1  Ministry of Agriculture & Forestry                                                                                                                   Risk Management Proposal:   
  
Risk Management Proposal: 
 
Rubus  spp. Seed for sowing  
from all countries 
 
 
 
 
 
  
 
 
Date July 2011 
 
 
 
 
Plant & Plant Product Imports 
Import & Export Standards Directorate 
Ministry of Agriculture & Forestry 
Pastoral House 
25 The Terrace 
PO Box 2526 
Wellington 6011 
New Zealand 
  
Tel: +64 4 894 5541 
Fax: +64 4 894 0662 
Email: plantimports@maf.govt.nz
 
    
 
                                                                                                                                                                             Rubus  spp. Seed for Sowing
 
 2  Ministry of Agriculture and Forestry                                                                                                              Risk Management Proposal:  
                                                                                                                                                                            Rubus  spp. Seed for Sowing 
 
Purpose 
The purpose of this document is to:  
 summarise the biosecurity risks associated with Rubus spp. seed for sowing stock from all 
countries;  
 recommend measures for the effectiv e management of these risks; and, 
 seek stakeholder feedback on the proposed ma nagement options and import requirements 
as outlined in the draft import health standard schedule.  
 
This import health standard (IHS) schedule ha s been developed in accordance with Section 22 
of the Biosecurity Act (1993).   
Background 
A 2009 review of the import requirements for Rubus spp. nursery stock and the development 
of the MAF Post Entry Quarantine Testing Manual have identified a number of gaps in the current Rubus idaeus seed for sowing import health standard schedule.  
 The scope of the IHS has been extended to include all species of Rubus  approved for import 
into New Zealand; to update the Rubus  testing schedule and to in clude specific measures to 
manage the risks. 
Objective 
The objective is to effectively manage bi osecurity risks posed by the importation of Rubus 
spp. seed for sowing, in a way that is consiste nt with New Zealand’s domestic legislation and 
international obligations.  
Analysis 
This analysis draws on the significant body of  information that already exists for Rubus  spp., 
which includes: 
 the seed for sowing IHS schedule for Rubus idaeus, under the IHS                          
155.02.05: Importation of Seed for Sowing      
 the nursery stock IHS schedule for Rubus  (under the IHS                                           
155.02.06: Importation of Nursery Stock ; 
 the MAF Post-Entry Quarantine Testing Manual for Rubus  (Raspberries, Blackberries and 
Hybridberries)  
1. COMMODITY DESCRIPTION  
The IHS will cover all the approved species of Rubus seed for sowing as listed on the MAF 
Plants Biosecurity Index  imported into New Zealand for the purpose of propagation. 
Under the current and proposed updated IHS, Rubus  seeds are not eligible for biosecurity 
clearance on arrival in New Zealand.  S eeds are imported into MAF-approved post entry 
quarantine facility, where they are germinated  and the resulting daughter plants are grown. 
Only daughter plants are eligib le for biosecurity clearance. 
2. REGULATED ORGANISMS REQUIRING MANAGEMENT 
The regulated organisms associated with Rubus seed for sowing are considered to be a subset 
of those identified in association with Rubus  spp. nursery stock.  Organisms that are seed  
 
 
3  Ministry of Agriculture & Forestry                                                                                                                   Risk Management Proposal:  
                                                                                                                                                                             Rubus  spp. Seed for Sowing
 
 transmitted were identified during the developm ent of the Post Entry Quarantine Testing 
Manual for Rubus. 
2.1 Viruses 
The curren
t seed for sowing IHS identifies Tomato black ring virus  and Tomato ringspot virus 
as regulated.  MAF considers that Raspberry ringspot virus  is also a risk associated with 
imported Rubus spp. seed for sowing 
2.1.1  Raspberry ringspot virus   
Raspberry ringspot virus (RpRSV) can be vectored by soil nematodes in the genus Longidorus (one 
species of which – Longidorus elongatus is present in New Zealand).  This virus can also be transmitted 
through infected seed (Lister and Murant, 1967). The host range for RpRSV is much wider than Rubus , 
and includes other economically important crops, e.g. Fragaria, Prunus, Vitis, and Ribes (DPV, access 
date Feb 2011). 
 
