Risk Management Proposal:  
Revision of  the import health standard : Soil, 
Rock, Gravel, Sand, Clay and Water   
 
 
 
 
Prepared for  public consultation  
by Plant Product Imports  
Animal and Plant Health Directorate  
 
 
 
 
 
April  2023 
 
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, interpr etation or opinion that may be present, nor for the consequences of any 
decisions based on this information.  
This publication is also available on the Ministry for Primary Industries  website at  
http://www.mpi.govt.nz/news -and-resources/publications/   
© Crown Copyright – Ministry  for Primary Industries   
i Contents  Page 
 
Submissions  1 
1 General information  3 
1.1 Purpose  3 
1.2 Background  3 
1.3 Timing and consultation  3 
1.4 Background and context of consultation  3 
2 Proposed changes to the standard  5 
2.1 General  5 
2.2 Treatments  6 
2.3 Transitional facilities  7 
2.4 Water  8 
2.5 Soil 8 
2.6 Rock, sand,  and clay  9 
2.7 Goods sourced from New Zealand’s exclusive economic zone (EEZ)  9 
2.8 Core samples  10 
3 References  11  
Ministry for Primary Industries   Risk Management Proposal: IHS.SOWTR  • 1 Submissions  
The Ministry for Primary Industries (MPI) invites comment from interested parties on the 
proposal to revoke the import health standard  Soil, Rock, Gravel, Sand, Clay , and Water , and 
replace it with a new import health standard Soil, Rock, Sand, Clay, and W ater.  
An import health standard (IHS) “specifies requirements to be met for the effective 
management of risks associated with importing risk goods, including risks arising because 
importing the goods involves or might involve an incidentally imported new organism.” 
(section 22 Biosecurity , Act 1993)  
This risk management proposal is designed to be read alongside the proposed import health 
standard  Soil, Rock, Sand, Clay , and Water . MPI would like feedback on the following 
changes:  
1. general restructuring of the standard to improve readability ; 
2. new option to treat  offshore  with appropriate documentation;  
3. new treatment options;  
4. removal of weight and volume limits on soil and water;  
5. allow direction to a transitional facility without a pe rmit;  
6. split commodities by type to better target treatments towards the correct risks;  
7. allow goods from New Zealand’s exclusive economic zone  to be treated as domestic 
with appropriate documentation ; and 
8. a new category for core samples . 
Include the following  in your submission :  
• The title of the consultation document in the subject line of your email  
• Your name and title  
• Your organisation’s name (if applicable)  
Send submissions to plantimports@mpi .govt.nz  by 25 May 2023 .  
Feel free to include any  technical information  you have  that support s your submission. While 
we prefer email, if  you would like to send your submission by post, you can mail it  to: 
Plant Product Imports  
Animal and Plant Health  Directorate  
Biosecurity New Zealand  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
Submissions received by  25 May 2023  will be considered during the development of the 
amended standard . Submissions received after the clos ing date may be held on file for 
consideration when the issued standard  is next revised/reviewed.  
 
