Risk Management Proposal:   
 
Proposed amendment s to the IHS 155.02.05: Seeds for sowing.  
 
FOR PUBLIC CONSULTATION  
 
 
 
 
 
 
 
4th February  2020   
i  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Plant & Pathways Directorate  
Biosecurity New Zealand  - Tiakitanga Pūtaiao Aotearoa  
Ministry for Primary Industries  - Manatū Ahu Matua  
TSB Bank Tower 147 Lambton Quay  
PO Box 2526 , Wellington 6140  
New Zealand  
Tel: +64 4 894 0100  
Fax: +64 4 894 0662  
Web: www.biosecurity.govt.nz   
Email: plantimports@mpi.govt.nz   
   
ii Contents  Page 
 
Submissions  3 
OFFICIAL INFORMATION ACT 1982  4 
DISCLAIMER  4 
Purpose  5 
Scope  5 
Part 1: Background  5 
Commodity Description  6 
Trade  7 
Current Border Requirements  8 
Part 2: Context  10 
Objective  10 
Domestic leg islation  10 
International obligations  10 
Part 3: Risk Assessment  11 
Source information  11 
Summary of risk  12 
Part 4: Risk Management  20 
Part 5: Proposed IHS requirements  23 
Part 6: Feasibility & Practicality of measures  25 
Part 7: REFERENCES  26  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 3 of 30 Submissions  
The Ministry for Primary Industries (MPI) invites comment from interested parties on the proposed new 
import health standard for pelleted seed imported as seeds for sowing . The proposed import health 
standard is supported by this risk m anagement proposal.  
The purpose of an import health standard is defined as follows in section 22(1) of the Biosecurity Act 
1993 (the Act): “An import health standard specifies requirements that must be met to effectively 
manage risks associated with impor ting risk goods, including risks arising because importing the goods 
involves or might involve an incidentally imported new organism”.  
MPI must consult with interested parties in accordance with section 23 of the Act before issuing or 
amending an import h ealth standard under section 24A of the Act. MPI therefore seeks formal comment 
on the proposed import health standard.   
The following points may be of assistance in preparing comments:  
 Wherever possible, comments should be specific to a particular matter  discussed in this document 
and/or proposed change in the IHS through referencing section numbers or commodity names , as 
appli cable .  
 Where possible, reasons, data and supporting published references to support comments should be 
provided .  
 The use of examples to illustrate particular points is encouraged.   
MPI encourages respondents to forward comments electronically. Please include the following in your 
submission:  
 The title of the consultation document in the subject line of your email;  
 Your name and title (if applicable);  
 Your contact details, including email, phone number/s and address; and  
 Your organisation’s name (if applicable) . 
Please send electronic submissions to: plantimports@mpi.govt.nz .  Should you wish to send hardcopy  
submissions, please send them to the following address to arrive by close of business on 04th March 
2020.  
Plant Germplasm ( Imports ) Team   
Plants & Pathways Directorate  
Ministry for Primary Industr ies 
PO Box 2526  
WELLINGTON 6140  
New Zealand  
Submissions received by the closure date will be considered during the development of the final draft 
IHS. Submissions received after the closure date may be held on file for consideration when the issued 
IHS is next revised/ reviewed.  
   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 4 of 30  
Official Information Act 1982  
Please note that your submission is public information . 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 submissi on, such as the information is commercially sensitive or 
they wish personal information to be withheld.  
Any decision to withhold information requested under the OIA is reviewable by the Ombudsman.  
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.  
Requests for further copies should be directed to:  
Publications Logistics Officer  
Ministry for Primary Industries  
PO Box 2526  
WELLINGTON 6140  
Email: brand@mpi.govt.nz   
Telephone: 0800 00 83 33 Facsimile: 04 -894 0300  
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  
 
   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 5 of 30 Purpose  
1. The purpose of this Risk Management Proposal (RMP)  is to: 
 Provide background information on the biosecurity risks of, and associated with, pelleted seed  
and the phytosanitary measures proposed to manage those risks.  
 Provide information to support the consultation on the draft standard . 
2. The risk management proposal is not itself the subject of consultation. However, MPI will accept 
comments and suggestions on the risk management proposal in orde r to improve future 
consultations on import health standards.  
Scope  
3. The scope of th is RMP is: 
 Background information relating to the biosecurity risks of , and associated with,  pelleted seed s 
and current measures to manage those risks;  
 Relevant legislation and international obligations  
 Risk assessment and risk management;  
 Proposed phytosanitary measures to manage the biosecurity risks ; and 
 Evaluat ion of  the feasibility  and practicality of implement ing the proposed measures.  
 
Part 1: Background  
4. Seed s imported  as contaminants in lots of seed imported for sowing , including pellet ed seed,  
present  a biosecurity risk because  the seed species  may be: 
 a quarantine wee d seed  species  - in 2016, the unwanted organism  Abutilon theophrasti  
(velvetleaf) was found in fodder beet fields on a number of farms in New Zealand ; the source of 
the velvetleaf was contaminated pelleted fodder beet seed ( Beta vulgaris ). 
 a carrier for seed -borne and/or seed transmitted diseases . Seeds of Triticum  (wheat) imported 
as contaminants will not meet current IHS phytosanitary measures and may be harbouring 
regulated pest /s, such as the fungi Tilletia controversa  or T. indica , or an y other regulated pest 
that may c ause economic impact s on relevant industries . 
5. Pellet ed seed is defined in the Import Health Standard 155.02.05: Seeds for sowing  as ‘Seed 
encased in a man -made nutritive or protective covering’.  
6. Pelleted seed cannot be visu ally inspected for contaminants without having the man -made case 
removed. The addition of the case obscure s the shape , the surface and weight of the seed enough 
that it is impossible to determine which species are present.  
7. As a result  of the velvetleaf inc ursion in 2016 , MPI introduced new border clearance measures  for 
pelleted seed to reduce the likelihood  of entry of quarantine weed seeds  and/or contamination1, on 
this pathway . The new requirements  were introduced through the issuance of a direction to an 
inspector under section 104(1) of the Act.  
                                                      
1Presence of a contaminating pest or unintended prese nce of a regulated article in or on a commodity, packaging, conveyance, container or storage place 
[CEPM, 1997; revised ICPM, 1999; CPM, 2018]   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 6 of 30 8. This direction requires that  a representative sample of seeds be taken from each lot of pelleted 
seed or at a rate of one in ten lots on arrival in  New Z ealand and inspection and testing undertaken 
for the presence of quarantine  weed seeds  and/or any other contamination . Lots will only receive 
biosecurity clearance if the inspection/testing  results are negative , meaning  the lot is considered 
free from any quarantine weed seeds  and/or contamination .  
9. These measures were revised in 2017 , because a high level of contamination by other regulated 
seed species was found in vegetable pelleted seed lots and less information existed about the level 
of contaminants i n flower and greenhouse crop species . The new inspection and testing 
requirements are  currently  managed in several ways, depending on which one of the groups the 
applicable plant species has been categorised into. Three groups were defined: Beta vulgaris , 
Group 1, vegetables species and Group 2, flower and greenhouse crop species  (lettuce and 
tomato rootstock)  (see APPENDIX 1) . 
10. The group categorisations are based on the likelihood of introduction of weed seeds via a particular 
host seed species, the natur e of the seed production system /s used to produce the seed  and the 
ability to adequately survey planted seeds  to prevent weed establishment in New Zealand . 
11. All lots of pelleted seed of Beta vulgaris  and Group 1 species must now be tested (at the expense 
of the importer) for the presence of any quarantine  weed seeds  and/or contamination .  
12. For Group 2 species , imported as pelleted seed , a verification system was implemented at the rat io 
of one in ten  pelleted seed lot . The selected lots are tested for the presence of any quarantine  
weed seeds  and/or contamination.  
Commodit y Description   
13. The following  species have been identified as eligible species for import into New Zealand from all 
countries as pelleted seed under IHS 155.02.05: Seeds for Sowing :  
 
