Risk Management Proposal for  
Truffles for Consumption and 
Propagation  
 
Amendment to the Import Health Standard 
BNZ-IMP-TUBER: Importation into New 
Zealand of specified fresh and frozen Tuber  
species ( truffles ) 
 
 
FOR PUBLIC CONSULTATION 
 
23 August 2016
 
 
  
 
 
  
 
    
 
    
 
 
   
Plant Imports  
Plants, Food & Environment  
Ministry for Primary Industries  
Pastoral House  
25 The Terrace  
PO Box 2526  
Wellington 6140  
New Zealand  
Tel: +64 4 894 0100  
Fax: +64 4 894 0662  
Email: plantimports@mpi.govt.nz  
 
ii | Page  
  
Contents   
CONTENTS  III 
SUBMISSIONS  1 
Official Information Act 1982 2 
INTRODUCTION  2 
Purpose  2 
Background  2 
Eligible Species  2 
Phytosanitary Requirements  3 
Phytosanitary Certification  3 
International Context  3 
Domestic Context  4 
Proposed Changes  4 
References  5 
 
 
iii | Page 
  
Submissions  
The Ministry for Primary Industries (MPI) invites comment from interested parties on 
proposed measures in two import health standard s: Fresh and Frozen Truffles for 
Consumption: MPI. IHS.FP .TRUFFLES  and Truffles for Propagation: MPI. IHS.TUBER , 
as outlined by this r isk management proposal . 
 Import health standard s (IHS) specif y the requirements  to be met for t he 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(1) , Biosecu rity Act 1993 [the Act] ). 
 
MPI has developed this proposal based on best available scientific evidence and assessment 
of this evidence. If you disagree with the measures proposed to manage the risks, please 
provide either data or published references to support your comments. This will enable MPI 
to consider additional evi dence which may change how risks are proposed to be managed.  
The following points may be of assistance in preparing comments:  
• wherever possible, comment s should be specific to a particular change in IHS 
requirements (referencing section numbers or commodi ty names a s applicable );  
• where possible, reasons , data and supporting published references to support 
comments are requested ;  
• the use of examples to illustrate particular points is encouraged.   
 MPI encourages respondents to forward comments electronica lly. 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 organisation’s name (if applicable); and  
• your address.  
Send submissions to: plantimports@mpi.govt.nz
. 
However, should you wish to forward submissions in writing, please send them to the following address to arrive by close of business on  20 September  2016.  
Plant Imports  
Plants, Food & Environment  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
Submissions received by the closure date will be considered during the development of the 
final IHS. Submissions received after the closure date may be held on file for con sideration 
when the issued IHS is next revised/reviewed.  
 
  
Offic ial 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 al so 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 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.  
Introduction 
Purpose  
1. MPI has reviewed the import requirements for truffle s for consumption and propagation. 
The purpose of this document is to  provide the rational e for the proposed changes  to 
import requirements . 
Background 
2. The IHS BNZ -IMP-TUBER: Importation into New Zealand of specified fresh and 
frozen Tuber species ( truffles ) was issued in 2003 to manage the biosecurity risk s 
associated with the importation of fresh and frozen truffles .  
3. Under the current IHS, truffles imported for consumption and propagation have the same 
import requirements. All truffles must be identified by morphological examination and 
molecular analysis, using polymerase  chain reaction (PCR), to ensure they are one of the 
four eligible species.  
4. The time and  cost of molecular testing effectively  prevents  the import of fresh truffles  
for consumption. Molecular testing can take up to 10 days and the cost can be greater than the actual market price of the truffle . The average shelf life of a fresh truffle for 
consumption is less than 7 days , so the quality of the truffle declines while the importer 
waits for the test result .  
Eligible Species  
5. Of the many truffles  species world -wide , only a few are sought  out for culinary 
purposes .  
6. Truffles species eligible for importation into New Zealand are: Tuber aestivum  
(Burgundy truffles), Tuber borchii  (Bianchetto), Tuber magnatum  (Italian white) and 
Tuber melanosporum  (Périgord black truffles).  
7. Many  truffle species are similar in morphology so that distinguishing species based on 
visual characteristics is not 100% accurate. Tuber indicum (Chinese truffles) closely 
resembles Tuber melanosporum ( Périgord  - black truffles). These two truffles cannot be 
accurately distinguished by visual (morphological) examination and molecular testing is required for 100% certainty about the species.  
  
Phytosanitary Requirements  
8. Truffles must be free from soil and other contamination, to prevent the entry of 
regulated pests into New Zealand. Prior to export, truffles  must be washed and 
inspect ed for soil and pest infestation (including pest eggs and larvae) .  
9. Evidence of soil and bacterial rot will be visible to the naked eye. A 10 x magnification 
lens may be used for more detailed surface inspection to detect signs of infestation by 
burrowing pests.  
Phytosanitary Certification  
10. Every consignment of truffles  must be accompanied by a phytosanitary certificate issued 
by the exporting country National Plant Protection Organisation (NPPO).  
 
