So, what really happened when New Zealand Food Safety reviewed the 3,100 submissions on glyphosate residues?
On paper, it looks like a win: cereals like wheat, barley, and oats stay at 0.1 mg/kg, and pre-harvest spraying is officially ruled out (banned) for human-consumption grain. That’s big news.
But scratch beneath the surface and the picture isn’t quite so tidy. Why did regulators suddenly change course? What loopholes remain? And what happens when limits are breached — because history shows that’s already happened, with little consequence.
This isn’t just about numbers on a page. It’s about trust, enforcement, and whether decisions truly put public health first.
Read the full Summary of Submissions on the Proposed Amendment to some Maximum Residue Levels for Glyphosate here.
What Changed — and Why
The headline takeaway is simple: glyphosate residues on wheat, barley, and oats will stay capped at 0.1 mg/kg — the lowest possible level — and from now on, glyphosate can only be applied before crops emerge if they’re destined for human consumption. In plain language, that means no more pre-harvest spraying of bread wheat, oats, or malting barley in New Zealand.
But here’s where it gets interesting: NZFS didn’t arrive at this decision on its own. The submissions revealed that many growers and millers already had contractual agreements banning or severely restricting pre-harvest glyphosate use. In other words, industry practice had quietly moved ahead of regulation, largely because brand owners and exporters needed to protect their reputations in overseas markets.
Faced with over 3,100 public submissions — most opposing higher limits — and sustained pressure from community groups, campaigners like us, and other affected stakeholders, NZFS decided to formalise the status quo rather than fight against it. The labels will now catch up to what many food businesses already demanded.
A Win on Cereals, a Compromise on Peas
For daily staples like bread, breakfast oats, and beer barley, the outcome is clear: limits stay at 0.1 mg/kg, and pre-harvest spraying is out. That’s a genuine win for public health and consumer trust.
But peas didn’t fare the same. Dry field peas will now carry a 6 mg/kg glyphosate limit, as originally proposed. Why the difference? According to NZFS, pre-harvest desiccation of peas remains common practice, and international markets — from the EU to the US — already allow levels between 8–10 mg/kg. With peas being a relatively small domestic crop and mostly destined for export, trade alignment trumped precaution.
So, while the cereals decision reflects shifting industry practice and public pressure, peas remain bound to the logic of the global commodity market.
The Animal-Feed Loophole
There’s one important caveat. While pre-harvest spraying is no longer permitted on cereals grown for human consumption, it remains allowed for animal feed.
That matters for two reasons:
- Cross-contamination risks — Food and feed grains often share storage silos, trucks, and processing facilities. Even with contracts and segregation systems, mix-ups happen.
- Indirect exposure — Residues in animal feed don’t just disappear. They can flow back into the human diet through meat, milk, and eggs. Regulators say this is accounted for in dietary risk models, but the reality is far messier than lab assumptions.
So while the ban is progress, it’s not a full safeguard. Glyphosate may still find its way into the food chain by less visible routes — and that’s something regulators haven’t explained.
Enforcement Gaps: Rules Without Consequences
One of the most revealing parts of the submissions summary is that wheat in New Zealand has previously tested as high as 5.9 mg/kg for glyphosate — nearly sixty times higher than the 0.1 mg/kg default limit.
Yet instead of recalls or penalties, NZFS pressed pause. Because farmers were technically following the label, officials treated MRLs as a measure of Good Agricultural Practice, not a line that could never be crossed. Enforcement was shelved until the reassessment was complete.
Fast forward to now: that reassessment has ended, the new rules are in place, and yet the pattern continues. We raised with MPI over a month ago that our independent honey testing found residues above the legal limit. So far? Crickets. No response. No action.
This is the heart of the problem. What good is a limit if it isn’t enforced? If regulators choose to quietly wave breaches through — whether in wheat yesterday or honey today — then “limits” are little more than paperwork.
A limit without enforcement is just a suggestion.
“A Higher MRL Isn’t Less Safe”?
One phrase comes up often in the summary: an MRL is not a safety limit. Regulators insist that residue levels — whether set at 0.1 mg/kg or 10 mg/kg — don’t directly tell us how “safe” the food is. Instead, they argue that safety is determined by a health-based guidance value (HBGV), which acts like a “risk cup.” As long as the total estimated intake from all food sources stays below that cup, they say, consumers are safe.