RpRSV has a host range wider than Rubus , and is included in the seed for sowing schedules for 
Fragaria  and Ribes, and also in the nursery stock schedules for Fragaria, Prunus, and Vitis. 
 
2.1.2 Tomato black ring virus 
Tomato black ring virus (TBRV)  has two known soil nematode  vectors – Longidorus attentuatus and 
Longidorus elongatus (the latter of which is present in New Zealand), as well as being spread through 
infected seed (Lister and Murant, 1967).  Th e host range for TBRV is much wider than Rubus  and 
includes other economically important crops, e.g.  Prunus, Allium, Fragaria, Ribes, Vitis , and 
Phaseolus (DPV, access date Feb 2011) . 
 TBRV has a host range wider than Rubus seed, and is included in the seed for sowing schedules for 
Fragaria  and Phaseolus , and also in the nursery stock schedules for Fragaria, Allium,  Prunus , and 
Tulipa . 
 
2.1.3 
Tomato ringspot virus 
Tomato ringspot virus (ToRSV) can be vectored by nematodes in the genus Xiphinema (six species are 
present in New Zealand), as well as  transmitted through infected seed (Lister and Murant, 1967). The 
host range for ToRSV is wider than Rubus , and includes other economically important crops, e.g. 
Fragaria , Prunus , Malus , Vaccinium , and Solanum lycopersicum (DPV, access date Feb 2011).  
 Some strains of ToRSV are pr esent in New Zealand. Howe ver, the strain infecting Rubus  has not been 
detected in New Zealand. ToRSV  has a host range wider than Rubus , and is included in the seed for 
sowing schedules for Fragaria and Vaccinium , and also in the nursery stock schedules for Fragaria, 
Lilium , Prunus , Rubus , Tulipa , and Vaccinium . 
 
The proposed specific management steps for th ese regulated organisms and diseases are 
discussed in section 4. 
3. MANAGEMENT OF RISK 
All seed for sowing imported into New Zeala nd must undergo a number of steps to ensure 
that the risk of regulated organisms is redu ced to an acceptable leve l. Table 1 provides a 
summary of the mitigation and verification steps that Rubus  spp. seed for sowing must go 
through to ensure freedom from regulated pests and disease.  
 
