Risk Management Proposal   
Irradiation as a p hytosanitary measure for the management of 
Tephritid  fruit flies  on fresh melon ( Cucumis melo ), scallopini 
(Cucurbita pepo ), strawberry ( Fragaria sp.), and zucchini ( Cucurbita 
pepo ) from Australia .  
 
 
 
 
Prepared for public consultation  
by Horticulture Imports  
 
 
 
 
 
 
16 February 2021 . 
  
 
 
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   RMP:  Draft - Phytosanitary measures for Fruit flies on melon, scallopini, strawberry and zucchini  • 1 Contents  Page 
 
Submissions  2 
1 Purpose  4 
2 Scope  4 
3 Part 1: Background  5 
4 Part 2: Context  7 
4.1 Domestic  7 
4.2 International  7 
4.3 New Zealand’s Biosecurity System  7 
4.4 Equivalence  8 
5 Part 3: Assessment  8 
5.1 Assessment of risk  8 
5.2 Assessment of risk management  9 
5.3 Feasibility and practicality of measures  9 
5.4 Summary  9 
6 References  11 
  
2 • RMP: Draft - Phytosanitary measures for Fruit flies  on scallopini, strawberry and zucchini  Ministry for Primary Industries  Submissions  
The Ministry for Primary Industries (MPI) invites comment from interested parties on the proposed 
amendment to the Import Health Standard (IHS) 152.02 : Importation and Clearance of  Fresh Fruit and 
Vegetables into New Zealand  as well as the specific IHS for  fresh melon ( Cucumis melo ) and fresh 
zucchini ( Cucurbita pepo ) from Australia which is supported by this Risk Management Proposal.  
 
An IHS “specifies requirements to be met for the effective management of risks associated with 
importing risk goods, inclu ding risks arising because importing the goods involves or might involve an 
incidentally imported new organism” (section 22(1) Biosecurity Act 1993).  
 
MPI therefore seeks comment on the proposed amendments to the  import requirements for fresh melon, 
scallopini, strawberry and zucchini from Australia for the management of fruit flies . MPI has developed 
this proposal based on assessment of the available scientific evidence.  
 
The following points may be of assistance in preparing comments:  
• Wherever possible, comments should be specific to a particular change in IHS requirements 
or a question asked in this document (referencing section numbers or commodity names as 
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 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 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 29 March 2021 . 
Plant Imports  
Animal and Plant Health  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Submissions received by the closure date will be considered during the amendment of the affected 
import health standards (IHS) which are as follows:  
• Import Health Standard 152.02: Importation and Clearance of Fresh Fruit and Vegetables into 
New Zealand ; and, 
• Import Health Standard Commodity Sub -class: Fresh Fruit/Vegetables Melon, Cucumis melo  
from Australia ; and,   
Ministry for Primary Industries   RMP:  Draft - Phytosanitary measures for Fruit flies on melon, scallopini, strawberry and zucchini  • 3 • Import Health Standard Commodity Sub -class: Fresh Fruit/Vegetables Zucchini, Cucurbita 
pepo  from Australia .  
 
Submissions received after the clo sure date may be held on file for consideration when the issued IHS 
are 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 the information is commercially sensitive , or 
they wish their personal information to be withheld.  
 
Any decision to withhold information requested under the OIA is reviewable by the Ombudsman .  
4 • RMP: Draft - Phytosanitary measures for Fruit flies  on scallopini, strawberry and zucchini  Ministry for Primary Industries  1 Purpose  
1. The purpose of this risk management proposal (RMP) is to:  
a. Summarise the known biosecurity risk associated with Tephritid  fruit flies on fresh 
melon  (rock melon and honeydew melon)  (Cucumis melo ), scallopini  (Cucurbita pepo ), 
strawberry  (Fragaria sp ), and zucchini  (Cucurbita pepo ) from Australia;  
b. Outline the proposed amendments to the import requirements for fresh melon, 
scallopini, strawberry  and zucchini  from Australia for the management of fruit flies ;  
c. Explain how the  proposed  phytosanitary measure ( irradiation ) manage s risk and is 
consistent with New Zealand’s domestic legislation and international obligations; and,  
d. Seek stakeholder feedback on the proposed amendment to the import requirements for 
the fresh melon, scallopini, strawberry  and zucchini  from Australia.  
   