Ageratum houstonianum  Spinacia oleracea  
Allium cepa  Lisianthus russellianus (= Eustoma 
grandiflorum)  
Allium porrum  Lobelia sp. 
Anethum graveolens  Lobularia maritima  
Angelonia salicariifolia  Mimulus sp. 
Antirrhinum sp.  Nemesia sp. 
Apium graveolens  Nicotiana sp. 
Begonia sp.  Ocimum basilicum  
Bellis perennis  Origanum vulgare  
Beta vulgaris  Papaver sp. 
Brassica napus  Pentas sp. 
Brassica oleracea  Pericallis hybrida (= Pericallis x hybrida)  
Calceolaria sp.  Petroselinum crispum  
Calibrachoa hybrida  Petunia sp. 
Campanula sp. Portulaca sp.  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 7 of 30 Celosia sp. Primula sp. 
Chaenorhinum sp. Pyrethrum sp. 
Chrysanthemum sp  Ranunculus sp. 
Cichorium endivia  Rosmarinus officinalis  
Cichorium intybus  Rudbeckia sp. 
Cineraria maritima (= Seneci o cineraria)  Salpiglossis sinuata  
Daucus carota  Salvia officinalis  
Dianthus sp. Saxifraga sp. 
Diascia barberae  Senecio cruentus (= Pericallis cruenta)  
Dichondra sp. Silene sp. 
Digitalis sp. Solenostemon scutellarioides  
Eruca sativa  Streptocarpus sp. 
Exacum affine  Sutera sp. 
Foeniculum vulgare  Tagetes sp. 
Gazania sp. Tanacetum parthenium  
Geranium sp. Thymus vulgaris  
Gerbera jamesoni  Torenia fournieri  
Gloxinia speciosa (= Sinningia speciosa)  Trachelium caeruleum  
Gypsophila sp. Verbascum sp. 
Helichrysum sp. Verbena sp. 
Heuchera sp. Veronica sp. 
Isolepis sp. Viola sp. 
Juncus sp. Zinnia sp. 
Lactuca sativa   
Laurentia axillaris (= Isotoma axillaris)   
Linaria sp.  
Pastinacea sativa   
Solanum lycopersicum   
Trade  
14. To date, eighty one different  seed  species (listed above) are eligible to be imported into New 
Zealand as pelleted seed . The majority of these seed species are flower s.  
15. Between January 2017 and  August 2019, 3567 lines of pelleted flower seed, 2513 lines of pelleted 
vegetable  seed and 181 li nes of pelleted fodder beet seed were imported  into New Zealand .  
16. Imports of pelleted seed are predominantly from the Eur opean Union (i.e. Denmark, France, 
Netherlands , Germany , Italy and Spain ) and North America (USA) .   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 8 of 30 17. Pellet ed seeds are widely used because it allows precision drilling; it is a carrier of some crop 
protection treatments; and it improve s the ability to handle the smallest  of seeds . 
18.  Seed  species are imported into New Zealand as pelleted seed for a variety of pu rposes , 
including forage for cows during the winter months, ornamental, human consumption and 
rootstock.   
Current Border R equirements  
NOTE:   
 All sampling and testing is at the importers expense.  
 Because of the velvetleaf response, pelleted  seeds from Italy are tested at a higher rate 
than from other countries.  
 
Pelleted fodder beet ( Beta vulgaris ) seed from all countries except Italy  
19. All lots of pelleted Beta vulgaris  seed grown in countries other than Italy and accompanied by an 
officiall y drawn  and sealed (according to ISTA methodology)  ‘bare’ sample of at least 31,540 seeds 
will have this ‘bare’ seed sample sent for seed analysis at a MPI -approved laboratory.  
20. The ‘bare’ seed sample must be accompanied by  documentation stating the follow ing: 
 that it was  sampled, labelled and sealed according to ISTA rules ; 
 the same lot/line number or unique identifier as stated on the pellet seed lot ; 
 species and variety name ; 
 sample weight ; and 
 date and signature of the sampler . 
21. All lots of pelleted Beta vulgaris  seed grown in countries other than Italy and not accompanied by a 
bare seed sample , as described above, will have a sample of at least 31, 540 pelleted seeds drawn 
(according to ISTA methodology ) and sent for seed analysis at a MPI -approved labora tory. 
22. The lot will only receive biosecurity clearance if the laboratory results are negative, meaning the lot 
is considered free from any quarantine weed seeds  and/or contamination . 
 
Pelleted fodder beet ( Beta vulgaris ) seed lots from Italy  
23. Individual lot s of pelleted Beta vulgaris  seed grown in Italy and accompanied by an officially drawn  
and sealed  (according to ISTA methodology) ‘bare’ sample of at least 48,480 seeds will have this 
‘bare’ seed sample sent for seed analysis at a MPI -approved laboratory.  
24. The ‘bare’ seed sample must be accompanied by documentation stating the following : 
 that it was sampled, labelled and sealed according to ISTA rules;  
 the same lot/line number or unique identifier as stated on the pellet seed lot ; 
 species and variety name ; 
 sample weight ; and  
 date and signature of the sampler.  
25. All lots of pelleted Beta vulgaris  seed grown in Italy and not accompanied by a bare seed sample , 
as described above, a representative sample of at least 48,480 seeds will be drawn (according to 
ISTA methodology) and sent  to a MPI -approved lab oratory . 
26. The lot will only receive biosecurity clearance if the laboratory results are negative, meaning the lot 
is considered free from any quarantine weed seeds  and/or contamination .  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 9 of 30  
Pelleted seed lots (except Beta vulgaris ) from all countries  
Group 1 (Vegetable  species ) 
27. All lots of pelleted seed from species in Group 1 must be sampled (according to  ISTA 
methodology ) and a representative sample sent for seed analysis at a MPI -approved laboratory , 
according to th e following specific measures:  
 The lot will be directed to a MPI -approved transitional facility where it will be held pending the 
return of the laboratory results . 
 For seed lots of 300,000 seeds or greater, a representative sample of at least 31,540 
seeds will be drawn .  
 For seed lots of less than 300,000  seeds , at least 10% of the total size of the lot will be 
sampled.  
 The lot will only receive biosecurity clearance if the laboratory results are negative , meaning  
the lot is considered free from any quarantine weed seeds  and/or contamination . 
OR 
 
28. All lots of pelleted seed from species in Group 1  accompanied by an officially draw n and sealed 
(according to ISTA methodology) ‘bare’ sample of at least 31,540 seeds will have this ‘bare’ seed 
sample sent for seed analysis at a MPI -approved laboratory , according to the following specific 
measures:  
 The ‘bare’ seed sample must be accompan ied by documentation stating the following:  
 that it was sampled, labelled and sealed according to ISTA rules;  
 the same lot/line number or unique identifier as stated on the pellet seed lot ; 
 species and variety name ; 
 sample weight ; and 
 date and signature of  the sampler . 
 The lot will be directed to a MPI -approved transitional facility where it will be held pending the 
return of the laboratory results . 
 The lot will only receive biosecurity clearance if the laboratory results are negative , meaning  
the lot is considered free from any quarantine  weed seeds  and/or contamination.  
 
Group 2 (Flower species and L. sativa  (lettuce) and S. lycopersicum  (tomato) ) 
29. Lots of pelleted seed from species in Group 2 , including L. sativa  and S. lycopersicum , will be 
sampled (according to ISTA methodology) and audit tested at 1:10 lots ratio. A representative 
sample will be sent for seed analysis at a MPI -approved laboratory , according to the following 
specific measures:  
 The lot will be directed to a MPI -approved transitional facility where it will be held pending the 
return of the laboratory results . 
 For seed lots of 300,000 seeds or greater, a representative sample of at least 31,540 
seeds will be drawn . 
 For seed lots of less than 300,000  seeds , at least 10% of the total size  of the lot will be 
sampled.   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 10 of 30  The lot will only receive biosecurity clearance if the laboratory results are negative , meaning  
the lot is considered free from any quarantine weed seeds and/or contamination . 
OR 
 