11. The certificate must state that the truffles  have been inspected for the presence of 
regulated pests and soil and are considered to be free from these contaminants.  
International  Context  
12. Where possible, phytosanitary import requirements  are aligned with international 
standards, guidelines, and recommendations as per New Zealand’s obligations under 
Article 3.1 of the World Trade Organisation (WTO) Agr eement on the Application of 
Sanitary and Phytosanitary Measures (SPS Agreement), and section 23(4)(c) of the 
Biosecurity Act 1993 (the Act).  
13. The Agreement s set 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  manag e the risks associated with the international movement of 
goods.  
 14. “The SPS Agreement will continue to guide how New Zealand sets standards and makes 
decisions related to biosecurity. In particular, it will be important to maintain th e 
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.” Balance in Trade [ online 
reference ISBN 978 -0-478-33881 -2] 
15. In keeping with New Zealand‘s obligations under the SPS Agreement , and the 
International Plant Protection Convention (IPPC), phytosanitary  measures must be 
justified for regulated pests ; commensurate with the risk; and  not discriminate unfairly 
between countries or between imported and domestically produced goods.  
 
Note : International standards, guidelines or recommendations referred to in the SPS agreement are those of 
Codex, OIE and the IPPC  (including regional standards developed by Asia Pacific Plant Protection 
Commission) . 
  
  
Domestic  Context  
16. The New Zealand biosecurity system is regulated through the Act. Section 22 of the 
Act describes an IHS and requires all risk goods (including plants and plant products) 
entering New Zealand to be covered by an IHS . 
17. MPI is the government authority responsi ble for maintaining biosecurity standards for 
the effective management of risks associated with the importation of risk goods into 
New Zealand (Part 3  of the Act).  
18. MPI is committed to the principles of transparency and evidence- based technical 
justificatio n for all phytosanitary measures, new and amended, imposed on importing 
pathways.   
Proposed Changes  
19. MPI proposes  to revoke the existing IHS and replace it with separate IHSs for the 
importation of truffles for consumption and for propagation.  
20. The proposed  separate I HS are: Fresh and Frozen T ruffles for Consumption:  
MPI. IHS.FP.TRUFFLES and Truffles for Propagation: MPI. IHS.TUBER  
Inclusion of A dditional Pests   
21. Plant Imports regularly receive permit applications for the import of fresh truffle s for 
consumption from Australia .  
22. The pest list for Tuber  included Northern hemisphere beetle and fly pests. Additional 
earth -borer beetles  which are present in Australia and are known to be associated with 
truffles there have been added to the pest list:  these include species in the  Bolborhachium  
and Blackbolbus  genera.  
23. These beetles feed on truffle s and are known to deposit their eggs in the soil. They lay 
relatively large eggs (Houston 2011) which are visible to the naked eye. These pests are 
managed by the existing measures; namely washing and inspection for freedom from 
soil and pest infestation.   
Pre export M orphological Examination  
24. Pre export m orphological examination of every truffle  is required to ensure only 
eligible species are sent  to New Zealand.  Examination must be completed by 
experienced truffle  personnel.  
25. A report of  morphological examination must accompany each consignment and be 
presented on arrival in New Zealand . The report needs to  state the species present in 
the consignm ent as well as provide the MPI import permit number  to enable the MPI 
Inspector to cross -reference the various documents . 
26. Any consignments without correct documentation will be directed to the facility stated 
on the import permit, until correct documentation is presented.  
Molecular Testing  Requirements  
27. Molecular testing to species level is important for truffle imported for propagation, to 
ensure only eligible species are imported and  cultivated in New Zealand. The 
requirement for molecular testing of truffles for propagation are unchanged in the 
proposed IHS: Truffles for Propagation: MPI. IHS.TUBER .  
  
28. For truffle imported for consumption, the accuracy of species level identification is  less 
critical.  Buyers and consumers want to know  that they are getting the truffles they have 
paid for , but this is a market and quality/price issue  and outside the purposes of t he 
Biosecurity Act 1993.   
29. MPI considers that  morphological examination of truffles is suff icient for a consumable 
product and proposes removing the requirement for molecular testing of truffle imported 
for consumption in the proposed IHS : Fresh and Frozen Truffles for Consumption: 
MPI. IHS.FP.TRUFFLE .  
30. It is illegal to use plant products imported under an IHS for a purpose not stated in that 
IHS. Penalties may be applied under the Act to persons found to be propagating 
inoculated -trees from truffles imported for consumption.  
Onshore A udit Testing  
31. MPI reserves the right to conduct audit testing of truffles  for consumption to confirm 
that the species matches that which is stated on the phytosanitary certificate.  
32. Consignments selected for species identification will be directed to a diagnostic 
labora tory in New Zealand  for molecular testing . The importer will be responsible for 
all costs incurred.  
33. Once the consignment arrives at the diagnostic laboratory, on e or more truffles  will be 
randomly selected from each species in the consignment and a small slice taken.  
34. Provide d all other requirements of the  IHS have been met, t he remainder of the 
consignment (including the selected truffles ) may be given biosecurity clearance on the 
same day and released to the importer .  
35. Testing r esults will be provided to the importer and MPI Plant Imports to confirm 
species identity.  If non -eligible truffles  species are detected , further permit applications 
from th e offshore supplier may be declined.  
36. Proposed changes to requi rements are detailed in the IHS: Fresh and Frozen Truffles 
for Consumption: MPI. IHS.FP.TRUFFLE Part 3.3: Species validation.  
Import Permit  
37. Import permits are required for all consignments of truffles imported under both 
proposed IHS. Applications for permits must include details of the offshore supplier 
and the name of the plantation where the truffles were sourced.  
38. MPI reserves the right to request further information regarding source of the truffles.  
References  
Balance in Trade [o nline reference ISBN 978 -0-478-33881- 2] 
Houston, T. F. 2011. Egg gigantism in some Australian earth -borer beetles (Coleoptera: 
Geotrupidae: Bolboceratinae) and its apparent association with reduction or elimination of 
larval feeding. Australian Journal of Entomology 50: 164–173.