All Rubus seed for sowing imported into New Zealand must be imported under a permit to 
import, issued by MAF under the import health standard 155.02.05:  Importation of Seed for 
Sowing. The permit to import is used to facilita te the import of the material, and details the 
specific import requirements fo r the particular consignment. 
 4  Ministry of Agriculture and Forestry                                                                                                              Risk Management Proposal:  
                                                                                                                                                                            Rubus  spp. Seed for SowingTable 1. Summary of mitigati on and verification steps for  Rubus  seed for sowing  
Step Target organisms Description of measures Related documents 
Pre-export 
phytosanitary 
inspection All  Prior to issuing a phytosanitary certificate, the exporting National Plant Protection Organisation 
(NPPO) must inspect the seed in accordance with appropriate official procedures for freedom from visually detectable regulated pests, and to ensure 
the consignment conforms to New Zealand’s import 
requirements.  155.02.05:  Importation 
of Seed for Sowing  
 International Standards 
for Phytosanitary 
Measures  ISPM 12. 
Guidelines for 
phytosanitary 
certificates (2001)  
On arrival verification/ 
inspection All  A 5kg sample (or the whole consignment if less than 5kg) is inspected to verify compliance with the import 
requirements, and to achieve a 95% confidence level for freedom from visually detectable regulated pests.  155.02.05:  Importation 
of Seed for Sowing  
 MAF Border Clearance 
Procedures (internal 
MAF document) 
Post entry 
quarantine 
(PEQ) All  The seed must be germinated, and the resulting 
daughter plants actively growing in a level two PEQ 
greenhouse for a minimum growing period of three 
months. 
 The minimum three month PEQ period is required for 
the completion of all serological, molecular and 
herbaceous indicator testing, which must be carried 
out on plants which are in active growth. 
 Plants undergo growing season inspection for visual 
symptoms of disease expression, and testing for 
pests and diseases of significant biosecurity concern.   MAF operational 
standard 
PBC.NZ.TRA.PQCON: 
Specification for the 
Registration of a Plant 
Quarantine or 
Containment Facility, 
and Operator  
 155.02.05:  Importation 
of Seed for Sowing  
 MAF Operational 
Standard 155.04.03: 
Diagnostic Facilities 
which undertake the 
identification or new 
organisms, excluding 
animal pathogens  
 MAF Post-Entry 
Quarantine Testing 
Manual for Rubus  
(Raspberries, 
Blackberries and 
Hybridberries)   
 Border Clearance Procedures 
3.1 Pre-export phytosanitary inspection and certification 
The exporting National Plant Pr otection Organisation (NPPO) inspects the consignment to 
confirm that it meets New Zealand’s import re quirements. The exporting NPPO must verify 
the following pre-export activities have been completed: 
 The seed for sowing is inspected in accordan ce with appropriate official procedures 
are is found to be free from visually dete ctable regulated pests and diseases  
 
Where the exporting NPPO has verified that th e consignment is compliant with the import 
requirements and no visually detectable regula ted pests and disease ha ve been identified, a 
phytosanitary certificate is issue d. Following certification, the seed  must be held in a manner 
to prevent infestation/reinfestation with regulated pests and diseases. 
3.2 On arrival verificati on of pre-export measures 
On arrival in New Zealand, the MAF inspector will inspect the consi gnm
ent to verify the 
required pre-export measures have been met. This verification include s the following steps: 
 Inspection of the phytosanitary certificate and permit to im port to ensure compliance 
with the import requirements  
 
 
5  Ministry of Agriculture & Forestry                                                                                                                   Risk Management Proposal:  
                                                                                                                                                                             Rubus  spp. Seed for Sowing
 
  Inspection of a 5kg sample (or the whole sample if under 5kg) to achieve a 95% 
confidence level for freedom from visually detectable regulated pests. 
  Where the MAF inspector has verified that th e consignment is compliant, the inspector will 
authorise movement of the seed to post entry quarantine. 
3.3 Post entry quarantine 
All Rubus  seed for sowing im
ported enters a post en try quarantine (PEQ) facility on arrival in 
New Zealand and are germinated.  The resul ting daughter plants unde rgo a period of post 
entry quarantine to ensure freedom from regulated pests and diseases. 
 