30. All imported lots of pelleted seed from species in Group 2 , including L. sativa  and S. lycopersicum , 
accompanied by an officially drawn  and sealed  (according to ISTA methodology) ‘bare’ sample of 
at least 31,540 seeds, will have this ‘bare’ seed sample sent for seed analysis at a MPI -approved 
laboratory , according to the following specific measures:  
 The lot will be directed to a MPI -approved transitional facility where it will be held pending the 
return of the laboratory results.  
 The ‘bare’ seed sample must be accompanied by documentation stating  the following:  
 that it was sampled, labelled and sealed according to ISTA rules;  
 the same lot/line number or unique identifier as stated on the pellet seed lot ; 
 species and variety name ; 
 sample weight ; and 
 date and signature of the sampler . 
 The lot will o nly receive biosecurity clearance if the laboratory results are negative , meaning  
the lot is considered free from any quarantine weed seeds and/or contamination . 
Part 2: Context  
Objective  
31. MPI’s objective is to ensure the known biosecurity risks associated with the importation of pelleted 
seed are managed appropriately and are consistent with New Zealand’s domestic legislation and 
international obligations.  
Domestic  legislation  
32. The New Zeal and biosecurity system is regulated through the Biosecurity Act. Section 22 of the Act 
describes the meaning of an IHS, and requires that the IHS specifies requirements to be met for 
the effective management of risks associated with importing risk goods (i ncluding plants and plant 
products) into New Zealand.  
33. MPI is the government authority responsible for the administration of the Act.  
34. MPI engages with interested parties and  affected New Zealand stakeholders when major 
amendments are made to an IHS.  
35. MPI follows MPI guidance  for decision -makers and procedures for the amendment of an IHS and 
consultation  on proposed amendments . 
International  obligations  
36. Where possible, phytosanitary measures are aligned with international standards, guidelines and 
recommend ations  as per New Zealand’s obligations under Article 3.1 of the W orld Trade 
Organisation (WTO)  Agreement on the Application of Sanitary and Phytosanitary Measures (SPS 
Agreement), WTO 1995  and section 23(4)(c) of the Act .  
37. The SPS Agreement states that p hytosanitary measures must not discriminate unfairly between 
countries or between  imported or domestically produced goods and , where there is a choice of  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 11 of 30 phytosanitary measures to reduce risk to an acceptable level, WTO members must select the least 
trade restrictive measure.  
Part 3: Risk Assessment  
Source information  
38. The following information  was used to inform the appropriate measures for the development of this 
RMP:  
 Relevant literature and database searches ; 
 MPI’s Emerging Risk System ; 
 Stakeholder  feedback ; and  
 Interception records  (APPENDIX 2 ). 
39. The risks associated with pellet ed seed are summarised in the table below. Further evidence 
supporting the statements in the table follows.  
 
Question  Factors to consider  
What is the relative risk associated with the 
commodity category?  Seed for sowing is a form of germplasm, identified under ISPM 
322 as the highest risk commodity category (category 4). This 
categorisation is based on a combination of the degree of 
processing and the end use of the commodity.  
What is the relative risk of the commodity 
within the commodity category?  
Which groups of pests and pathogens are 
most important on the commodity?  Seed for sowing is a lower risk type of germplasm (“plants for 
planting”) compared to whole plants and some types of cuttings, 
because seeds are usually dried and removed from other plant 
parts such as fleshy fruits or pods. Drying and removal of other 
plant parts reduces the numbers and types of associated 
invertebrates.  
On the other hand, there are a range of pathogens associated 
with seed. Few of these cause visible symptoms on the seed.  
Seed is often harvested and sorted mechanically. As a result, 
there are a range of contaminants associated with seed for 
sowing. These include soil, seeds of species other tha n the 
commodity and other extraneous plant material.  
Pellet ed seed , has undergone additional processing following 
harvest (application of a coating which may contain pesticides 
and/ or fertilisers). As a result, the numbers and types of 
associated vertebrates are reduced further. Pellet ed seed is 
also likely to result in a further reduction in contamination that is 
not the same size and shape of the seed.  
What are the minimum requirements for 
seed for sowing?  
What is managed by the minimum 
requirements and what is not?  The minimum requirements for seed for sowing are bas ed 
largely on visual inspection of the seed  to detect  contamination, 
infestation and other irregularities (such as seed which is 
discoloured, which may indicate disease). In the majority of 
cases, there is no post -entry quarantine. Pathogens and 
invertebra tes that are known to be transmitted through seed for 
sowing are usually managed by additional requirements  that 
can be carried out in the country of export or in New Zealand in 
few cases . 
                                                      
2 Link to ISPM 32 https://www.ippc.int/static/media/files/publication/en/2016/01/ISPM_32_2009_En_2015 -12-22_PostCPM10_InkAmReformatted.pdf    
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 12 of 30 For pelleted  seed, the minimum requirements are likely to be 
less effective at detecting certain types of contamination. The 
coating applied to the seed means that it is not possible to 
confirm the presence of contamination which is a similar size, 
shape and weight to  the commodity species. This type of 
contamination is most commonly seed of other species.  
What values are at risk in New Zealand 
from pests, pathogens and contamination 
associated with pelleted seed?  The main risks associated with pelleted seed come from  the 
presence of contaminating seed. The risk either results from the 
contaminating seed being a weed or from the contaminating 
seed having associated pathogens.  
In general, contaminating seed which is picked up during the 
harvest of a crop is likely to be  a weed of that crop and similar 
crops. Therefore the impacts are most likely to be economic. 
Where the contaminating seed has associated pathogens, the 
impacts will depend on the pathogen and its host range.  
What is the level of knowledge about 
contamin ation in pelleted seed?  Contamination types and levels in pelleted seed will depend on 
a wide range of factors, and may be difficult to predict reliably 
without knowledge of specific crop production systems. On the 
other hand, there have been recent analys es of the results of 
onshore  tests conducted on imported pelleted seed. The 
analyses allow some general conclusions to be drawn and 
some categories to be proposed.  
Summary of risk 
 
Entry  and Exposure  
40. For the purposes of biosecurity, contamination risks of imported seed lots include: soil, regulated 
pest(s), seed species that have been assessed as a weed risk, unidentified seeds and plant 
material.  
41. As determined by the Import Health Standard 155.02.05:  Seeds for sowing , on arrival in New 
Zealand seeds must be made available for inspection and examination by MPI Inspectors at the 
importer’s expense. Further, each line of seed must undergo inspection to verify  that the seed and 
associated documentation is  compliant with the requirements of this IHS; an officially drawn sample 
will be inspected for contaminants from each line as per MPI current procedures.  
42. The importation of pellet ed seeds  enables the entry to New Zealand of quarantine weed seeds 
and/or regulated pest(s) because the coating  process changes the shape and weight of the seeds 
making visual inspection for contamination  at the New Zealand border almost impossible.   
43. In this RMP,  quarant ine weed seeds and/or regulated pest(s) are considered to have entered New 
Zealand if viable seeds of a species other than the commodity are present together with the host 
seed pellet at a low infestation level after biosecurity clearance.  In addi tion, pelleted seed is 
usually high value and is likely to be planted. Therefore contaminants, even if at a low level per 
seed, are likely to be planted and exposed to the New Zealand environment.  In February 2016, 
velvet leaf was found on a small number of  farms in the South Island where it was not known to be 
present. All positive detections in the South Island were directly linked to fodder beet crops grown 
from a number of lines of pelleted fodder beet ( Beta vulgaris var. rapacea ) seed s originated from 
Italy and exported from Denmark.   
44. Seed species grown under greenhouse/glasshouse or in the field can be responsible for the 
introduction of a new organism such as a genetically modified organism or a new species to the 
New Zeala nd environment as a contamina nt.   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 13 of 30 45. The import health standard states that seeds for sowing must be free from unidentified seed. 
Unidentified seed species (contaminant in Dianthus  and Lactuca sativa ) may increase the 
likelihood of introduction of a new species into the New Zealand envir onment where its biological 
traits are unknown . 
46. Results from onshore tests undertaken on pelleted seed since the implementation of emergency 
border meas ures in 2016 have been analysed . The onshore tests, which involved dissection of 
pellets, were undertake n between 1st May 2016 and 6th December  2019  for all three categories of 
pelleted seed: Beta vulgaris ; vegetables ( Group 1 ); flowers , tomato as rootstock and lettuce ( Group 
2). 
47. Between 1st May 2016 and 6th December  2019 , 265 onshore  tests were undertaken on imported 
lots of pelleted Beta vulgaris  seed . Analysis of the test results showed contamination rates were 
high across these imports .  
48. During the same period, 150 tests were undertaken for pelleted vegetable seed s (Group 1 ). This 
difference in the number of tests taken for this group in relation to the number of tests done for 
Beta vulgaris  can be explained by the fact that initial measures prior to 2017 were that only one in 
ten lots was sampled and tested ; and after 2017, all lot s were sampled and onshore tested .  
49. Contamination rates were variable across the different species in Group 1 , as highlighted in Figure 
1 (below). During 1st May 2016 and 6th December  2019, 54% of pelleted carrot seed lots imported 
and tested onshore were contaminated. In total, 13 lots were tested onshore , where  seven lots 
contaminated.  
50. Contamination rates of o ther seeds species from this group with ten or more onshore tests 
performed during the same period were : Leek  (10% of the 60 lots tested onshore we re 
contaminated ); Celery  (11% of the 27 lots tested onshore were contaminated ); Endive (57% of the 
7 lots tested were contaminated) and Fennel  (18% of the 17 lots tested onshore were 
contaminated ) (see Figure 1) .  
 
