Risk Management Proposal:  
Amendments to the  
Import Health Standard for Sea Containers 
from All Countries  
SEACO 
 
 
 
 
 
 
 
 
 
 
 
Prepared for public consultation  
by Invasive Species Team 
Animal and Plant Health Directorate 
 
 
 
 
 
 
 
 
May 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  
General information 2  
Purpose 2  
Background 2  
Timing and consultation 2  
Background and context of consultation 2  
Biosecurity risk associated with the sea container pathway 3  
Proposed changes to the standard 3  
Non-regulatory changes to the standard 3  
Transshipment requirements 3  
Clean on arrival 4  
Sea containers and their cargo from Italy 4  
Sensitive goods 5  
References 6   
Risk Management Proposal: Amendments to the Import Health Standard for Sea Containers from All Countries   1 Submissions 
The Ministry for Primary Industries (MPI) invites comment from interested parties on the 
amended import health standard Sea Containers from All Countries  (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 changes to the import health standard Sea 
Containers from all Countries . 
1. Inclusion of “clean on arrival” 
2. Transshipping through New Zealand 
3. Update of the quarantine declaration 
4. Requirements for Italy between 1 September and 30 April of every year 
5. Inclusion of sensitive goods as a 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 standards@mpi.govt.nz  by 10 June 2022 
 
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: 
 
Invasive Species Team 
Animal and Plant Health Directorate 
Biosecurity New Zealand  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Submissions received by 10 June 2022 will be considered during the development of 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.    
Risk Management Proposal: Amendments to the Import Health Standard for Sea Containers from All Countries   2 General information 
Purpose 
(1) The purpose of this document is to:  
 Outline the proposed amendments to the requirements for the standard; 
 Provide the rationale for the proposed standard amendments and how they manage 
risk; and 
 Ask for feedback on the proposed standard amendments to importing requirements. 
Background  
(2) The standard was issued and came into effect on 31 August 2020. The standard was 
issued under section 24A of the Biosecurity Act 1993 and applies to all sea containers 
that arrive in New Zealand from foreign countries and territories. 
Timing and consultation 
(3) The proposed amendments to the import health standard Sea Containers from All 
Countries  were released for consultation on 9 May 2022 . The consultation remains 
open until 10 June 2022 . 
Background and context of consultation 
International regulation of risk goods 
(4) “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)  
(5) “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)  
Domestic regulation of biosecurity risks associated with craft arrivals 
(6) 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 that effectively manage risks 
associated with importing 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 we impose on importing pathways, 
whether new or amended. MPI periodically reviews all import health standards, related 
documents and other standards so that the legal requirements are clear and so that 
information is consistently presented and as easy as possible to understand.  
Risk Management Proposal: Amendments to the Import Health Standard for Sea Containers from All Countries   3 Biosecurity risk associated with the sea container pathway 
 
(7) The biosecurity risks of sea containers entering New Zealand are largely to do with the 
possibility of organisms stowing away in them without people being aware. These can 
be insects, weed seeds or other plant material, or any other organism that New Zealand 
does not want. For more detail on these risks, see Risk Management Proposal: 
Amendments to the Import Health Standard for Sea Container from All Countries  (May 
2020). A separate document, Pest risk assessment: Halyomorpha halys (Brown 
marmorated stink bug) , describes the biosecurity risks of the brown marmorated stink 
bug.  
Proposed changes to the standard 
Non-regulatory changes to the standard  
 
(8) MPI has made some minor changes to the standard to align with MPI’s current 
formatting policies and to ensure that the legal requirements are clear, consistently 
presented, and as easy as possible to understand.  
(9) These include:  
 Changes to the order of requirements within the standard, which in turn changes the 
numbering of the requirements; 
 Updates to the generic wording associated with import health standards; and 
 Corrections of minor grammatical and spelling errors, and addition of “not 
applicable” in the quarantine declaration template in Schedule 4. 
(10) None of these changes alter the requirements in the standard or the intent of the 
requirements. They are considered 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.  
(11) These minor changes are mentioned here for clarity and transparency. They are not part 
of the consultation. 
Transshipment requirements 
 
(12) MPI proposes adding a general requirement requiring all containers that are 
transshipped through New Zealand to arrive clean and free of regulated pests. This is in 
addition to the specific requirements for BMSB in section 3.1.2 relating to containers 
transshipping through Italy. 
(13) Some containers may be discharged in New Zealand before they continue to their final 
destination. These containers, while they may be discharged, do not require biosecurity 
clearance. However, they can still pose a risk due to the potential of biosecurity 
contaminants or regulated pests moving from one container to another when on a vessel 
or a wharf.  Pests can move from the exterior of fully enclosed containers or from the 
interior and exterior of non-fully enclosed containers.  
(14) The import health standard Vehicles, Machinery and Parts  contains transshipping 
requirements (section 2.3). The proposed requirement for all transshipped containers is  
Risk Management Proposal: Amendments to the Import Health Standard for Sea Containers from All Countries   4 similar to the requirements in Vehicles, Machinery and Parts to reduce confusion and 
maintain consistency.  
(15) MPI does not expect these requirements to not create any significant or undue work for 
importers or exporters. It is good practice to ship containers clean. 
Clean on arrival 
 