2 Scope  
2. This RMP lists the information and processes used to assess:  
a. Whether  irradiation as  the proposed phytosanitary measure sufficiently manages the 
risk of Tephritid fruit flies on fresh melon, scallopini, strawberry a nd zucchini from 
Australia .  
3. The draft amendment to the IHS is the subject of consultation under section 23(3) of the 
Biosecurity Act (1993). This RMP provides information to support the consultation on the IHS 
amendment but is not itself the subject of consultation. However, MPI will accept comments and 
suggestions on the RMP in order to improve futu re IHS consultations.  
4. The RMP is divided into 3 parts:  
a. Part 1 provides background information on currently approved phytosanitary measures 
to manage the risk of Tephritid fruit flies on fresh melon, scallopini, strawberry and 
zucchini.  
b. Part 2 outlines the context for considering irradiation as an effective  phytosanitary 
measure.  
c. Part 3 outlines  the risk of  Tephritid  fruit flies  on fres h melon,  scallopini,  strawberry  and 
zucchini  from Australia, and the suitability of irradiation  to effectively manage this r isk.  
   
Ministry for Primary Industries   RMP:  Draft - Phytosanitary measures for Fruit flies on melon, scallopini, strawberry and zucchini  • 5 3 Part 1: Background  
 
5. Tephritid f ruit fl ies are a pest of concern on  fresh melon, scallopini, strawberry  and zucchini 
from Australia.  
6. The current options to manage the risk of Tephritid fruit flies on fresh melon, scallopini, 
strawberry and zucchini from Australia are documented in : 
a. IHS 152.02 : Importation and Clearance of Fresh Fruit and Vegetables into New 
Zealand ; 
b. IHS Commodity Sub -class: Fresh Fruit/Vegetables Melon, Cucumis melo  from 
Australia;  
c. IHS Commodity Sub -class: Fresh Fruit/Veget ables Zucchini ( Cucurbita pepo ) from 
Australia; and  
d. Export Plan for Fresh Produce from Australia to New Zealand.1 
7. The Export Plan for Fresh Produce from Australia to New Zealand (hereafter “Export Plan”) will 
take effect on 25 February 2021. On this date, the Export Plan will supersede  the previous 
bilateral arrangement, the Australia -New Zealand Bilateral Quarantine Arrangement Systems 
Operation Manual 6E  (hereafter “BQA”) .  
8. Within the IHSs  listed above , references to the BQA have been intentionally retained. MPI and 
the Australian Department of Agriculture, Water and the Environment (DAWE) have agreed in 
the Export Plan  that: 
a. where a BQA is referenced in an IHS for fresh fruits or vegetables from Australi a, the 
Export Plan will be considered equivalent ; and,   
b. the use of numbered appendices to describe treatment pathways will continue to be 
used in additional declarations.  
9. The options  in the Export Plan  to manage the risk of Tephritid fruit flies on  specific commodities  
are listed in the table below : 
 
Commodity  Pest Current options to manage  the 
specified  fruit fl y species  
Melon  Bactrocera cucumis  
Ceratitis capitata  Rockmelons  
• Pest free area  
OR 
• Dimethoate Dip/Spray  
Dipped or flood sprayed 
in Dimethoate at 400ppm 
active ingredient for 1 
minute )  
OR 
• Field Control 
Programmes   
AND  
Winter Window  (1 May till 
1 September)  
 