 
 
Figure 1 - Contamination rate s (95 % confidence interval ) for pelleted seed species from Group 1 with ten or more 
laboratory tests done during the period 1st May 2016 to 6th December 2019). Other species listed in Group 1 were 
not added to this table because the number of laboratory tests was  less than five.  Number of onshore tests 
performed for each group is shown in each box.  NOTE:  Contamination rate in this document is defined as the 
percentage of number of lots tested onshore which contaminants (other regulated seed species) were found.  60 2717137
0102030405060708090
Leek Celery Fennel Carrot EndiveContamination rate (%)
Risk group one commodities 
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 14 of 30 51. Although contamination levels were not as high as those found in pelleted seed  lots of Beta 
vulgaris , pelleted vegetable seed lots had a much higher level of contamination than pelleted seed 
lots from Group 2 (flowers, lettuce and tomato for the purpose of rootstock), as shown in Figure 2 
(below). Analysis of the Beta vulgaris  lots imported and onshore tested inform that 28% of the 2 65 
lots were contaminated. O ut of the 150 tests performed on seed species from Group 1, 2 2% were 
found contaminated. The contam ination rate for seed species tested from Group 2 was 5% on 461 
tests performed onshore.  
52. NOTE:  As the implementation of an audit test as a measure for seed species of Group 2 (flower 
species,  lettuce and tomato for the purpose of rootstock) was introduced  in 2017, o nshore tests are 
from the period of 30st August 2017 to 6th December 2019.  
 
 
 
Figure 2 - Contamination rates (95 % confidence interval) for pelleted seeds of Beta vulgaris, Group 
1 & 2 species (1st May 2016 to 6th December 2019).  Number of onshore tests performed for each 
group is shown in each box. NOTE:  Contamination rate in this document is defined as the 
percentage of number of lots tested onshore which contaminants (other regulated seed species) 
were found.  
53. A number of  different contaminants were found inside seed pellets from seed species in all the 
groups.  Some of them include: unidentified species, Allium sp., Solanum sp., Brassica sp. Setaria 
sp., Triticum aestivum, Avena sativa  and Chenopodium sp ., among others ( APPENDIX 2 ). In 
addition, pelleted seeds  are not able to have any of the contaminant(s) found removed by usual 
seed cleaning processes such as gravity separators. Because all pelleted seeds have the same 
shape and weight, meaning that host species cannot be separated from the contaminants. 
Therefore, the biosecurity risk must be managed through different processes.  
54. There were 461 tests  performed in flower , lettuce , and tomato for the purpose of rootstock  crops 
group (Risk Group 2)  during the period of 30st August 2017 until 6th December 2019 . The 
contamination rate for those with more than ten imported lots and tested onshore were the 
following: Petunia  sp. (there we re 37 lots tested which 5% were contaminated ); Dianthus  sp. (there 
were 25 lots tested of which 8% were contaminated ); Lactuca sativa  (there were 1 81 lots tested of 
which 4% were contaminated); Lobelia sp.  (there were 3 1 lots tested of which 6% were 
contaminated); Begonia sp.  (there were 5 2 lots tested of which 2% were contaminated ) and 
Lisianthus sp . (there were 50 lots tested of which 4% were contaminated) .  265 150 461
0510152025303540
Beta vulgaris Group One Group TwoContamination rate (%) 
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 15 of 30 55. Less than 10 imported lots of pelleted  tomato seed for the purpose of rootstock were te sted under 
the audit testing regime. No contaminants were found on any of the lots tested as a result of the 
audit testing.   
56. Although the majority of flower species imported into New Zealand are grown indoors in 
greenhouses in the exporting country, this i s not the case for all. Species from the genera Bellis, 
Chaenorrhinum, Juncus, Lobelia  and Saxifraga  are known to be grown in the field in different 
countries of origin prior to be imported from a re -export country to New Zealand. Overall, seeds 
growing outside i n the exporting country are more likely to have weeds or other species growing as 
voluntaries around them, and therefore weed seeds and/or other seeds are more likely to be 
present in the lot, such was the case for Lobelia  and Juncus .  
57. In the contex t of seeds growing in greenhouses (i.e. flower species) in the exporting country, the 
likelihood of seeds growing alongside weeds and/or other species and these contaminants entering 
New Zealand together with the host species is considered to be low; but t he proportion of those 
contaminants to be present on the lot is uncertain. Testing onshore informed  that lots of Portulaca , 
Dichondra  and Lisianthus  were found to have other plant species in the same pellet as the host 
species.    
58. Information provided by the industry informed MPI that 95% of all pellet flower seeds either as F1 
hybrid (i.e. from plants grown indoors in greenhouses) or from open pollinated plants at the place of 
production are sold in New Zealand to commercial nurser ies. These nurseries grow each of these 
seeds for retail market in New Zealand as plants for planting targeting the home garden market.  
59. A small percentage is then sold online to home gardeners as pellet seeds and also to small 
growers who may supply locally grown flowers to their local markets. It is considered likely that if 
any weed  seed had been inadvertently planted, and if the seeds germinated, they would likely be 
weeded out by gardeners as the seedlings are different to the intended flower species  and not 
desirable .  
 
 
 
Figure 3 -  Contamination rate with 95 % confidence intervals for risk group two commodities with 
10 or more laboratory tests during  30st August 2017 to 6th December 2019 . Number of onshore 
tests performed for each group is shown in each box. NOTE:  Contamination rate in this document 
is defined as the percentage of number of lots tested onshore which contaminants (other regulated 
seed species) were found.  
60. In summary, analysis of results of onshore  tests of pelle ted seed at the border since  emergency 
measures were introduced in 2016, show that :  181
5250373125
051015202530
Lettuce Begonia Lisianthus Petunia Lobelia DianthusContamination rate (%)
Risk group two commodity 
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 16 of 30  Although, the contamination rate is not statistically different between the Beta vulgaris  
group and Group 1 , Beta vulgaris  group has th e highest rate of contamination ( 28% out of 
265), follo wed by Risk Gro up1 – vegetables  (22% out of 1 50) (Figure 2) .   
 Risk Group 2 - flowers, lettuce and tomato has a contamination rate significantly lower than 
for the other two groups  (5% out of 4 61) (Figure 2) .  
 Contamination rates are variable across the differ ent seed species onshore tested in 
Group 1  and Group 2  (Figure 1 and 3) .  
 
Establishment and spread  
Contaminant as a quarantine weed  
61. The assessment of establishment of a regulated pest, including a  quarantine weed seed  via the 
pelleted seed pathway is made on the basis that the pest has formed a self-sustain ing population 
in New Zealand. The likelihood of establish ment  in the New Zealand environment (beyond one 
season) is uncertain, but it can  be high  depending o n the species . 
62. In general, contaminati ng seed which is picked up during the harvest of a crop is likely to be a 
weed of that crop and similar crops. If the commodity seed is planted then the contaminants will be 
planted at the same time. If the contamination is present at even a very low level  of infestation (per 
seed of the commodity) then , given the number of commodity seeds sown , there is a reasonable 
chance that the contaminant seed will find conditions suitable somewhere in New Zealand to 
germinate and develop into a plant that can reprodu ce and form a new population.  
63. Velvet leaf ( Abutilon theophrasti ) can be used as an example to illustrate the potential for a very low 
level of infestation by contaminant seed to lead to establishment of a difficult to control weed 
species.  
64. In February 2016,  velvet leaf was found on a small number of farms in the South Island where it 
was not previously known to be present. All positive detections in the South Island were directly 
linked to fodder beet crops grown from a number of lines of fodder beet ( Beta vu lgaris  var. 
rapacea ) seed pellets originated from Italy and exported from Denmark.  
65. A single velvet leaf plant originat ing from one viable seed can drop up to 17,000 seeds once 
growing in the field.  Therefore , even if a contaminant seed is present at a very low level in seed for 
sowing, a single germinating plant has the potential to form the basis of an established population.  
66. Velvetleaf seeds can survive for up to 50 years in soil and germinate in large numbers in cultivated 
areas such as field crops. Propa gation is always by seeds, which are produced in large numbers, 
and dispersed by opening of each carpel with a vertical slit along the outer edge. Velvetleaf is 
difficult to control because it is resistant to many herbicides, and normal weed management 
practices don't work at controlling it. It keeps emerging over summer and autumn . Seeds can lie 
dormant in soil and then germinate years later. This often happens in response to cultivation and 
movement of soil  (cabi.org , 2019) .  
67. Certain Solanum  species are not present in New Zealand and are regulated organisms. Solanum 
species unable to be identified to species level were foun d as contaminants in lots of pelleted 
seeds. The species Solanum elaeagni folium , for example, is known to be an invasive species 
capable to out compete native flora and it is recognised as an unwanted organism under the 
Biosecurity Act.   
 
