31 March 2028 is closer than it looks: what the Organic Standards Regulations will ask of you

The organic management plan is the spine

Regulation 22 of the Organic Products and Production Regulations requires every operator to have an organic management plan showing how the product will comply with the organic standard, and how the operator will comply with the Act, secondary legislation and directions.

Regulation 23 sets the bar for it. The plan must be in writing, contain the information set out in Schedule 3, be clear enough to be readily understood by the operator and anyone else required to use it, and be detailed enough that whoever is responsible for implementing a procedure will know how to implement it. That last clause is the one that catches people. A plan that only its author can follow does not meet regulation 23.

Schedule 3 sets out what has to be in it. In summary:

• Clause 2: operator name, trading name, New Zealand Business Number, electronic address, business address, the name and contact details of whoever has day-to-day management, and the name and business address of any relevant service provider. If a vehicle is used only for transporting the product, the address where it is usually kept counts as a business address.
• Clause 3: the position, or name and position, of the individual responsible for day-to-day management of the plan, and of anyone managing a key task prescribed by supplementary notice.
• Clause 4: particulars of the operator's activities and of any services provided by a relevant service provider.
• Clause 5: the boundaries and layout of every site where activities are carried out, with specific rules for mobile premises and for transport.
• Clause 6: each key task, who manages it, and how that person will acquire or maintain the required competencies.
• Clause 7: for each product, its name or type entering and leaving the operation boundaries, whether it complies with the organic standard and relevant export requirements, every ingredient or component, every input, anything else that could affect compliance, and all outputs including waste.
• Clause 8: any activities or services carried out inside the operation boundaries that do not relate to the product.

Then the document control obligations in regulation 25, which are the ones most likely to trip an otherwise well-run operation:

• keep an up-to-date version of the plan
• make it accessible to anyone responsible for implementing any procedure in it
• keep a copy of every document that has been in the plan and has since been replaced or removed
• make the plan and any related document available, or able to be made available within 2 working days, to the chief executive, an authorised person, a verifier or verifying agency, an overseeing recognised entity, or an organic products officer

Superseded documents must be kept for the longer of 4 years or the shelf life of the product the plan relates to. "Related document" includes any reference material the plan points to, any evaluation report, and every superseded version.

Regulation 27 requires periodic review, and the plan itself must say when and how often you will review it, and what you will do if it falls short.

The practical translation of all of that: version control is a legal obligation, not good practice. If your plan lives in a single document that gets edited in place, you are not compliant with regulation 25(1)(c) no matter how good the current version is.

How often you get verified

The frequency ladder in regulation 84 is worth understanding early, because it rewards a clean run and it is unforgiving of a bad first one.

Initial verification must be carried out within 12 months of approval, under regulation 82. Then:

If your initial verification produces an unacceptable outcome, you start at step 1. If it produces an acceptable outcome, you start at step 2. Two consecutive acceptable outcomes move you one step up the ladder, so the gap between verifications lengthens. An unacceptable outcome at any point lets the verifier increase the frequency, taking into account the corrective action required, the complexity of your plan and your business, your conduct, and your compliance history.

Exporters are on a different track under regulation 86. Initial verification must happen before the earlier of 6 months after approval or the date you first export. The next verification is within 6 months of the initial one starting. Two consecutive acceptable outcomes move you to every 12 months. Any unacceptable outcome puts you back to every 6 months until you get two clean ones.

Operators subject to internal verification, in practice group members, have subsequent verification within 5 years of the initial one and every 5 years after, in addition to the internal verification they complete under the group's control system.

You can request more frequent verification under regulation 87. Some operators will want to, particularly in the first two years while the regime beds in.

The proposed amendments that change what you do

MPI describes Appendix 2 as minor and technical, and says they are not policy changes. Several of them will change practice.

Regulation 13(3), inputs, from "think" to evidence. As drafted, an operator can use an acceptable input if they "think" it is needed to achieve an outcome and that outcome cannot be achieved with what is already available or by methods within the production unit. MPI proposes an objective test requiring the operator to support the decision with evidence. If this proceeds, input decisions become a documented justification rather than a judgement call. That is a real change to your record-keeping.

Regulation 14, recording how inputs are used. Currently you must record input use, but not how the input was used. MPI proposes adding it, so that it can assess whether use was justified. Another field on the same record, but plan for it.

Regulation 41(4), concurrent conversion periods. As drafted, the plant conversion period is additional to the land conversion period and only begins after land conversion is complete. MPI acknowledges this creates unnecessarily long and impractical timeframes, particularly for perennial crops, and proposes allowing the periods to run concurrently where appropriate. For anyone planning an orchard or vineyard conversion around the 2028 date, this is the single most consequential proposal in Appendix 2. It is worth a submission from anyone it affects, with the actual timeline it would save you.

Regulation 45(3)(a), compost residue testing. Currently testing of the final compost mix for residues, with records kept, is required in every case where certain materials are used. MPI is explicitly asking whether a risk-based approach would be better. If you make your own compost, your view on this is the evidence MPI needs.

Regulation 45(4)(a)(ii), "specification sheets" to "documentation". The term is not widely used in organic production and narrows what counts as evidence from a supplier. A broader term allows the forms of evidence that suppliers actually provide.

Regulation 38(3), non-compliant products. The regulation requires compliant products to be identified and kept separate from non-organic products, but says nothing about non-compliant products, which is a traceability gap. MPI proposes including them.

Regulation 98, defining aquaculture products. The term is currently undefined. MPI suggests "unprocessed products from any aquaculture species".

Regulation 19, waste and by-products, and regulation 83(5), non-organic feed. Both are cases where MPI is asking whether core obligations belong in the regulations rather than in supplementary notices, and whether the chief executive has clear enough decision-making powers. This is dry, and it matters: a requirement in regulations is stable and visible, a requirement in a notice can change without an Order in Council.

What to do between now and 2028

The regulations reward operators who start their document control early, because a plan built in 2027 and reviewed twice before 2028 is a plan with a history. A plan built in March 2028 is a plan with none.

Three things worth doing this year, none of which depend on the consultation outcome:

1. Map your operation boundaries and site layouts as Schedule 3 clause 5 requires. This is the part people underestimate, particularly where activities happen across leased blocks or mobile premises.
2. Put superseded plan documents under version control now, with dates, and keep them. The 4-year clock is not something you can reconstruct later.
3. List every input you use and how you use it, whether or not the regulation 14 amendment proceeds. If it does, you already have it. If it does not, you have a better plan anyway.

The operators who do this well tend to be the ones who already treat organic systems as a resilience investment rather than a compliance cost, which is why organic is becoming the resilient choice.

Submissions on the proposed amendments close 11:59pm, 22 September 2026. Questions 10 to 12 cover this section, and question 12 asks specifically which amendments should be removed, amended or added, referring to the change numbers in Appendix 2.