Honeydew melons  
• Pest free area  
OR 
 
1 An Export Plan is a bilateral arrangement between MPI and a trading partner which describes the activities that will be 
undertaken to meet the phytosanitary requirements for the export of fresh fruit and vegetables for consumption from Australia  to 
New Zealand .  
6 • RMP: Draft - Phytosanitary measures for Fruit flies  on scallopini, strawberry and zucchini  Ministry for Primary Industries  • Dimethoate Dip/Spray  
(Dipped or flood sprayed 
in Dimethoate at 40 0ppm 
active ingredient for 1 
minute )  
AND  
• Field Control 
Programmes   
AND  
Winter Window  (1 May till 
1 September)  
 
Scallopini  Bactrocera cucumis  
Ceratitis capitata  • Pest free area  
OR 
• Field Control 
Programmes  
AND  
Winter Window  (1 May till 
1 September)  
OR 
• Dimethoate Dip/Spray  
(Dipped or flood sprayed 
in Dimethoate at 400ppm 
active ingredient for 1 
minute ) 
Strawberry  Bactrocera 
neohumeralis  
Bactrocera tryoni  
Ceratitis capitata  • Pest free area  
OR 
• Methyl Bromide 
Fumigation  (48 g/m³ for 3 
hrs at a flesh temperature 
>15ºC at a loading of not 
greater than 50% 
chamber capacity ) 
 
Zucchini  Bactrocera cucumis  
Ceratitis capitata  • Pest free area  
OR 
• Field Control 
Programmes  
AND  
Winter Window  (1 May till 
1 September)  
OR 
• Dimethoate Dip/Spray  
(Dipped or flood sprayed 
in Dimethoate at 400ppm 
active ingredient for 1 
minute ). 
 
 
10. The Australian Department of Agriculture , Water and the Environment  have requested that MPI 
recognise irradiation as a n equivalent  phytosanitary treatment option for the management of 
Tephritid fruit flies  on fresh melon, scallopini, strawberry and zucchini. Irradiation treatment 
would be established in accordance with ISPM 28 Annex 7: Irradiation treatment for fruit flies of  
Ministry for Primary Industries   RMP:  Draft - Phytosanitary measures for Fruit flies on melon, scallopini, strawberry and zucchini  • 7 the family Tephritidae (generic)  at the rate of 150 gray  (GY) . The application of irradiation as a 
phytosanitary measure will be applied according to the guidelines  for irradiation in Codex/ 
ASTM and  ISPM 18: Guidelines for the use of irradiation as a phytosanitary measure.  
4 Part 2: Context  
4.1 DOMESTIC  
11. The New Zealand biosecurity system is regulated through the Biosecurity Act 1993. 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 importi ng risk goods (including 
plants and plant products) into New Zealand.  
12. The Ministry for Primary Industries (MPI) is the government authority responsible for the 
effective management of risks associated with the importation of risk goods into New Zealand 
(Part 3, Biosecurity Act 1993).  
13. MPI engages with interested parties and/or affected New Zealand stakeholders, and the 
exporting country requesting market access, during the development of an IHS.  
14. MPI follows MPI policies and procedures for the development and  consultation of an IHS.  
4.2 INTERNATIONAL  
15. Where possible, phytosanitary measures are aligned with international standards, guidelines, 
and recommendations as per New Zealand’s obligations under Article 3.1 of the World Trade 
Organisation (WTO) Agreement on t he Application of Sanitary and Phytosanitary Measures 
(SPS Agreement), WTO 1995 and section 23(4)(c) of the Biosecurity Act 1993.  
16. The SPS Agreement states that phytosanitary measures must not discriminate unfairly between 
countries or between imported or d omestically produced goods, and where there is a choice of 
phytosanitary measures to reduce risk to an acceptable level, WTO members must select the 
least trade restrictive measure.  
17. Setting the least trade restrictive measure to manage risk to an acceptabl e level in an IHS 
includes evaluating alternative or equivalent measures as requested by trading partners (Article 
4 SPS Agreement).  
 