Contaminant as a vector for diseases  
68. Crops grown under greenhouse/glasshouse conditions a re not free from weeds  or contaminant 
seeds . Weed or contaminant seeds grown in greenhouses or in the field can act as environmental  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 17 of 30 reservoirs for regulated pests. E nvironmental reservoirs of  regulated pests  that are transmitted 
between plants of the same  or different species by vectors such as bumblebees , whiteflies, thrips  
or aphids have the potential to be transmitted back into outdoor commercial crops via these 
insects.  
69. The steps to introduction  for most pathogens  present with a contaminant seed , taking for example 
serious viruses and viroids like Pepino mosaic virus  or Potato spindle tuber viroid  (regulated pests 
of species of Solanum ), would be:  
 Seed of weed or contaminant plant is infected with virus /viroid  either on the seed coat or in 
the em bryo.  
 Infected seed contaminates lot of seed for sowing (and gets pelletized)  
 Infected seed is planted along with the seed for sowing lot 
 Seed pellet dissolves, and seed germinates  
70. The plant which grows from the infected seed survives long enough for the v irus to be transmitted 
from the plant (via mechanical transmission, a vector, seed, pollen etc)  (MPI, 2016) . 
71. Bumblebees are often used for pollination in commercial tomato production; the bumblebee 
species Bombus impatiens  and B. terrestris  contribute to t he spread of the seed transmitted virus, 
Pepino mosaic virus  (PeMV) , between tomato plants  (Shipp et al, 2008; Lacasa et al., 2003). 
Bombus terrestris  is the most common bumblebee  in New Zealand and it can be found throughout 
the country . Bumblebees can al so transmit PepMV between different species: from tomato plants 
into the weed species Datura stramonium , and from th is species back into tomato again (Stobbs et 
al., 2009 ; MAF , 2012 ).  
72. Therefore, a greenhouse where a host species for this virus grows as a contaminant plant and it is 
infected with this virus, Pepino mosaic virus , can act as a source of inoculum . If bumblebees are 
present in commercial greenhouses and can get out readily through ventilation etc to the outdoor 
environment, t he virus present in  this contaminant plant may be vectored from the initial infected 
plant  to other plants inside the greenhouse and also outside to commercial crops .  
73. Some of the reported genera of contaminant seed ( Lolium  and Triticum ) can be associated with 
species of Tilletia. Taking T. indica  as an example, the events that must occur for an introduction 
are as follows:  
74. Seed of a susceptible host plant species that is growing as a weed amongst the commodity plant 
species to be imported as seed for sowing  is infected with Tilletia  – an infected seed is basically 
transformed into millions of Tilletia  spores encased in a seed coat.  
 Infected seed contaminates lot of seed for sowing (and gets pelletized)  
 Infected seed is planted along with the seed for sowing lot 
 Seed pellet dissolves, releasing millions of spores into the soil  
 Spores germinate in the soil and infect host plants.  
75. When these steps are considered , there is a higher probability of introduction (entry and 
establishment) for a single infected seed that holds millio ns of Tilletia  spores, even if there is a 
small number of contaminant seeds in a lot, than for pathogens that require the seed to germinate 
for the pathogen to be transmitted (as in the previous example) . 
 
Contaminant as a new organism  
76. In 2018, 189.8 million hectares of genetically modified crops were planted across the world 
(ISAAA .org, 2019). Commercially genetically modified events of specific crops such as Brassica 
napus var. oleifera  among others is known to be grown and sold internationally. MPI has specific  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 18 of 30 measures in place for these species as seeds for sowing and in some cases  as plants for planting 
too.  
77. Brassica  sp have been intercepted as contaminant in lots of vegetable ( Allium ampeloprasum  and 
Cichorium  endivia ) pelleted seeds . If seeds f rom genetically modified Brassica napus  resistant to 
herbicide are imported into New Zealand as a contaminant they may grow as weeds amongst other 
crops  therefore a usual tool for prevention of establishment (herbicide) will not be as effective. 
Once plants are established, any that produce seed will establish a reservoir of GM seed in the 
soil, from which new plants can grow.  
78. Genetically modified seeds can easily spread through a commercial  crop because they will 
germinate and grown like any other plant. Once in the environment, g enetically modified crops may 
also have the ability to  breed with related weed species, and different and more herbicides might  
have to be used  to control these plants . 
79. In greenhouse systems, effective sanitation and weed control may lead to elimination of a 
genetically modified plant during the growing season. However, lack of an adequate sanitation at 
the end of the previous sea son will lead to a recurrence of genetically modified plants.  
 