 2 • Risk Management Proposal: IHS.SOWTR  Ministry for Primary Industries   
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 a vailable to requesters unless there are sufficient 
grounds for withholding it, as set out in the OIA. Submitters may wish to indicate grounds for 
withholding specific information contained in their submission, such as information being  
commercially sensiti ve or personal. Any decision to withhold information requested under the 
OIA is reviewable by the Ombudsman .   
Ministry for Primary Industries   Risk Management Proposal: IHS.SOWTR  • 3 1 General  information  
1.1 Purpose  
(1) The purpose of this document is to:  
• Outline  the requirements in proposed new import health  standard ;  
• Provide the rationale for the proposed requirements and explain how they manage 
risk; and  
• Ask for  feedback . 
1.2 Background   
(2) MPI is proposing to revoke the current import health standard  Soil, Rock, Gravel, Sand, 
Clay , and Wate r and replace it with a new import health standard Soil, Rock, Sand, 
Clay, and Water . 
(3) The current standard was issued on 21 June 2021. The current standard was issued 
under section 24 A of the Biosecurity Act 1993 and applies to soil, rock, sand, clay , and 
water that is imported into New Zealand . 
1.3 Timing and consultation  
(4) The proposed new import health standard Soil, Rock,  Sand , Clay , and Water  was 
released for consultation on 12 April 2023 and will remain open for consultation until 
25 May 2023.  
1.4 Background and context of consultation  
1.4.1 International regulation of risk goods  
(5) “The World Trade Organi zation Agreement on the Application of  Sanitary and 
Phytosanitary Measures (SPS Agreement)  sets in place rules that protect each country’s 
sovereign right to take the measures necessary to protect the life or health of its people, 
animals, and plants , while at the same time facilitating trade. It embodies and promotes 
the use of science -based risk a ssessments to manage the risks associated with the 
international movement of goods. The SPS Agreement guide s how New Zealand sets 
standards and makes decisions related to biosecurity. ” (MAF et al., 2009, p. 1)  
(6) “In particular, [it is] important to maintain the standards of transparency and scientific 
rigour required by the SPS Agreement and to make decisions as quickly as possible. 
This will encourage other countries to comply with the rules of the SPS Agreement and 
also demonstrate that New  Zealand’s strict  controls are justified to countries that 
challenge them. ” (MAF et al., 2009 , p. 13) 
1.4.2 Domestic regulation of biosecurity risks associated with craft arrivals  
(7) The N ew Zealand  biosecurity system is regulated through the Biosecurity Act 1993 (the 
Act). Section  22 describes a n import health standard and requires all risk goods entering  
New Zealand  to be managed by one. MPI is the N ew Zealand  government ministry 4 • Risk Management Proposal: IHS.SOWTR  Ministry for Primary Industries  responsible for maintaining biosecurity standards that effective ly manage  risks 
associated with import ing risk goods and craft into N ew Zealand  (Part 3, Biosecurity 
Act 1993). MPI is committed to the principles of transparency and evidence -based 
technical justification for all phytosanitary measures  we impose  on importing pathways , 
whether new or amended.  MPI periodically reviews all biosecurity  standards  and related 
documents  so that the legal requirements are clear  and so that  information is 
consistently presented and as easy as possible to understand.  
   
