A national organic mark is only worth what sits behind it

What is being asked

Section 133(1)(d) of the Act allows regulations to provide for a national organic mark, who may use it, and conditions on its use. MPI consulted the sector on an organic logo in 2021, and of the 79 submitters who answered that question, most supported creating one.

MPI now sees two feasible options beyond the status quo of no mark:

1. a single mark usable in both domestic and international markets, or
2. separate marks, one for international use and one for domestic use, with the option that the domestic mark is not regulated at all and the sector relies on the verifier's own mark instead.

It is also asking about design: whether the mark should visually reflect New Zealand and how, how it should distinguish regulated organic products, and whether the export version could be the domestic mark with an element added. Feedback from this round feeds a full design consultation in 2027.

Questions 13 to 17 cover it, and question 17 invites you to send images and sketches.

The case for a single mark

A mark does three things MPI names: supports confidence in organic claims, distinguishes product made under New Zealand's regulatory system, and supports recognition in international markets.

A single mark does all three more cheaply than two. It builds one asset instead of splitting recognition across two. Two marks create a hierarchy the moment they exist, whichever way you design them, and the domestic one becomes the lesser mark by implication. Anyone who has watched a two-tier labelling scheme play out in another sector knows how that ends.

There is a reasonable counter-argument, which is that export markets need a mark tied precisely to equivalence arrangements while the domestic market needs something a shopper recognises, and that one mark cannot carry both jobs. Design can resolve most of that: MPI's own suggestion of a shared mark with an added element for export is a sound instinct. Our position is a single mark with an export element, restricted to approved operators. But the option is not the hard part of this question.

The hard part

A mark is a promise that something has been checked. Its value depends entirely on whether the person receiving it can check it back.

Here is what the Act currently guarantees on that front.

Section 54 requires a public register of all approved operators and recognised entities, kept so that it can be stored, accessed and reproduced by electronic means, enables the public, operators and recognised entities to know details of operators and recognised entities for the purposes of the Act, and facilitates the compliance and audit functions of the Ministry.

Section 55 sets the content of the register. In full, it is: name, contact details, and any other prescribed information.

Section 56 requires the register to be published on an internet site free of charge, and a copy of information in it supplied at no more than reasonable cost on request.

Read section 55 again. Name and contact details are the whole of what is guaranteed. "Any other prescribed information" is a regulation-making hook, and it has not been used. As it stands, nothing in the Act requires the register to record what a person is approved for.

That is the gap, and it is not academic. Certification under ISO 17065 is scoped: an operator is certified for particular products, under particular standards, for particular markets. A grower certified for pipfruit for the domestic market is not thereby certified for processed juice for the EU. A register that lists a name and an email address tells you the operator exists. It does not tell you whether the product in front of you is inside their scope.

A directory is not a verification mechanism. And a national mark backed by a directory is a stronger claim resting on a weaker check.

Why that combination is worse than no mark

This is the part we would most like the sector to argue about, because we think it is right and it is not obvious.

A counterfeit word claim is cheap to disbelieve. If an unfamiliar business writes "organic" on a label, a careful buyer already treats it as unverified and goes looking. The claim carries only the credibility of whoever made it.

A counterfeit national mark carries the credibility of the Crown. It tells the buyer that a state system stands behind the claim, which stops them looking. So introducing a mark raises the payoff from a false claim without, by itself, raising the probability that a false claim is detected. If the register behind the mark cannot answer "is this product, from this operator, for this market, actually inside their approval", then the mark has moved risk from the person making the claim onto the person relying on it.

The fix is not to abandon the mark. It is to prescribe the register content and the access method at the same time as the mark, so they ship together.

What the register would need to carry

Two things, both available under powers the Act already contains.

Prescribe register content under section 55(c). The fields that make a mark checkable are: the product or category scope of the approval; the standards and market equivalences it covers; the verifying entity; status and the dates it applies from and to; and a persistent identifier so a record can be cited and re-found. None of that requires new primary legislation. It requires regulations using the hook in section 55(c).

Publish it machine-readably under section 56. Section 56 requires publication free of charge on a website. It says nothing about usability, which means a scanned PDF list would satisfy it. What makes a register usable to the people who need it, which is buyers, verifiers and the systems they run, is an open API, a downloadable bulk dataset, and stable per-scope URLs so a specific approval can be linked to. Publishing the specification for comment before it is built would cost MPI little and save a rebuild.

Neither of these is a novel demand. Both of New Zealand's largest organic export destinations already do it:

• The USDA Organic INTEGRITY Database publishes certification scope, covering crops, livestock, wild crops and handling, along with the commodities each operation offers, with full-dataset snapshots downloadable monthly.
• The EU's TRACES public organic operator directory, under Article 35 of Regulation (EU) 2018/848, publishes individual certificate documents per operator showing the product categories they are certified for.

On OANZ's figures, the United States and the EU together took roughly 47 percent of New Zealand's organic exports in 2024. The buyers our exporters most need to convince are already accustomed to being able to look an operator up and see the scope. A New Zealand register that offers a name and an email address will be compared to those, and not favourably.

What we are submitting

For the record, so you can argue with it:

1. A single mark with an export element, restricted to approved operators, conditional on 2 and 3 below.
2. Prescribe register content under section 55(c): product and category scope, standards and market equivalences, verifying entity, status and dates, persistent identifiers.
3. Publish machine-readably under section 56: open API, bulk dataset, stable per-scope URLs, with the specification published for comment before it is built.

The conditionality is the point. We would rather New Zealand had no national mark than a national mark nobody can check.

The same visibility argument applies to the exemption threshold: see the exempt-list argument in our exemption threshold post.

If you submit on one thing this month

Make it question 16. MPI is asking what the mark should look like, and most submissions will answer only that. The design will be consulted on properly in 2027. The register decisions will not be, unless the sector raises them now, and the register is what the design will eventually rest on.

Submissions close 11:59pm, 22 September 2026, at mpi.surveymonkey.com/r/8PGC3G5 or organicsconsultation@mpi.govt.nz.