Economic impacts   
80. Imported pelleted seeds can harbour risk material that can result in economic impact to New 
Zealand. Economic impacts may potentially arise from the cost of response activiti es, immediate 
trade impacts for some organisms  (e.g. loss of G M free status) , long term management costs, 
impacts on efficacy of current pest management including integrated pest management, impacts on 
production (lower quality/quantity of commercial crop)  or the cost of meeting additional 
requirements for exports to some countries.  
81. The likelihood of eradication success once quarantine weed seeds and/or regulated pest(s) have 
established in the New Zealand environment declines rapidly as the land area invol ved increases. 
New Zealand has eradicated only seven weed species – all had barely formed self -sustaining 
popul ations before their removal (doc.govt.nz , 2019).  
82. As an example, t he weed v elvet leaf causes serious economic damage to agricultural production, 
particularly maize, soybeans and cotton. Other crops that this weed has been associated with 
include: beans, tobacco, alfalfa, peanuts and sugar beet ( cabi.org,  2019). According to 
Cropsciences. bayer.com  (2019) velvetleaf is one of the worst agricultural weeds in corn and sugar 
beet in North America. It has the ability to compete for light and water with the crop and releases 
allelochemicals that reduce growth and emergence of neighbouring plants. Velvetleaf cau ses high 
yield losses  and interferes with harvesting . In soybean, 72% crop loss can be caused by infestation 
of velvetleaf , while 70% crop loss has been recorded in maize ( cabi.org , 2019).   
83. The MPI costs of the 2016 Velvetleaf Response were approximately $ 3.6 mill ion. In November 
2017 the Velvetleaf Response was formally transitioned into the Velvetleaf Long Term 
Management Programme. The MPI costs for this programme to date (September 2019) are 
approximately $350,000. These figures do not include the costs  of velvetleaf management borne 
by others e.g. Regional Councils, industry bodies or farmers. These figures also do not include the 
economic costs of reduced production associated with the weed. It is too soon to know what the 
ongoing economic consequences  of the 2016 velvetleaf incursion into New Zealand will be. An 
analysis conducted by New Zealand Institute of Economic Research in 2017 estimated that the 
incursion could have significant economic impacts and could reduce GDP by between $294 and 
$484 milli on by 2030. These figures come with a high level of uncertainty as the analysis was 
based on the limited knowledge of that time and a number of assumptions were made after 
discussions with industry stakeholders, MPI officials and scientific experts.   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 19 of 30 84. Contam ination in the form of undeclared viable seeds such as Solanum sp. (contaminant in 
Daucus  carota ), Portulaca sp. (contaminant in Lobelia ), Daucus carota  (contaminant in Pastinaca  
and Lactuca sativa ), Lolium sp.(contaminant in Beta vulgaris, Daucus carota  and Lactuca sativa ) 
and Agrostis sp. (contaminant in Portulaca ), which have all been intercepted from imported pelleted 
seed lots (Appendix 2),  can act as vectors for seed transmitted diseases  that may affect 
economically important crops in New Zealand .  
i. One species  of Portulaca, Portulaca oleraceae , is a known vector for the regulated seed 
transmitted pest Cucumber green mottle mosai c virus  (CGMMV). This virus is highly 
contagious and can be transmitted via contact, machinery, shoes and hands, among 
others.  Its viral particles are stable, and the virus can be maintain its infectivity for a long 
period of time.  In New Zealand, the impact of establishment of CGMMV would be greatest 
for the squash and pumpkin industry. Given the annual sales value of butternut squash, 
pumpkin, melon and other cucurbitaceae grown in New Zealand ($~51 million) the direct 
economic impact in the first year of CGMMV establishing in a New Zealand crop is likely to 
be in the millions of dollars.  
ii. Daucus carota  is a host for the regulat ed pest ‘Candidatus Liberibacter solanacearum ’ 
haplotype s C and D. Diseased host species would have their yield and quality impacted 
when infected with this pathogen.  In 201 8 carrot seed exports totalling $ 30.3m went to 
Continental Europe  (Fresh Facts .co.n z 2018). Domestic sales of carrots (fresh and 
processed) were valued at $ 56 million in 201 8, and exports were valued at $ 8.5 million 
(fresh), $ 1.8 million (processed)  (Fresh Facts .co.nz  2018). 
iii. Solanum  species, such as Solanum nigrum , Solanum lycopersicum , Solanum melongena , 
Solanum muricatum  and Solanum jasminoides  among other species are known to be hosts 
for the regulated seed transmitted pest Potato spindle tuber viroid  (PSTVd ). The viroid is 
highly contagious and can be  transmitted between plants by tou ch, either by plants rubbing 
against each other or people touching plants. The use of cutting or pruning tools or 
contaminated machinery or any form of physical contact between plants can r esult in 
disease transmission ( MAF , 2012). Other regulated seed -transmitted pests with similar 
mode of transmission known to infect species of Solanum , i.e.Tomato apical stunt viroid , 
Tomato chlorotic dwarf viroid  and the virus Pepino mosaic virus , can also be transmitted by 
bumblebees ( MAF , 2012). Tomatoes and capsicums  and potatoes are all  important crops in 
New Zealand . If PSTVd did establish in New Zealand crops, financial losses due to PSTVd 
are likely to be greater in potato and tomato crops. In Capsicum, there may be financial 
losses due to the costs of testing for a nd removing asymptomatic infected plants. Domestic 
sales of tomatoes  (outdoor , processed  and greenhouse ) were valued at $ 141.5  million in 
2018, and exports (greenhouse ) were valued at $ 9.6 million (fresh), $ 3.1 million 
(processed)  (Fresh Facts .co.nz  2018). Domestic sales of potatoes  (fresh/table  and 
processed) were valued at $ 139 million in 201 8, and exports (fresh and processed) were 
valued at $ 26.4 million (fresh), $ 114.9  million (processed)  (Fresh Facts .co.nz  2018). 
iv. Lolium  and Triticum  seeds have been fo und as contaminants in pelleted seeds and they 
can carry spores of Tilletia  species . Together with Agrostis  seeds they can be carriers of 
different plant pathogenic smuts . Tilletia  species are important pathogens which can 
establish from ungerminated seed – millions of spores can be present in a single infected 
grain of the host species. In New Zealand, the majority of wheat grain produced is for the 
domestic market, therefore direct economic impacts may be lower than in countries which 
have a large export market. However, there will be indirect effects of an increase in 
importing wheat. Additional control costs could also be incurred by growers were Tilletia 
indica  and/or T. controversa  to establish in New Zealand such as changes to integrated 
pest management systems, increase d treatment costs and funding of trials to test resistant 
cultivars  (MPI, 2015) . Species of Tilletia  could also impact the export market for seed 
production . The value of arable exports was  $236 million for the year ended June 2 019.  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 20 of 30 Exports of ryegrass ( Lolium ) were valued at $55,070 ,000 in 2018. The annual production 
of barley, wheat, maize and oats is around 950,000 tonnes according the New Zealand 
Grain & Seed Trade Association (NZGSTA .co.nz , 2019).  
Part 4: Risk Management  
Pre-export inspection and phytosanitary certification  
85. Pre-export inspection and phytosanitary certification of risk goods  by the National Plant Protection 
Organisation (NPPO) of the exporting country ensures that the requirements of the relevant IHS 
have be en met by th at country.  
86. A phytosanitary certificate can provide verification that lots of pelleted seed are  free from visually 
detectable contaminants , such as other viable seed, soil, contaminant animal or plant material or 
other extraneous matter.  The c ertificate can also be used to provide additional verification for other 
steps of the seed pelleting process , if the NPPO has sufficient oversight over th is. 
Verification on arrival in New Zealand   
87. Upon arrival  in New Zealand , importers must make the seeds and accompanying  documentation 
available for inspection by an MPI inspector , as per the current Import Health Standard (IHS) 
155.02.05: Seeds for sowing  requirements .  
88. If a lot is found to harbour a quarantine weed seed after i t has been analysed by an MPI -approved 
seed testing facility , the importer will be offered the option of having the lot reshipped or destroyed.  
89. Pelleted seeds are examined using purity testing to determine the number and identity of other 
seeds in a test s ample (i.e. quarantine weed seed and other contaminants).  
A. Purity Testing  
90. The purpose of purity testing is  to assess the levels of contamination from other seed and organic 
matter (other crop seed and weed seed , leaves, stems, badly broken seed, etc ) and inorganic  
matter (stones, soil etc ) (Sansor.org. (2019).  
91. The sampling and purity test is performed in accordance with ISTA  methodology. This is designed 
to ensure that the assessment made is representative of the seed lot from which the submitted 
sample is drawn. Seed purity is assesse d through visual inspection to identify, where possible for 
the species being assessed, the genus and/or species of seeds p resent and the types of other 
contaminants .  
Options Analysis  
Beta vulgaris and vegetable crops  
92. The adoption of testing for each seed lot for pelleted Beta vulgaris  and vegetable seeds is justified, 
because the contamination rate found during the period of  2016 until 2019 was high and the type of 
contaminants  included quarantine weed seeds and seeds with specific requirements .  
93. As highlighted previously in this document, t he contamination rate is not statistically different 
between the Beta vulgaris  group a nd Group 1  (vegetables) , Beta vulgaris  group has the highest 
rate of contamination (28% out of 265), followed by Group1 (vegetables ) (22% out of 150) .  
94. Seed species found as contaminants on both groups do have specific requirements under the 
import health standard 155.02.05: Seeds for sowing for regulated pests where seeds is a pathway, 
e.g. Solanum sp.; Lolium sp.; Daucus carota; Triticum aestivum; Horde um vulgare . Quarantine 
weed seeds were  also found in the case of Beta vulgaris , e.g. Silybum marianum.   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 21 of 30 95. Some contaminants  were identified to genus level belonging  either from 
 genera with species where the import specification is ‘requires assessment’. Seed  species 
listed in the Plant Biosecurity Index (PBI) as ‘requires assessment’ cannot be imported into 
New Zealand, or  
 genera where some  species are widely grown as  garden  flowers, while some  are known to 
be invasive weeds , e.g. Malva sp . 
 
Tomato rootstock  
96. Audit testing for lots of pelleted tomato seeds imported for the purpose of rootstock showed no 
contamina nts on all lots tested  during 2017 until 2019 . Therefore, the introduction of specific 
measures on this commodity is not warranted. Further, pelleted tomato seeds are imported to be 
sold to commercial nurseries which grow each seed for grafting on other So lanaceae species such 
as eggplant, peppers and tomatoes. This particular end use of the seed after biosecurity clearance 
means that any contaminants are likely to be identified and destroyed during normal nursery 
production practices, reducing risk to an a cceptable level.  
 
Flower species  
97. The level of contamination found on this group was low in comparison to the other two groups. The 
majority of seed species found as contaminants were other flower species. As a result, mandatory 
purity testing is not warranted for pelleted flower seeds. The majority of pelleted flower seeds 
imported into New Zealand are sold to commercial nurseries  (approx. 95%) , where the seeds are 
grown indoors, in greenhouses. Commercial nurseries grow these seeds to sell as plants for 
planting in pots for the home garden market. Only a small percentage of pelleted flower seeds is 
sold online for home gardeners and small growers.  
98. The management of  contaminants on pelleted flower  seed s after biosecurity clearance in 
greenhouses and home gard eners (i.e manual rouging  and/or herbicide application ) is considered 
to reduce to an acceptable level the biosecurity risk associated with the low level of contamination 
found on this group  
99. Moreover, contaminants found on pelleted flower seeds were largely other flower species 
(APPENDIX 2).  
 