Ministry for Primary Industries   Risk Management Proposal: IHS.SOWTR  • 5 2 Proposed changes  to the standard 
2.1 General  
(8) MPI has  completely reviewed the standard and made substantial changes to the 
structure of the document. The risk profile of the goods has not changed. The 
requirements for biosecurity clearance are either unchanged, reduced, or expanded to 
include more options, depending on the risk goods.  
(9) We propose removing “ gravel ” from the title , as g ravel  is a mix ture of rock and sand . 
The new standard  will still cover gravel, but gravel will not be mentioned explicitly in 
the title . 
(10) To reduce confusion  for importers and border staff, the proposed  new standard now 
explicitly address es goods  that importers commonly enquire about  and their 
requirements .  
(11) Organisms  (e.g. seeds, microorganisms) from goods import ed under this standard 
cannot be propagated.  This is not a change, but we have made this clearer. If you want 
to import an  organism  to propagate , you can still use another standard, such as Seeds for 
Sowing , Research Samples ( Excluding Animal Sa mples)  or Microorganisms from All 
Countries . We are adding a note  to the new standard advising importers to contact MPI 
if the other standards do not meet their needs . We may then assess the risk of the 
product and consider adding the product to  this standard.  
2.1.1 Changes relating to r esearch samples  
(12) The current soil and rock standard refers to “samples imported for purposes other than 
research or consumption”, incorrectly giving the impression that research samples 
cannot be imported under this standard. We have removed all instances of “for purposes 
other than research”.  
(13) On 4 August 2021, we  created  import  requirements for research samples containing 
soil, water and other organic matter  in a new import health standard, Research Samples 
(Excluding Animal Samples) . We also removed the requirements for research samples 
from the soil and rock standard at the same time.  
(14) However, the Research Samples  standard states that samples for research may be 
eligible for import under another import h ealth standard . This means that g oods 
intended for research can still be imported under  the soil and rock standard  if they meet 
the requirements  of this standard .  
2.1.2 Feasibility  
(15) We expect these changes to make the scope of the standard clearer and easier to 
understand. The scope itself has not changed, but we hope it is now less confusing .  
(16) We also expect this to reduc e holds on goods at the border while waiting for 
clarification from MPI.  
 6 • Risk Management Proposal: IHS.SOWTR  Ministry for Primary Industries  Question for submitters:  
Are there commodities that you regularly import that are not clearly identified in the 
new standard?  
2.2 Treatments  
2.2.1 Acceptance of overseas treatments  
(17) The current standard does not allow goods to be treated offshore. We are proposing 
allowing o ffshore  treatments with a treatment certificat e. This is similar to  many other 
MPI standards (e.g. Dried and Preserved Plant Material , Stored Plant Products for 
Human Consumption , Processed Animal Feed of Plant Origin , Fertilisers and Growing 
Media of Plant Origin ). 
(18) The current standard requires soil and some water samples to be treated on arrival by an 
MPI-approved treatment supplier. No overseas alternatives are permitted without 
approval by a chief technical officer of MPI (CTO) along with a permit to import. Some 
importers are currently importing goods that have  been treated offshore using methods 
that are the same as or  equivalent to the current measures in the standard.  
(19) Under the proposed new standard , these importers will not need an import permit or be 
required to  re-treat their goods on arrival in New Zealand.  
2.2.2 Removal of quantity limits  
(20) We are proposing removing  absolute weight or quantity limits . Some commodities  
(e.g. rocks, sand, clay, religious water ) will still have  different requirements for 
different quantities.   
(21) The current standard has a 10 kg weight limit  for soil  and a 100  L volume limit  for 
water , if not commercially packaged. These limits were not put in place to manage 
biosecurity risk  but to help manage the  capacity of New Zealand treatment providers. 
This is not something MPI typically regulates, and treatment providers can manage their 
own capacity.  Removing the weight limits does not change the biosecurity risk.   
(22) We currently require a permit to import qu antities of water and soil that are over the 
limits. In removing the limits, we will also remove the requirement for a permit.  
(23) Under the proposed new standard , you should arrange treatment  with your onshore 
treatment provider before your goods  are shipped .  
2.2.3 New treatment options  
(24) We are proposing new treatment options for certain commodities .  
a) Water filtration  with the filtration residue subsequently destroyed, reshipped, or 
treated with an alternative method for clearance  
b) Irradiation for water  
c) Dry heat for soil , rock, sand , and clay  
d) Autoclaving for soil, rock, sand , and clay   
Ministry for Primary Industries   Risk Management Proposal: IHS.SOWTR  • 7 e) Cleaning for rock, sand , and clay  
(25) Most archaea and bacteria have a diameter between 0.2 and 3 μm (Westoby et al. 2021) . 
Filtration down to 0.1 μm will manage the risk of most harmful organisms found in 
water.  
(26) Irradiation is a widely accepted disinfection option for water ( Chatzisymeon  et al., 
2011; Lee et al., 2015; Pullerits  et al., 2020).  This will also bring us in line with 
Australia, which  currently has an irradiation option for water  (BICON, 2023).  
(27) In soil, temperatures over 100°C  will deactivate even heat -tolerant pathogens and seeds 
after 30 minutes  (Agrios 2005) . The United States Department of Agriculture (USDA) 
has approved treatments  for dry heat soil sterilisation , which we will use here .  
(28) Autoclaving is a standard soil treatment  for research  purposes . We propose making the 
same  autoclave option  that is  currently available for other types of risk goods  available  
for soil.  
(29) We propos e offering c leaning , or m anua l removal of soil, plant , or animal  material as an 
option for rock, sand, and clay. This is already used informally at the border when  
organic material is found on these commodities. For these goods , the contamination can 
often be removed without damage to the goods themselves.  
(30) We propose  requiring  soil to be  “loosely packed and spread no thicker than 10 cm.” 
Treatment of soil is less effective if the soil is tig htly packed or piled more than 10  cm 
thick (Mechler 2022).  Treatment providers using good practice should already be doing 
this.  
2.2.4 Feasibility  
(31) The efficacy of the new treatments meet s or exceed s the efficacy of existing treatments. 
Allowing offshore treatme nts gives  importers more options.  