(16) MPI proposes the addition of “on-arrival” to section 1.4.(1)a, which requires sea 
containers imported into New Zealand to be clean and free of regulated pests. This 
proposed change in wording is to provide further clarity and to align with MPI’s policy 
to manage regulated pests and biosecurity contamination offshore where possible.    
(17) MPI’s long standing expectation has been that containers arrive in New Zealand clean. 
However, sometimes containers leave their country of origin clean but do not arrive in 
New Zealand clean. This can happen when containers transship through other countries 
on their way here, where they may be repacked or stored in areas where 
recontamination could occur. Adding “clean on arrival” further clarifies MPI’s long 
standing expectation that care is taken to avoid contaminating pests becoming 
associated with a container even if the container goes through other countries on its way 
to New Zealand.  
Sea containers and their cargo from Italy 
 
(18) The current treatment requirements for sea containers and their cargo exported from 
Italy during the brown marmorated stink bug (BMSB) season were introduced as 
emergency measures in 2018. This was after MPI detected high levels of stinks bugs on 
goods in December 2017. These emergency requirements were then written into the 
standard in 2019 and expired on 30 April 2022. 
(19) MPI considers that these requirements remain necessary to manage the ongoing risk of 
BMSB from Italy and proposes making the 2018 emergency measures permanent. 
(20) The BMSB populations in Italy are still growing and continue to be documented at 
levels well above any other BMSB risk country.  
(21) MPI proposes continuing to require all sea containers and their cargo exported from 
Italy during the BMSB season to be treated for these stink bugs before arriving in 
New Zealand. 
(22) While stink bugs detected on goods arriving in New Zealand from Italy remain at a 
similar level to those in December 2017, most bugs detected are dead due to treatments. 
This means our treatment requirements are working and that treatment is still needed 
(23) Detections continue to be spread across a diverse range of imported Italian goods. 
However, this is not the case with BMSB detections on goods from the 37 other BMSB 
risk countries. Detections on goods from these countries are typically on a narrow range 
of goods, mostly vehicles, machinery and parts, which are structurally complex and 
frequently stored outside. 
(24) MPI explored putting the requirements for goods exported from Italy into a new and 
separate standard. While working through that process, it became apparent that a new 
standard would make things more complicated for importers and exporters, rather than 
simpler. With the requirements for goods from Italy staying in the sea container  
Risk Management Proposal: Amendments to the Import Health Standard for Sea Containers from All Countries   5 standard, importers and exporters who trade across multiple countries will only have 
one standard to look at. Based on that, MPI has decided to leave the requirements for 
goods exported from Italy in the Sea Containers  standard for ease of use. 
(25) MPI continues to look for ways to improve BMSB management across all pathways. 
We remain open to exclusions or reduced BMSB management where the risks of BMSB 
contamination are considered low enough to enable it. 
Sensitive goods 
 
(26) MPI proposes to include the list of commodities the MPI considers to be sensitive to 
treatment to be include as a schedule within the standard (Schedule 3), rather than in a 
separate document. 
(27) Section 3.1.1(3)a)i) in the current Sea Containers  standard enables goods that are too 
sensitive for treatment to be inspected on arrival. It directs readers to a list of sensitive 
goods on MPI’s website. The proposed Schedule 3 will make it easier for importers to 
check what goods are excluded from the treatment requirements.  
(28) MPI also reviewed the list of sensitive goods to ensure it only includes goods that 
cannot be treated without sustaining damage. When reviewing this list, MPI also 
ensured that these goods are not associated with increased BMSB contamination, which 
may require different risk management measures where treatment is not possible. MPI 
has not made any changes to this list as a result of the review. 
(29) Many of the sensitive goods on the list are food and medicinal products, which have 
more stringent hygiene and storage practices within the manufacturing and logistics 
supply chain. These more stringent hygiene and storage practices in turn reduce the risk 
of BMSB contamination. 
(30) MPI will regularly review requirements to make sure they continue to be appropriate for 
the risk. Over recent years, MPI has improved its ability to target specific goods, 
importers and manufacturers that have a higher risk of contamination with brown 
marmorated stink bugs including those with a history of non-compliance. 
 
   
Risk Management Proposal: Amendments to the Import Health Standard for Sea Containers from All Countries   6 References 
Burne, A R (2019) Pest Risk Assessment: Halyomorpha halys  (Brown marmorated stink 
bug). Version 1, June 2019. Ministry for Primary Industries; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/38075-Pest-risk-assessment-Halyomorpha-halys-
Brown-marmorated-stink-bug-Technical-Paper  
FAO (2019) International Standard for Phytosanitary Measures (ISPM) No. 15. Regulation of 
wood packaging material in international trade.  Secretariat of the International Plant 
Protection Convention, Food and Agricultural Organization of the United Nations; Rome, 
Italy. 
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  
MPI (2020) Risk Management Proposal: Amendments to the Import Health Standard for Sea 
Container from All Countries . Ministry for Primary Industries; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/40430-IHS-Sea-Containers-2020-review-RMP.pdf  
MPI (2021) Vehicles, Machinery and Parts . Ministry for Primary Industries; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/30224-Vehicles-Machinery-and-Parts-Import-Health-
Standard