Vegetables into New Zealand  (152.02)  
• Fresh Rambutan f or Human Consumption  
• Fresh Ginger ( Zingiber officinale  and Z. zerumbet ) for Human Consumption  
 
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 proposed  changes to  phytosanitary inspection requirements  in 
the standard s. 
 
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 28 October 2023 . 
 
Feel free to include any  technical information  you have  that support s your submission. While 
we prefer email, if  you would like to send your submission by post, you can mail it  to: 
 
Horticulture Imports  
Animal and Plant Health  Directorate  
Biosecurity New Zealand  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Submissions received by  28 October 2023  will be considered during the development of the 
amended  standard s. Submissions received after the clos ing 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 infor mation being  
commercially sensitive or personal. Any decision to withhold information requested under the 
OIA is reviewable by the Ombudsman . 2 • Amendment of the pre -export phytosanitary inspection requirements  Ministry for Primary Industries  1 General information  
1.1 Purpose  
(1) The purpose of this document is to:  
• Outline  the proposed  changes to the phytosanitary inspection requirements that are 
carried out by an exporting national plant protection organisation  (NPPO)  for all 
countries trading with New  Zealand ;  
• Provide the rationale for the proposed amendments ;  
• Ask for  feedback on the  proposed standard amendments to phytosanitary inspection 
requirements ; and  
• Recognise that Peronosclerospora sorghi  is not a pest on Australian sweetcorn.  
1.2 Background   
(2) The standard s were  issued on 9 June  2017 (rambutan) , 20 December  2019 (ginger)  
and 24 July 2023  (fresh fruit and vegetables  152.02) . The standard s were  issued under 
section 24A of the Biosecurity Act 1993 and appl y to rambutan from Viet  Nam, 
ginger  that is imported  into New Zealand from foreign countries and territorie s, and 
many fresh fruit and vegetables from  many countr ies under IHS 152.02 . 
1.3 Timing and consultation  
(3) The proposed amendments to the import health standards for fresh fruit and vegetables  
(152.02 ), rambutan  and ginger were released for consultation on 20 September 2023  
and will remain open for consultation until 28 October 2023 . 
1.4 Background and context of consultation  
1.4.1 Pre-border phytosanitary measures  
(4) Pests that pose a relatively low risk to New  Zealand are categorised as re quiring basic 
measures. Basic measures are comprised of commercial production processes and 
pre-export phytosanitary inspection and certification.  
a. Commercial production  
i. MPI expects a ll fresh produce for export to New Zealand to be 
commercially produced in  accordance with recognised standard 
cultivation, pest management, harvest, and packaging activities.  
ii. All fresh produce for export to New Zealand must be of an export 
grade. Being of export grade minimises the likelihood of infested or 
infected fresh prod uce entering the export supply chain.  
b. Pre-export phytosanitary inspection and certification  
i. Pre-export phytosanitary inspection and certification by the NPPO of 
all commercially produced fresh produce for export to New Zealand is 
required.  
ii. Sample fruit are inspected using official procedures and at 10× 
magnification for  pests that like to hide ( cryptic  pests ) or small pests . 
Consistent with international practice, the inspected sample must be 
free from regulated pests.   
Ministry for Primary Industries   Amendment  of the pre -export phytosanitary inspection requirements  • 3 iii. If an inspector finds a live regulated pest in the lot, an appropriate 
measure must be applied (e.g., an approved treatment) , or the lot must 
be rejected for  export to New Zealand.  
c. Conditions and measures should follow the International Standards for 
Phytosanitary Measures  (ISPM)  unless the risk analysis justifies additional 
conditions.  
1.4.2 Biosecurity risk s associated with  sweetcorn ( Zea mays ) from Australia  
(5) We currently require targeted measures on fresh  sweetcorn from Australia  for three 
pests : sorghum downy mildew  (Peronosclerospora sorghi ), maize downy mildew  
(Peronosclerospora maydis ) and corn smut  (Ustilago maydis ). However, only maize 
downy mildew and corn smut are biosecurity risks on sweetcorn from Australia. 
Australia has been recognised as free from sorghum downy mildew since  2007 
(EPPO, 2007).  
(6) The biosecurity risks of the pests themselves have not changed. Maize downy mildew 
and corn smut still need to be managed on sweetcorn from Australia, and sorghum 
downy mildew still needs to be managed on produce from places where it is present.  
2 Proposed changes  to the standards  
2.1 Regulatory changes  to the standards  
2.1.1 Proposed changes to pre -export phytosanitary inspection  
(7) We are  proposing changing  the requirements for phytosanitary inspection in the  three 
standards : Importation and Clearance of Fresh Fruit and Vegetables into 
New Zealand (152.02) , Fresh  Rambutan  for Human Consumption , and Fresh Ging er 
for Human Consumption . 