Question  for submitters:  
Are there treatment options that achieve equivalent outcomes that you would like to 
see added to the new standard?  
2.3 Transitional facilities  
(32) We propose allowing goods that are going directly to a  transitional facility to be 
imported without a permit.  
(33) Goods that cannot meet biosecurity clearance requirements (e.g. treatment would 
damage their usefulness for research) can be imported for use in a transitional facility. 
Currently, importers require a permit to  do this.   
(34) The transitional facilities listed in the proposed new standard are adequate to manage 
biosecurity risk from untreated soil , water,  rock, sand, or clay  so requiring a permit to 
assess this every time is an excessive measure.  8 • Risk Management Proposal: IHS.SOWTR  Ministry for Primary Industries  2.3.1 Feasibility  
(35) This will reduce costs and administrative time for  both importers  and MPI . 
2.4 Water  
2.4.1 Potable water  
(36) We propose replacing the term “water for consumption” with “potable water” to focus  
on the condition of  the water instead of the intended use . 
(37) We are not proposing any new requirements . 
2.4.2 Non-potable water  
(38) We propose using three categories of non-potable water  to better target the risks . 
a) Water for religious purposes  
b) Geothermal water  
c) All other non -potable water  
(39) We are now interested in the origin or end use of the water. This is a change from the 
current standard , which requires all water samples that are not visually clear  to be 
treated . 
(40) The end use of a consignment changes its biosecurity risk. Water imported in low 
quantities for religious purposes is low risk . Typical use involves personal cons umption  
in a home , which  is an unlikely way for organisms in the water to become established in 
New  Zealand . The low risk of water imported for religious purposes combined with the 
small volumes imported  and inspection  for visually detectable risks  will manage the 
biosecurity risks of this water . This measure is similar to the current standard.  
(41) We propose adding filtering and irradiation as treatment options for geothermal water 
and all other non -potable water.  See sect ion 2.2 “Treatments” for more information on 
filtration and irradiation.  
(42) Organisms in geothermal water can be  heat-resistant  (thermophilic ). Boiling does not 
treat geothermal water , so while all other non -potable water can also be boiled, 
geothermal water can only be treated with chemicals, irradiated, or filtered.   
2.4.3 Feasibility  
(43) The new treatments meet or exceed the efficacy of existing treatments. The changes 
give importers more options to meet the requirements.  
2.5 Soil 
(44) We are proposing allowing s oil collected  from more than 3 metres below surface level 
to be imported without treatment.  We will require a  declaration that states  that the goods 
were collected from more than 3 metres below the surface .  
Ministry for Primary Industries   Risk Management Proposal: IHS.SOWTR  • 9 (45) The principal habitat for soil organisms is the solum layer, which is on average  1 m 
deep  but may be up to 3 m in some parts of the world (FAO). Soil collected from below 
3 m poses very little biosecurity risk.  
(46) We are not changing measures  for any other soil, except for new treatment options, 
outlined in the “Treatments ” section above  (2.2). 
2.5.1 Feasibility  
(47) The proposed changes reduce  the requirements for low -risk goods , as well as  treatment 
costs and administrati on work  for importers.  
2.6 Rock, sand , and clay  
(48) The standard currently requires rock, gravel, sand , and clay samples to be free from 
organic material but  does not state how this is to be verified . 
(49) The proposed standard is clearer  about how we will verify that rock, sand , and clay are 
free of organic material. Importers will be able to choose from severa l options , 
depending on the size or origin of the consignment . 
a) Declaration  
b) Inspection  
c) Treatment  
d) Direction to transitional facility  
e) Import p ermit  
(50) Visual inspection will only be available for small quantities of goods. Rock, sand and 
clay are not risk  good s on their own.  Our goal is to ensure that they are not 
contaminated with soil or other organic material. It is not feasible for border staff to 
inspection large quantities of rock, sand , and clay for organic material, so w e are 
proposing stricter measures f or larger quantities  of these goods . Larger quantities are 
higher risk . We are proposing requiring these goods to be treated or have an import 
permit.  
(51) We will not require treatment for m aterials collected from deeper than 3  metres, in line 
with our require ments for soil. Instead, we will require a  declaration that states  that the  
goods were collected from more than 3 metres below the surface . 
(52) We have added guidance to th is section  with a  list of non -risk goods that do not have 
any biosecurity requirements . This will clarify that many industrial and commercial 
goods are exempt.  
2.6.1 Feasibility  
(53) We expect the  changes to make our expectations for consignments clearer to  importers.  
2.7 Goods sourced from New Zealand ’s exclusive economic zone (EEZ)  
(54) We propose  allow ing goods collected from New Zealand ’s exclusive economic zone  
(EEZ) to receive biosecurity clearance without  treatment. Instead, we will require a  10 • Risk Management Proposal: IHS.SOWTR  Ministry for Primary Industries  declaration that states the goods have come from New Zealand’s  exclusive economic 
zone . 
(55) The exclusive economic zone  is the area between 12 and 200 nautical miles off the 
coast of New Zealand  (Manat ū Taonga , 2019) . 
(56) The organisms  in the sea surrounding New Zealand are likely to also be present on or 
near the mainland a nd pose little biosecurity risk.  
2.7.1 Feasibility  
(57) This will reduce  treatment costs and  administrative work for importers of goods  from 
our exclusive economic zone . 
2.8 Core samples  
(58) We propose adding a  new category for core samples . We frequently receive  questions 
about core samples, which are usually imported for research  or industrial purposes . 
(59) We propose allowing i ce or snow cores to be imported without  treatment (unlike 
general non -potable water) as long as they remain frozen.  If there are any organism s in 
the samples, they will not be able to  escape  as long as the samples  remain frozen.  
(60) We propose adding a p ost-clearance requirement to treat  ice and snow cores before 
dispos ing of them . Post-clearance requirements are enforceable under section 24D(1) of  
the Biosecurity Act.  
(61) All other core samples (expected to be mostly rock and/or soil) w ill have the same 
requirements as any other rock or soil , which will also be listed in this section for 
clarity.  
2.8.1 Feasibility  
(62) This will  reduc e treatment costs and administrative work for importers of core samples . 
 