Lettuce  
100. According to HortNZ, lettuce is one of the ten key vegetables that are staple to the Kiwi diet. In 
2016, 8,400 tonnes were produced in New Zealand.  Lettuce is grow n in different areas of the 
country. It is not an export crop due to its short shelf life. According to the industry a pproximately 
500 different seed lots of lettuce are imported annually , where the largest lot may have 9 million 
pellets an d the smallest 100,000 pellets  (Hortz.co.nz, 2020) .  
101. Although, the contamination level found was of 4%, i n terms of absolute numbers, pelleted lettuce 
seeds shown to have 3 times more contaminants than pelleted Lisianthus  seeds with the same 
contamination rate.  
102. Common seed species found as contaminants were field crop  seed species , e.g. Daucu s carota  
and Lolium sp . These contaminant seeds do have specific requirements listed in the import health 
standard.  
103. The adoption of an audit testing with moveable tie rs of compliance (option 4 – see below) for 
pelleted lettuce seed lots arriving into New Zealand is justified , because:    
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 22 of 30 i. Contrary to how pelleted flower seeds are managed after biosecurity clearance, pelleted 
lettuce seeds are sow n either directly to the ground or start in seed trays and plant out 
after approx.4 -5 weeks.  
ii. Lettuce will grow in large field areas to supply consumer demand across the country , 
therefore the re is biosecurity risk associated with the presence of contaminan ts that can 
act as carrier of regulated pests or as a regulated weed is higher in comparison to pelleted 
flower seeds.  
   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 23 of 30 Part 5: Proposed IHS requirements  
It is proposed to amend IHS 155.02.05: Seeds for sowing , through addition of a new section under  Part 
1: General Requirements  as follows.  
1.9 Seed imported as pellet ed seed  
(1) On arrival in New Zealand seeds must be made available for inspection and examination by 
MPI Inspectors at the importer’s expense.   
(2) All imported lots of pelleted seed must be held in a MPI-approved transitional facility pending 
the return of the laboratory results.  
(3) In addition  to meet ing all the  applicable  requirements of Part 1: General Requirements  of this 
standard , all pelleted  seed lots must be acc ompanied by the following:  
 a phytosanitary certificate which must meet the requirements set under Part 1.5.2 of the 
IHS 155.02.05: Seeds for sowing.  
 an Orange Seed Analysis Certificate (SAC) issued by an ISTA -accredited seed testing 
laboratory  or a Seed Analysis Certificate issued by an AOSA -accredited seed testing 
laboratory which must meet the criteria listed under  Part 1.5.2 of the IHS 155.02.05: 
Seeds for sowing.  
 
Beta vulgaris and vegetable species  
(4) In addition to 1.9  (3), on arrival pellete d seed lots of Beta vulgaris  and vegetable species must 
have a representative sample officially drawn and sealed (according to ISTA methodology) from 
each  lot of pelleted seed and tested for purity at a MPI -approved laboratory for the presence of 
quarantine weed seeds  and other contaminants .  The options for the representative samples 
are: 
Option 1:  A ‘bare’ seed sample of at least 31,540 seeds  accompany ing the pelleted  seed  lot, 
which include s an official label issued by the ISTA -accredited seed l aboratory 
stating : 
 that the seeds  have been sampled, labelled and sealed according to ISTA rules ; 
 the same lot/line number or unique identifier as stated on the pellet ed seed lot ; 
 the species and variety name ; 
 the sample weight, and  
 the date, name  and signature of the ISTA accredited/approved sampler .  
 
Option 2: For individual  lots of pelleted seed not ac companied by a bare seed sample , a 
representative sample of at least 31,540 seed pellets will be drawn according to 
ISTA methodology and sent for  seed analysis at a MPI approved laboratory at the 
importers expense.  
 
Option 3: For individual lots of pelleted seed of less than 300,000 seeds and not accompanied 
by a bare seed sample, a representative sample of at least 10% of the total size of 
each lo t will be drawn according to ISTA methodology and sent for seed analysis at 
a MPI approved laboratory at the importers expense.  
For individual lots of pelleted seed of 300,000 pellet seeds or greater, and not 
accompanied by a bare seed sample, a representa tive sample of at least 31,540  
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 24 of 30 pellet seeds will be drawn according to ISTA methodology and sent for seed 
analysis at a MPI approved laboratory at the importers expense.   
 
(5) The Options apply as follows:  
a) For pelleted Beta vulgaris  seed grown in all countries except Italy, Options 1 and 2 are 
applicable.  
b) For pelleted Beta vulgaris  seed grown in Italy, Option 1 and 2 are applicable, but the 
representative sample must be of at least 48,480 seeds.  
c) For pelleted vegetable seed of species  grown in all countries, Options 1 and 3 are 
applicable.  
 
Lettuce  
(6)  In addition to 1.9( 3) importers of pelleted seed lots of lettuce grown in all countries must comply 
with the option listed below : 
 
Option 4: On arrival , pelleted seed lots of lettuce must  have a representative sample officially 
drawn and sealed (according to ISTA methodology) and tested for purity at a MPI -
approved laboratory for the presence of quarantine weed seeds and other 
contaminants .  
i. For individual lots of pelleted seed of less than 300,000 seeds and not 
accompanied by a bare seed sample, a representative sample of at least 
10% of the total size of each lot will be drawn according to ISTA 
methodology and sent for seed analysis at a MPI approved laboratory at 
the importers expense . 
ii. For individual lots of pelleted seed of 300,000 pellet seeds or greater, 
and not ac companied by a bare seed sample , a representative sample of 
at least  31,540 pellet seeds  will be drawn according to ISTA 
methodology and sent for seed analysis at a MPI ap proved laboratory at 
the importers expense  
 
Two tiers of compliance check will be used to validate phytosanitary certification 
details against the actual lot. These are, for each importer and species imported:  
 
iii. A random compliance check on one in ten lots; and  
iv. A random compliance check on one in twenty lots. 
 
Initially, one complete compliance check, selected randomly, per ten lots shall be 
carried out to validate phytosanitary certification details (free from quarantine weeds 
and other contaminants) again st the actual lot.  
 
Where significant compliance is demonstrated over time (ten consecutive 
compliance checks validate conformance), the regime can be raised to one 
complete compliance check per twenty lots. 
 
If a compliance check identifies a non -conform ance (quarantine weed seed or a 
contaminant), the level of compliance check will drop a tier.  
   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 25 of 30  
Guidance  
 If a one in twenty compliance check identifies a non -conformance, the level of 
compliance check will reduce to one in ten compliance check tier. Or, if a one in ten 
compliance check identifies a non -conformance, the next ten lots shall be fully 
reconciled.  
 For flower pelleted seed  lots MPI reserves the right to undertake validatio n audits to 
confirm that consignments of pellet seed flowers 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.  
Part 6: Feasibility & Practica lity of measures  
A. Purity Testing  
104. The mandatory visual inspection and purity testing onshore on a bare seed sample or 
seed pellet sample as proposed in the following section ‘ Proposed IHS requirements ’ is 
operationally feasible and effectively manages the ri sk posed by the introduction of a  regulated 
(quarantine) weed seeds  and/or contaminant  (s) for the following reason:  
a) Purity testing analysis performed in an ISTA accredited laboratory under the ISTA 
guidelines is an efficacious tool.  
 Purity testing perform ed onshore in an MPI -approved ISTA accredited laboratory will 
verify the purity of the seed lot.  If the seed lot is not pure, the testing will determine the 
nature of the contamination, and the identity of contaminant seeds or pests, thereby 
enabling the risk of the contaminant to be assessed and managed appropriately . 
 An ISTA accredited  laboratory has to adhere to the ISTA Accreditation Standard, the 
ISTA Rules for Seed Testing, have competent staff and appropriate equipment and 
demonstrate its independen ce of judgement and integrity in relation to sampling and 
testing . This provides an appropriate level of assurance to MPI that the results are 
reliable because it follows an internationally recognized methodology.  
   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 26 of 30 Part 7: REFERENCES   
 