2.1.2 IHS 152.02: Importation and Clearance of Fresh Fruit and Vegetables into New Zealand  
(8) We propose combining s ections 2.3 and 2.4 of the import health standard for fresh 
fruit and vegetables and updating the  section  to clarify what the  NPPO is required to 
do during pre -export phytosanitary inspection , in alignment with ISPM  31. 
Methodologies for sampling of consignments  (this change is highlighted in the draft 
standard for your convenience) . 
a. These proposed  changes ref lect the expectation MPI already has for pre -export 
phytosanitary inspections. Our trading partners are aware of th ese requirement s 
and are already meeting them. Th is proposed  change aims to align  the standard  
with ISPM  31. Methodologies for sampling of co nsignments . 
b. MPI audits NPPOs based on import health standards, bilateral arrangements, 
and relevant ISPMs, including ISPM 31.  
2.1.3 Fresh  Rambutan  for Human Consumption  and Fresh Ginger  for Human Consumption  
(9) In section 3.1 ( “Phytosanitary inspection ”) of the standards for fresh rambutan and 
fresh ginger, currently the NPPO of the exporting country must “sample each 
homogeneous grower  lot of fresh [ rambutan or ginger ].” We are proposing to change 4 • Amendment of the pre -export phytosanitary inspection requirements  Ministry for Primary Industries  this to “sample each homogeneous lot of fresh [ rambutan or g inger ]” in alignment  
with ISPM 31. Methodologies for sampling of consignments . 
a. A lot may be considered homogenous after the final pest mitigation measure 
before certification. This can include packhouse processing or a specific 
treatment ( e.g., vapour heat  treatment, etc.).  
b. We expect the NPPO to determine  and manage the criteria used to distinguish 
homogenous lots,  as for all our other import health standards ( except for the 
citrus standards, which are being amended separately ). 
(10) These proposed  changes provide the same level of confidence that the consignment 
does not contain regulated pests.  
2.1.4 Proposed changes  to the schedule for sweetcorn from Australia the standard for fresh 
fruit and vegetables  
(11) We propose removing the requirement for an additi onal declaration for sorghum 
downy mildew ( Peronosclerospora  sorghi ) for Australian fresh sweetcorn.  
(12) We are not proposing  any changes to our requirements for Peronosclerospora maydis  
or Ustilago  maydis , and we will still require an additional declaration for fresh 
sweetcorn from Australia for  these pests . 
2.2 Non-regulatory changes  to the standards  
(13) MPI has proposed  some changes to format of the standard s to align with MPI’s current 
formatting and to ensure that the legal requirements are clear, consistently pr esented, 
and as easy as possible to understand.  
(14) These include:  
a. Updating MPI databases and hyperlinks  
i. ePest has been replaced by the database Product Import and Export 
Requirements  (PIER)  
ii. The Biosecurity Organisms Register for Imported Commodities 
(BORIC)  has been replaced by the Official New Zealand Pest Register  
(ONZPR)  
b. Adding reference to the guidance document: Information on Clearance of 
Fresh Fruit and Vegetables for Human Consumption  
c. Adding definitions to help readers understand the standards  (highligh ted in the 
draft 152.02 standard for your convenience)  
(15) None of these proposed changes alter the requirements in the standard or the intent of 
the requirements. MPI considers these would be minor changes in accordance with 
section 24B(2) of the Biosecurity Act and, as such, do not require consultation under 
section 23(3)  of the Act.  
(16) These proposed  minor changes are mentioned here for clarity and transparency. They 
are not part of the consultation.   
Ministry for Primary Industries   Amendment  of the pre -export phytosanitary inspection requirements  • 5 3 Rationale for the proposed change s to the standard  
(17) In all our standards for fresh fruit and vegetables, we require the produce  exported to 
New  Zealand to have a pre -export phytosanitary inspection.  Inspection and 
certification by the exporting NPPO assures us that the fresh produce is  free from 
visually detectable regulated pests.  
3.1.1 IHS 152.02: Importation and Clearance of Fresh Fruit and Vegetables into New Zealand  
(18) Our standard for fresh fruit and vegetables  (section 2.3 and 2.4) does not clearly 
specify all the requirements for pre -export phytosanitary inspection and currently does 
not referen ce the ISPMs. The updated  section will clarify the inspection requirements 
for the exporting NPPO . 
(19) We propose  changing  the fresh fruit and vegetable standards to specify that the 
minimum sample size for inspection must be based on a 95% confidence level th at no 
more than 0.5% of the units in the lot are infested, as set out in the ISPM 31 . 
Methodologies for sampling of consignments . Homogeneity of a lot is required to 
ensure the statistical relevance of the sampling methods in ISPM 31. In the context of 
phytosanitary sample inspection and certification , a homogenous lot (for phytosanitary 
inspection)  is defined as:  
“A lot to be sampled should be a number of units of a single commodity  
identifiable by its 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, or  
- type of processing.  
The criteria used by the NPPO to distinguish lots should be consistently applie d 
for similar consignments.”  
Note that lot homogeneity can be identified by the grower but can also be defined by a 
number of other factors.  