It is proposed that the material  shall enter a Level 2 post entry quarantine facility. A minimum 
growing period of three months is proposed  as the time required allowing the imported 
material to undergo serological, molecu lar, and herbaceous indicator testing. 
 The three month growing period will begin once the germinated seeds have two fully 
expanded leaves. 
3.3.1 Growing season inspection 
Material must undergo regular growing season inspections by a MAF Biosecurity Inspector, 
to ensure freedom from visually  detectable regulate d pests. Where visibl e signs of pests and 
disease are detected, samples may be co llected and sent for diagnostic testing. 
 The operator of the post entry quarantine facility is also expected to undertake regular 
inspections of the plants dur ing the growing season, and to notify the MAF Biosecurity 
Inspector if pest or dise ase symptoms are observed. 
3.3.2 Testing for regulated organisms of significant biosecurity concern 
Pests and diseases of significant concern require  specific mitigation measures to ensure they 
do not enter and establish in New Zealand.   The following specific tests may be appropriate to detect regulated viruses: 
 Biological tests: he rbaceous indexing 
 Molecular tests: polymera se chain reaction (PCR) 
 Serological tests: enzyme linked immunosorbent assay (ELISA) 
 For viruses the proposed testing requirements are based on the level of biosecurity risk 
associated with the organism. Due to the potentia l biosecurity risk posed by some organisms, 
a combination of testing methods is proposed.  With prior approval from MAF, internationally accepted testing methods will be accepted as equivalent to the requirements of the import health standard.  The Post Entry Quarantine Testing Manual for Rubus  describes appropriate testing protocols 
for each of the proposed tests. 
3.4 Non-compliance 
Im
ported seed or daughter plants in PEQ (d erived from imported seed) which are not 
compliant with the import requirements will not be eligible for biosecurity clearance. Where 
the inspector identifies that the seed consignm ent is not compliant, the importer will be given 6  Ministry of Agriculture and Forestry                                                                                                              Risk Management Proposal:  
                                                                                                                                                                            Rubus  spp. Seed for Sowingthe option to make the consignmen t compliant (where appropriate) or to reship or destroy the 
material. 
3.5 Equivalence 
If
 the seed will not meet the conditions of th e import health standard, the importer may submit 
to MAF an application for assessment of equivalent phytosanitar y status. Where MAF 
determines that alternative measures will provide an equivalent phytosanitary status, the 
details of the equivalence will be recorded on the permit to import. 
3.6 Biosecurity clearance 
Biosecurity clearance sh
all only be given for daughter plants in PEQ, where the inspector is 
satisfied that the following has occurred: 
 The imported seed and daughter plants in PEQ comply with the requirements of the 
import health standard 
 There are no discrepancies in accompanying documentation 
 The goods display no signs of harbouri ng organisms that may be unwanted 
organisms 
 There has been no recent change in circumstances or knowledge that makes it unwise 
to give biosecurity clearance. 
4. MAF PROPOSAL 
This section outlines the proposed requirements for each regulated organism associated with 
Rubus spp. seed for sowing.  
4.1    Viruses 
4.1.1 Raspberry ringspot virus  
As Raspberry ringspot virus (RpRSV) can be dispersed naturally, and the introduction of this virus 
would have impacts outside the berry industry, MAF considers that specific testing for this virus is 
required. MAF considers that herbaceous indexing on to the indicator species Chenopodium quinoa , 
Cucumis sativus , Nicotiana clevelandii and the optional species Chenopodium amaranticolor, in 
conjunction with a serological or molecular test, is  appropriate to detect RpRSV (IHS 152.05.06: 
Importation of Nursery Stock and MAF Rubus  Testing Manual).  
 Proposal 
That Raspberry ringspot  virus is included as a regulated pest, and that one of the following measures 
must be met prior to biosecurity clearance being given: 
 Pest free area declaration (assessed by MAF) 
 Herbaceous indexing  (Chenopodium quinoa , Cucumis sativa , and Nicotiana clevelandii) AND 
ELISA or PCR  
 
4.1.2  Tomato black ri
 ng virus 
As Tomato black ring virus  (TBRV) can be dispersed naturally, and the introduction of this virus would 
have impacts outside the berry industry, MAF considers that specific testing for this virus is required.  
MAF considers that herbaceous indexi ng on to the indicator species Chenopodium quinoa, Cucumis 
sativa, Nicotiana clevelandii, and the optional species  Chenopodium amaranticolor , and in conjunction 
with a serological or molecular test, is appropriat e to detect TBRV (IHS 152.05.06: Importation of 
Nursery Stock and MAF Rubus  Testing Manual).  
 