Cabi.org. (2019). Abutilon theophrasti (velvet leaf). [online] Available at: 
https://www.cabi.org/isc/datasheet/1987 [Accessed 17 Nov. 2019]  
Shipp, J L; Buitenhuis, R; Stobbs, L; Wang, K; Kim, W S; Ferguson, G (2008) Vectoring of Pepino 
mosaic virus by bu mble -bees in tomato greenhouses. Annals of Applied Biology 153(2): 149 -155.  
Stobbs L W; Greig, S; Weaver, L; Shipp, L; Ferguson, G (2009) The potential role of native weed 
species and bumblebees (Bombus impatiens) on the epidemiology of Pepino mosaic viru s. Canadia n 
Journal of Plant Pathology 31:  254-261. 
Lacasa, A; Guerrero, M M; Hita, I; Martinez, M A; Jorda, C; Bielza, P; Contreras, J; Alcazar, A; Cano, A 
(2003) Implication of bumble bees (Bombus spp.) on Pepino Mosaic Virus (PepMV) spread on 
tomato cro ps. Boletin de Sanidad Vegetal, Plagas 29(3): 393 -403. 
Isaaa.org. (2019).  Global Knowledge Center on Crop Biotechnology - ISAAA.org/KC . [online] Available 
at: http://www.isaaa.org/kc/default.asp [Accessed 17 Nov. 2019].  
Doc.govt.nz. (2019). [online] Availa ble at: https://www.doc.govt.nz/Documents/science -and-
technical/SciencePoster69.pdf [Accessed 17 Nov. 2019].  
Cropscience.bayer.com. (2019).  Abutilon theophrasti Medicus - Bayer - Crop Science . [online] Available 
at: https://www.cropscience.bayer.com/en/crop -compendium/pests -diseases -weeds/weeds/abutilon -
theophrasti [Accessed 17 Nov. 2019].  
Freshfacts.co.nz. (2019). [online] Available at: https://www.freshfacts.co.nz/files/freshfacts -2018.pdf 
[Accessed 17 Nov. 2019].  
Nzgsta.co.nz. (2019).  About Us | NZGSTA | The New Zealand Grain & Seed Trade Association . [online] 
Available at: https://www.nzgsta.co.nz/about -us/ [Accessed 17 Nov. 2019].  
Sansor.org. (2019). [online] Available at: http://sansor.org/wp -content/uploads/2012/10/11 -Analyse -
seed -purity -Learner -Manual.pdf  [Accessed 11 Sep. 2019].  
MAF (2012) Import Risk Analysis: Tomato and  Capsicum seed for sowing from all countries.  
MPI (2016) Technical Advice: contaminant seed species in seed for sowing  
Hort.co.nz (2020) [online] Available at: https://www.hortnz.co.nz/assets/Media -Release -Photos/HortNZ -
Report -Final -A4-Single -Pages.pdf   [Accessed 16 Jan. 2020].  
   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 27 of 30  
APPENDIX  1: Pelleted seed species in Groups 1 and 2 (listed in the Plant Biosecurity Index 
(PBI)  
 
Group 1  
Vegetable species  
Allium cepa  
Allium porrum  
Allium ampeloprasum  
Apium graveolens  
Brassica napus  
Brassica oleracea  
Cichorium intybus  
Cichorium endivia  
Daucus carota  
Foeniculum vulgare  
Pastinacea sativa  
Spinacia oleracea  
 
Group 2  
Vegetable species  
Lactuca sativa  
Solanum lycopersicum  
Flower species  
Ageratum houstonianum  
Anethum graveolens  
Antirrhinum sp. 
Angelonia salicariifolia  
Begonia sp. 
Bellis perennis  
Calceolaria sp. 
Calibrachoa hybrida  
Campanula sp. 
Celosia sp. 
Chaenorhinum sp. 
Cineraria maritima (= Senecio cineraria)  
Chrysanthemum sp. 
Dianthus sp. 
Diascia barberae  
Dichondra sp. 
Digitalis sp. 
Exacum affine  
Eruca sativa  
Gazania sp. 
Geranium sp. 
Gerbera jamesoni   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 28 of 30 Group 2  
Gloxinia speciosa (= Sinningia speciosa)  
Gypsophila sp. 
Helichrysum sp. 
Heuchera sp. 
Isolepis sp. 
Juncus sp. 
Laurentia axillaris (= Isotoma axillaris)  
Linaria sp. 
Lisianthus russellianus (= Eustoma grandiflorum)  
Lobelia sp. 
Lobularia maritima  
Mimulus sp. 
Nemesia sp. 
Nicotiana sp. 
Ocimum basilicum  
Origanum vulgare  
Papaver sp. 
Pentas sp. 
Pericallis hybrida (= Pericallis x hybrida)  
Petroselinum crispum  
Petunia sp.  
Portulaca sp. 
Primula sp. 
Pyrethrum sp. 
Ranunculus sp. 
Rosmarinus officinalis  
Rudbeckia sp. 
Salpiglossis sinuata  
Salvia officinalis  
Saxifraga sp. 
Senecio cruentus (= Pericallis cruenta)  
Silene sp. 
Solenostemon scutellarioides  
Streptocarpus sp. 
Sutera sp. 
Tagetes sp. 
Tanacetum parthenium  
Thymus vulgaris  
Torenia fournieri  
Trachelium caeruleum  
Verbascum sp. 
Verbena sp. 
Veronica sp. 
Viola sp. 
Zinnia sp. 
   
Ministry for Primary Industries   Risk Management Proposal for Pelleted Seed for Sowing  Page 29 of 30  
APPENDIX 2  – Interception Data between 1st May 2016 and 6th December  2019  
 
Commodity  Contaminants  
Allium ampeloprasum  Lactuca sativa; Brassica sp., unidentified seed ; Solanum 
sp., Daucus carota ; Beta vulgaris  
Apium graveolens  Amaranthus sp. , Poa sp.,  
Begonia  Eustoma grandiflorum  
Beta vulgaris  Triticum aestivum; Fallopia convolvulus; Hordeum vulgare; 
Galium aparine; Avena sp; Helianthus annuus; Avena 
sativa; Carthamus lanatus; Lolium sp.; Brassica sp.; 
Convolvulus arvensis; Ipomoea sp.; Calystegia sp.; 
Convolvulus sp.; Triticum sp.; Convolvulace ae; Paspalum 
sp.; Coriandrum sativum; Spinacia oleracea; Silybum 
marianum; Avena fatua; Galium sp; Malva sp.; Trifolium 
repens; Daucus carota;  Secale cereal e; Paspalum 
dilatatum ; Paspalum sp.   
Brassica napus  Cichorium intybus ; Galium sp.  
Cichorium intybus; Cichorium endivia  Chenopodium album; Lactuca sp; Chenopodium sp.; 
Dianthus sp.; Echinochloa sp.; Bassia sp.; Medicago 
lupulina; Nepeta sp.; Brassica sp.; Setaria sp. ; Allium sp. , 
Helminthotheca echioides, Anethum graveolens, Solanum 
sp. 
Daucus carota  
 Chenopodium  sp.; Cichorium intybus; Solanum sp.; Lolium 
sp.; Polygonum aviculare; Cirsium vulgare; Rumex s p.; 
Galium sp; Torilis arvensis, Galium sp., Malva sp.  
Dianthus  Unidentified seed , Heuchera sp.  
Dichondra repens  Lobelia sp., Petunia sp.  
Foeniculum vulgare  Valerianella locusta; Solanum sp. ; Allium sp.; Solanum 
lycopersicum  
Juncus effusus  Viola sp.  
Lactuca sativa  
 Allium  sp.; Trifolium repens; Daucus carota; Lolium sp.; 
Unidentified seed  
Lobelia  Portulaca sp.; Spergularia sp.  
Lisianthus  Lobelia sp.  
Mix Salad  Chenopodium sp.; Helminthotheca echioides; Nepeta sp. ; 
Galium sp. ; Allium sp.; Echinochloa sp.; Setaria sp.;  
Solanum sp. ; Sonchus oleraceus  
Pastinaca sativa  
 Daucus carota; Phalaris paradoxa; Sherardia arvensis; 
Allium sp.; Trifolium pratense ; Brassica sp.; Secale 
cereale; Solanum sp.; Petroselinum crispum; 
Chenopodium sp.;  
Petunia xhybrida  Lobelia sp.; Unidentified seed  
Portulaca  Agrostis  sp. 
Senecio  Begonia  sp.