4.3 NEW ZEALAND’S BIOSECURITY SYSTEM  
18. New Zealand operates a biosecurity system for which the phytosanitary aspect (covering plant 
health) is a key part.  
19. No biosecurity system can reduce  risk to zero. The objective of the system is to reduce the 
likelihood of entry and establishment of regulated organisms (including pests, diseases and 
weeds) to an acceptable level.  
20. An organism is ‘regulated’ by MPI if it could cause unacceptable consequences (i.e. likely to 
cause unacceptable economic, environmental, socio -cultural or human health impacts) if it were 
to enter and establish in New Zealand, provided the following conditi ons are met:  
a. it is not present in New Zealand; or  
b. it is present but under official control in New Zealand;  
c. it can establish and spread in New Zealand.  
- Entry and establishment are defined as ‘introduction’ by the International Plant Protection Convention 
(IPPC).   
8 • RMP: Draft - Phytosanitary measures for Fruit flies  on scallopini, strawberry and zucchini  Ministry for Primary Industries  21. The New Zealand phytosanitary system focuses on ensuring that the most significant pests, for 
example economically important fruit flies, are unlikely to ever establish in New Zealand. The 
system also manages risk associated with all regulated pests.  
22. The focus of the IHS for plant -based goods is to, wherever possible, manage unacceptable 
phytosanitary risks identified as being associated with the goods before arrival/clearan ce at the 
New Zealand border. The expectation is that commercial consignments of plants and plant 
products meet New Zealand’s phytosanitary import requirements on arrival (risk is managed 
offshore ). 
23. MPI monitors the pathway performance related to each IHS to ensure it provides the expected 
level of protection. This is achieved through verification and inspection activities at the border 
(and where possible, identification of pests detected) and audits of the export systems and 
critical control points contai ned in government -government arrangements (e.g. Bilateral 
Quarantine Arrangement, Export Plan, etc.).  
4.4 EQUIVALENCE  
24. For a phytosanitary measure to be approved by MPI as equivalent it must offer the same or 
greater level of protection to what it is replacing or is currently in place.  
25. The assessment of any equivalence request is based on:  
a. international standards for phyt osanitary measures (ISPMs); for example:  
i. ISPM 24. Guidelines for the determination and recognition of equivalence of 
phytosanitary measures ; 
b. efficacy data relating to a treatment;  
c. the target pest(s); and,  
d. other relevant information (e.g. history of trade ).  
26. MPI must ensure that any measure approved is consistent with the Biosecurity Act 1993 and, 
the Sanitary and Phytosanitary Measures (SPS) agreement with regard to scientific justification, 
non-discrimination and offer transparency in assessment processe s and decisions.  
5 Part 3: Assessment  
27. The proposed irradiation rate of 150 Gy align s with ISPM 28; Annex 07 Irradiation treatment for 
fruit flies of the family Tephritidae (generic) .  Part 3 discusses the  risk of Tephritid fruit flies on 
fresh melon, scallopini, strawberry and zucchini from Australia  and the  suitability of irritation to 
manage this risk.  
5.1 ASSESSMENT OF RISK  
28. Fruit fly species in the family Tephritidae, namely the target species Ceratitis capitata, 
Bactrocera cucumis , B. neohumeralis  and B. tryoni , are pests of concern on fresh melon, 
scallopini, strawberry and zucchini from Australia because:  
 
a. They are present in Au stralia and are associated with the commodities ( MPI, 2020).  
b. They are not known to be present in New Zealand . New Zealand has country freedom 
for all fruit flies of economic significance (MPI , 2020).  
c. The target species are polyphagous or highly polyphago us and there are suitable 
breeding hosts present in New Zealand ( MPI, 2020).  
d. The target species are likely to be able to establish at least in the warmer parts of New 
Zealand, except B. neohumeralis  which may only form temporary populations (MPI, 
2020).   
Ministry for Primary Industries   RMP:  Draft - Phytosanitary measures for Fruit flies on melon, scallopini, strawberry and zucchini  • 9 e. The impacts of establishment of the target species are likely to be high to severe. Even 
a temporary incursion is likely to be associated with significant impacts caused by trade 
barriers and eradication costs (MPI, 2020).  
 