   
Ministry for Primary Industries   Risk Management Proposal: IHS.SOWTR  • 11 3 References  
Agrios, G N (2005 ) Control of plant diseases . In Plant Pathology  (pp. 293 –353). Elsevier 
Academic Press.  
DAFF ( 9 March 2023) Case: Water Effective: 09 Mar 2023  BICON . Department of 
Agriculture, Fisheries and Forestry. 
https://bicon.agriculture.gov.au/ImportConditions/Conditions?EvaluatableElementId=714619
&Path=UNDEFINED&UserContext=External&EvaluationStateId=6cacd683 -1ea3 -4577-
9dee -
181862752648&CaseElementPk=2057969&EvaluationPhase=ImportDefinition&HasAlerts=
True&HasChangeNotices=True&IsAEP=False . Accessed 21 March 2023.  
Chatzisymeon, E ; Droumpali, A ; Mantzavinos, D ; Venieri, D (2011 ) Disinfection of water 
and wastewater by U V-A and UV -C irradiation: Application of real -time PCR method. 
Photochemical & Photobiological Sciences , 10(3 ): 389–395. 
https://doi.org/10.1039/c0pp00161a   
FAO. Physical properties | FAO SOILS PORTAL  https://www.fao.org/soils -portal/data -
hub/soil -properties/physical -properties/zh/  Accessed 7 December 2022 . 
Lee, O -M; Kim, H Y ; Park, W ; Kim, T -H; Yu, S (2015 ) A comparative study of disinfection 
efficiency and regrowth control of microorganism in secondary wastewater effluent using 
UV, ozone, and ionizing irradiation process. Journal of Hazardous Materials , 295 : 201–208. 
https://doi.org/10.1016/j.jhazmat.2015.04.016   
MAF; MFAT; FSA (2009) Balance in Trade . Ministry of Agriculture and Forestry, Ministry 
of Foreign Affairs and Trade, New Zealand, Food Safety Authority; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/12576 -balance -in-trade   
Mechler, S ( 17 February 2022 ) Beginner ’s Guide to Autoclaving Soil. Consolidated Sterilizer 
Systems. https://consteril.com/soil -sterilization/  Accessed 3 February 2023 . 
Manat ū Taonga | Ministry for Culture and Heritage (30 April 2019) Exclusive economic 
zones. Te Ara Encyclopedia of New Zealand – Te Ara Encyclopedia of New Zealand . 
https://teara.govt.nz/en/map/33830 /exclusive -economic -zones . Accessed 17 February 2023.  
Pullerits, K ; Ahlinder, J ; Holmer, L ; Salomonsson, E ; Öhrman, C ; Jacobsson, K ; Dryselius, R ; 
Forsman, M ; Paul, C J ; Rådström , P (2020) Impact of UV irradiation at full scale on bacterial 
communities in drinking water. Npj Clean Water , 3(1). https://doi.org/10.1038/s41545 -020-
0057 -7  
Westoby, M ; et al. (2021) Cell size, g enome size, and maximum growth rate are near -
independent dimensions of ecological variation across bacteria and archaea. Ecology and 
Evolution , 11(9): 3956 –3976 . https://doi.org/10.1002/ece3.7290