Proposal 
That Tomato black ring virus  is included as a regulated pest, an d that one of the following measures 
must be met prior to biosecurity clearance being given: 
 Pest free area declaration (assessed by MAF) 
 Herbaceous indexing  (Chenopodium quinoa , Cucumis sativa , and Nicotiana clevelandii  AND 
PCR   
  
 
 
7  Ministry of Agriculture & Forestry                                                                                                                   Risk Management Proposal:  
                                                                                                                                                                             Rubus  spp. Seed for Sowing
 
 4.1.3  Tomato ringspot virus 
As Tomato Ringspot virus  (ToRSV) can be dispersed naturally, and the introduction of this virus would 
have impacts outside the berry industry, MAF considers that specific testing for this virus is required. 
MAF considers that herbaceous indexi ng on to the indicator species Chenopodium quinoa, Cucumis 
sativa,  Nicotiana clevelandii, and the optional species Chenopodium amaranticolor , in conjunction with 
a serological or molecular test, is appropriate to detect ToRSV (IHS 152.05.06: Importation of Nursery 
Stock and MAF Rubus  Testing Manual).  
 
Proposal 
That Tomato ringspot virus  is included as a regulated pest, and th at one of the following measures must 
be met prior to biosecurity clearance being given: 
 Pest free area declaration (assessed by MAF) 
 Herbaceous indexing  (Chenopodium quinoa , Cucumis sativa , and Nicotiana clevelandii  ) AND 
ELISA or PCR  
   
4.2   Post Entry Quarantine 
The IHS currently requires seed to be imported in to a level three PEQ facility, germinated and grown 
for a minimum period of one growing season, and for the plants to undergo testing for regulated viruses.  
The level of PEQ required has been reviewed, an d MAF considers that a level two PEQ facility is 
adequate for holding Rubus  plants derived from imported seed.  Tomato black ring virus , Tomato 
ringspot virus , and Raspberry ringspot virus  are all transmitted by nematodes .  A level two PEQ facility 
requires that plants are grown in pots on raised benches, MAF regards a level two PEQ facility as 
sufficient to contain these regulated viruses . 
 
A minimum PEQ period of three months is proposed, as the time required for the plants to grow 
sufficient leaf material for testing and treatment to occur.  The three month PEQ period will commence 
once plants have entered a period of active growth and have two fully expanded leaves.  Testing for regulated viruses can occur when there is sufficient  leaf material to be collected in accordance with 
section 7 of the MAF Rubus  Testing Manual.  Inspection of herbaceous indicator plants takes a 
minimum of fours weeks, which may impact on the timeframes for biosecurity clearance.  
Proposal 
That the PEQ requirements for Rubus  spp. be amended, to allow seed to be grown in a Level 2 PEQ 
greenhouse for a minimum growing period of three months, to undergo growing season inspections and 
testing for regulated viruses.. 
REFERENCES 
Description of Plant Viruses (DPV) website.  Ra spberry ringspot virus, Tomato ringspot virus, 
Tomato black ring virus.  http://www.dpvweb.net/intro/index.php  
 
Hanada K., Harrison B.D. 1977.  Effects of viru s genotype and temperature on seed transmission 
of nepoviruses.  Annals of Applied Biology – 85:  79-92 
 
ICTVdB -The Universal Virus Database website.  Tomato ringspot virus. 
http://www.ictvdb.rothamsted.ac.uk/ICTVdB/index.htm 
 
Lister R.M. and Murant A.F. 1967. Seed tr ansmission of Nematode-borne viruses.  Annals of 
Applied Biology – 59:  49-62  
 
MAF Biosecurity New Zealand Post-Entry Quarantine Testing Manual - Rubus  
http://www.biosecurity.govt.nz/f iles/regs/imports/plants/hi gh-value-crops/rubus-testing-
manual.pdf  
MAF Biosecurity New Zealand standard 155.02.06 Importation of Nursery stock  http://www.biosecurity. govt.nz/files/ihs/155-02-06.pdf
 8  Ministry of Agriculture and Forestry                                                                                                              Risk Management Proposal:  
                                                                                                                                                                            Rubus  spp. Seed for Sowing 
MAF Biosecurity New Zealand standard 155.02.05 Importation of Seed for sowing 
http://www.biosecurity.govt .nz/files/ihs/155-02-05.pdf