29. Measures are justified  to manage the biosecurity risk of  fruit flies of  the Tephritidae family on 
the fresh melon, scallopini, strawberry, zucchini from Australia pathways because:   
 
a. It is possible  that fruit infested with fruit fly can enter New Zealand, if there are no 
phytos anitary measures in place to manage the risk offshore.  
i. The fruit fly life stages that are most likely to enter New Zealand with imported 
fresh fruit are eggs and/or larvae. Eggs are laid under the fruit skin and may be 
inconspicuous. Larvae feed within the  fruit and may not be detected during 
phytosanitary inspection (MPI, 2020).  
ii. Larvae and eggs may survive cool storage and transit to New Zealand, as 
evidenced by New Zealand and international border detections of fruit flies on 
fresh produce (MPI, 2020).  
 
b. Fruit flies have the potential to establish and spread in New Zealand . 
i. Infested fruit is likely to be disposed of. Most fresh produce is disposed of in 
low risk ways, but some is disposed of ways that would allow adult flies to 
emerge from infested fruit in New Zealand, e.g. in home composts (MPI, 2020).  
ii. Potential host plants are available throughout New Zealand in production 
areas, home gardens and the wider environment (MPI, 2020).  
iii. Some areas of New Zealand would provide suitable environmental conditions 
for the target species to successfully form tempor ary or permanent populations 
(MPI, 2020).  
 
c. The presence and  establishment of Tephritid  fruit flies would have a significant impact 
on the economy .  
i. Fruit flies have the potential to cause economic impacts by directly damaging 
horticultural crops that are s ignificant to New Zealand and by requiring costly 
control measures (MPI, 2020).  
ii. Importing countries may impose additional phytosanitary measures on New 
Zealand fresh produce to obtain assurance that exported produce is free from 
fruit flies (MPI, 2020).  
iii. The financial impact of a fruit fly incursion into New Zealand is likely to be high 
to severe. Many horticultural commodities are at risk:  
1. In 2019, Apple exports alone were worth $820 million . Combined , fresh 
produce export s totalled  $6.2 billion (New Zealan d Horticulture, 2019).  
2. Kiwifruit Vine Health (2020) estimated that an incursion of Q ueensland 
fruit fly could cause losses to the kiwifruit industry of between $2 
million and $430 million, depending on the circumstances.  
5.2 ASSESSMENT OF RISK MANAGEMENT  
 
30. Irradiation at 150 Gy manages the risk of Tephritid fruit flies on imported fresh melon, scallopini, 
strawberry and zucchini from Australia because:  
a. ISPM 2 8; Annex 07 ‘Irradiation treatment for fruit flies of the family Tephritidae 
(generic)’  states that irradiation of fruit and vegetables at 150 Gy minimum absorbed 
dose prevent s the emergence of adult fruit flies at the stated efficacy.  
i. There is 95% confidence that this treatment would prevent the emergence of 
not less than 99.9968% of adult fr uit flies.   
10 • RMP: Draft - Phytosanitary measures for Fruit flies  on scallopini, strawberry and zucchini  Ministry for Primary Industries  ii. Irradiation may not cause out right mortality of fruit flies. Live but non -viable 
larvae and/or pupae may be encountered during inspection. This does not 
imply a failure of the treatment.  
 
b. Irradiation at 150 Gy exceeds the species -specific irra diation rate of 100 Gy specified 
for B. tryoni  (ISPM 28; Annex 05) and C. capitata (ISPM 28; Annex 14) . 
31. The treatment should be applied in accordance with the requirements of ISPM 18; Guidelines 
for the use of irradiation as a phytosanitary measure . This will be captured in the Australian 
export plan which is subject to audit.  
 