3.1.2 Standards for rambutan and ginger  
(20) We require  phytosanitary inspection to be conducted specifically on a homogenous 
grower lot in several  of our  standards . However, we did not detail our  rationale  for 
requiring  grower lot inspection in consultation documents , and this requirement is not  
supported by risk assessment. In all our other standards for  fresh produce , samples for 
inspection should be from a homogenous lot , and we do not mention “grower lot”.  
a. MPI may prescribe the homogeneity factor for inspection ( such as  grower lot) 
in a standard when  the risk analysis justifies that  a greater level of confidence 
is necessary for phytosanitary assurance.   
i. This was not the case with rambutan.   
ii. The risk analysis for ginger recommended  that the exporting country 
must “sample each homogeneous grower lot for fresh ginger.”  6 • Amendment of the pre -export phytosanitary inspection requirements  Ministry for Primary Industries  However, MPI has concluded that the evidence in the risk analysis did 
not justify this condition.  
b. Article 3 of the SPS Agreement  states that NPPOs should “ harmonize san itary 
and phytosanitary measures on as wide a basis as possible , Members shall base 
their sanitary or phytosanitary measures on international standards, guidelines 
or recommendations, where they exist, except as otherwise provided for in this 
Agreement .” 
(21) The rationale for the requirement for homogenous grower lot inspection has been 
questioned by trading partners who contend that the requirement is impractical, 
unjustified , and that homogeneity across a lot can be achieved by factors other than by 
a grower lot in accordance with ISPM 31 . Methodologies for sampling of 
consignments . 
(22) Sampling  each lot in accordance with ISPM 23 . Guidelines for inspection  and 
ISPM  31. Methodologies for sampling of consignments  is sufficient to provide  the 
confidence that the consignment is free of visually detectable regulated pests, as is 
required for export  to New  Zealand.  
(23) If regulated pests are found in the homogenous lot during phytosanitary inspection, the 
appropriate action will be taken (rejecti on of the lot, treatment, resorting, etc.) to 
ensure the risk is mitigated and New  Zealand’s biosecurity is maintained.  
(24) The inconsistency in fresh produce standards creates uncertainty for MPI during audit s 
and assessing equivalence requests.  
3.1.3 Schedule for sweetcorn from Australia  in the standard for fresh fruit and vegetables  
(25) Sorghum downy mildew ( Peronosclerospora sorghi ) has erroneously been listed as a 
pest of sweetcorn from Australia for a number of years. It  was at one time thought to 
be in Australia , but this was a misidentification. The mildew has now been correctly 
identified as maize downy mildew  (P. maydis ) (Wang et al., 2000). Australia has been 
recognised as free from sorghum downy mildew  since 2007 (EPPO, 2007).  
(26) We recognise  Australia’s  country freedom  from sorghum downy mildew  and propose  
amending the standard  as part of this recognition . We already require measures for 
maize downy mildew, and we are not changing these measures . 
4 Feasibility of the proposed change s to the standard  
(27) Growers, exporters, and importers will not have to do anything differently.  
(28) The proposed changes  will give NPPOs flexibility to determine and manage 
homogeneity within their national phytosanitary certification systems . 
(29) The proposed changes  regarding phytosanitary inspection will ensure consistency in 
assessment of NPPO export systems across  our fresh produce import  pathways.   
Ministry for Primary Industries   Amendment  of the pre -export phytosanitary inspection requirements  • 7 5 References  
FAO (2005) International Standard for Phytosanitary Measures (ISPM) No. 23 . Guidelines  
for inspection.  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.  
MPI (2016 a) Import Risk Analysis: Fresh Rambutan from Vietnam.  Ministry for Primary Industries; 
Wellington,  New Zealand.  https://www.mpi.govt.nz/dmsdocument/14254 -Import -Risk-Analysis -
Fresh -Rambutan -from -Vietnam . Accessed  30 January 2023.  
MPI (2017) Import Health Standard: Fresh Rambutan for Human Consumption.  Ministry for Primary 
Industries; Wellington, New Zealand. https:/ /www.mpi.govt.nz/dmsdocument/18446 -Fresh -
Rambutan -for-Human -Consumption -Import -Health -Standard . Accessed 30 January 2023.  
MPI (2019a) Import Risk Analysis: Ginger  (Zingiber officinale , Zingiber zerumbet ) Fresh Produce . 
Ministry for Primary Industries; Wellington, New Zealand.  
https://mpi.govt.nz/dmsdocument/36837/direct . Accessed 30 January 2023 . 
MPI (2019 b) Import Health Standard: Fresh Ginger ( Zingiber officinale and Z. zerumbet ) for Human 
Consumption.  Ministry for Primary Industries; Wellington, New Zealand.  
https://www.mpi.govt.nz/dmsdocument/39284 -Fresh -Ginger -Zingiber -officinale -and-Z.-zerumbet -for-
Human -Consumption -Import -Health -Standard . Accessed 30 January 2023 .