5.3 FEASIBILITY AND PRACTICALITY OF MEASURES  
32. Irradiation is currently an approved measure for the export of capsicum, lychee, mangoes, 
tomatoes, papaya/pawpaw and table grapes from Australia  for management of  Tephritid  fruit 
flies. 
33. The irradiation facilit ies, managed by Steritech, are currently certified by DAW E as compliant 
with international and Australian domestic requirements. The irradiation plant s are  located in 
Brisbane and  Melbourne  are used to treat for export to other international destinations.  
5.4 SUMMA RY 
34. MPI considers irradiation at 150 Gy to effectively manage the risk of Bactrocera cucumis, 
Ceratitis capitata, Bactrocera tryoni and Bactrocera neohumeralis  on fresh melon, scallopini, 
strawberry and zucchini  imported  from Australia.  
35. MPI proposes  that the following IHSs are amended to include irradiation  at 150 Gy as a 
phytosanitary  measure  to manage Tephritid fruit flies  on fresh melon, scallopini, strawberry and 
zucchini from Australia : 
a. Import Health Standard 152.02: Importation and Clearance of Fresh Fruit and 
Vegetables into New Zealand ; and,  
b. Import Health Standard Commodity Sub -class: Fresh Fruit/Vegetables Melon, Cucumis 
melo  from Australia; and , 
c. Import Health Standard Commodity Sub -class: Fresh Fruit/Vegetables Zucchini, 
Cucurbita pepo  from A ustralia.  
36. All measures contained in IHS s are subject to regular review based on pathway compliance, 
emerging risk assessment, new information/intelligence, and results of audit of the Export Plan 
or other bilateral agreement.  
37. MPI monitors interceptions of all regulated pests (and hitchhikers) and the appropriateness/ 
effectiveness of phytosanitary measures during trade.  
 
6 References  
 
Kiwifruit Vine Health (KVH), 2020. Fruit flies. Retrieved August 30, 2020, from https://kvh.org.nz/fruitflies.  
 
International Standard for Phytosanitary Measures (ISPM) 18. 2019. Guidelines for the use of irradiation as a 
phytosanitary measure . Rome, IPPC, FAO.  
 
International Standard for Phytosanitary Measures (ISPM) 28, Annex 5. 2009. Irradiation treatment for Bactrocera 
tryoni . Rome, IPPC, FAO.  
  
Ministry for Primary Industries   RMP:  Draft - Phytosanitary measures for Fruit flies on melon, scallopini, strawberry and zucchini  • 11 International Standard for Phytosanitary Measures (ISPM) 28, Annex 7. 2009 a. Irradiation treatment for fruit flies 
of the family Tephritidae (generic) . Rome, IPPC, FAO.  
 
International Standard for Phytosanitary Measures (ISPM) 28, Annex 14. 2011. I rradiation treatment for Ceratitis 
capitata (2011) . Rome, IPPC, FAO . 
 
Ministry for Primary Industries (MPI), 2018. Import Health Standard 152.02: Importation and Clearance of Fresh 
Fruit and Vegetables into New Zealand . Wellington, New Zealand.  
 
Ministry for Primary Industries (MPI), 2018a. Import Health Standard Commodity Sub -class: Fresh 
Fruit/Vegetables Melon, Cucumis melo  from Australia . Wellington, New Zealand.  
 
Ministry for Primary Industries (MPI), 2018b. Import Health Standard Commodity Su b-class: Fresh 
Fruit/Vegetables Zucchini, Cucurbita pepo  from Australia . Wellington, New Zealand.  
 
Ministry for Primary Industries (MPI), 2019. Export plan for fresh produce from Australia to New Zealand . 
Wellington, New Zealand.  
 
Ministry for Primary Indu stries (MPI), 2019 a. EPest. Retrieved August 04, 2020, from 
https://www.mpi.govt.nz/importing/food/fresh -fruit-and-vegetables/requirements/epest/  
 
Ministry for Primary Industries (MPI), 20 20. Technical advice : Assessment of risk of tephritid fruit flies on fresh 
melon (Cucumis melo), scallopini (Cucurbita pepo), strawberry (Fragaria sp.) and zucchini (Cucurbita pepo) from 
Australia . Wellington, New Z ealand   
 
New Zealand Horticulture, 2019. Fresh Facts. Retrieved August 30,2020, from 
https://www.freshfacts.co.nz/files/freshfacts -2019.pdf