That might sound tidy in theory, but it jars with public expectations. Most people assume that if the legal limit is exceeded, food safety is at risk. And who could blame them? If a packet of Weet-Bix or a jar of honey tests above the MRL, the public deserves more than a technical explanation about “risk cups” and “good agricultural practice.”
The bigger issue is that these risk models only account for glyphosate in isolation. They don’t account for formulated products like Roundup®, with surfactants and co-formulants that can change how the chemical behaves in the body. They don’t account for real-world mixtures of multiple pesticides we’re all exposed to daily.
So when regulators say “a higher MRL isn’t less safe,” they’re asking the public to trust a model that leaves out much of what people are actually exposed to. That gap between the theory and the lived reality is where trust continues to erode.
Old Diet Data, Modern Chemicals
Another uncomfortable truth in the submissions summary: New Zealand’s dietary exposure assessments are still built on outdated nutrition surveys. The models rely heavily on data from the 1997/98, 2002, and 2008/09 national nutrition surveys — each based on single-day food recalls that don’t reflect long-term consumption patterns.
Regulators admit these surveys are “somewhat old” but call them “acceptable for a Tier 1 risk assessment.” In plain language: they’re using the best data they’ve got, even if it’s decades out of date.
Why does this matter? Because consumption habits have changed dramatically since the late 1990s. Children today may eat far more cereal, processed food, or imported produce than the data suggests. High-consumption groups — like kids, athletes, or communities with limited food diversity — may face greater exposure than the models predict.
Yet the dietary exposure work underpinning New Zealand’s glyphosate decisions hasn’t been updated to match the reality of what we eat now.
If safety is only as strong as the data behind it, then relying on 20-year-old surveys doesn’t inspire much confidence.
Roundup Gets a Free Pass
A recurring theme in the submissions was concern not just about glyphosate itself, but about the formulated products sold under names like Roundup®. These products include surfactants and other co-formulants designed to make glyphosate stick to leaves, penetrate plant tissues, and resist being washed away. One of the most frequently cited is POEA (polyethoxylated tallow amine), which has been shown to be far more toxic to aquatic organisms — and potentially to humans — than glyphosate alone.
So what did NZFS say in response? That they are “not aware” glyphosate or its main breakdown product (AMPA) become more toxic in formulations, and that it’s the EPA’s job to review co-formulants like POEAs. In other words: not our problem.
But that sidesteps the core issue: New Zealanders are exposed to the formulation, not the lab-isolated active ingredient. Testing only for glyphosate and AMPA ignores the rest of the chemical cocktail. Regulators are assessing theory, not reality.
Without formulation-level testing, without full ingredient disclosure, and without recognition that “glyphosate” almost always arrives bundled with other substances, the official story remains incomplete. Roundup® gets a free pass, even as questions mount.
What the Summary Leaves Out
For all its detail, the Summary of Submissions leaves some big questions hanging.
- Timelines for change: Yes, the labels will be updated to “pre-emergence only” for cereals, but when? How soon will the new rules actually appear on products farmers are buying? Without clear timelines, enforcement can be quietly delayed.
- Compliance plan: NZFS admits past breaches went unpunished, but offers no roadmap for how it will respond next time. Will we see recalls, fines, or penalties if residues exceed 0.1 mg/kg again — or more of the same shoulder shrug?
- Produce parity: Cereals got a win, but many fruits and vegetables carry far higher glyphosate limits. Apples, grapes, and kiwifruit can have residues at levels multiple times higher than cereals. Where is the review process for these everyday foods?
- Transparency gaps: While NZFS references its monitoring programmes, the public still can’t easily access comprehensive, up-to-date residue data. For a chemical as controversial as glyphosate, “trust us” isn’t enough.
In short: the summary tidies up the cereal debate, but leaves broader questions untouched. The public may have secured one win, but the system that allowed unsafe practices to persist hasn’t been fully fixed.
Where This Leaves Us
On the surface, this looks like a victory: cereals protected at 0.1 mg/kg and a clear ban on pre-harvest spraying for human-consumption grain. That’s a major step forward and proof that public pressure works.
But it’s also a reminder of how fragile progress can be. Animal-feed crops still allow pre-harvest use. Honey has tested over the legal limit with no regulatory response. Enforcement remains weak, dietary data is outdated, and Roundup® formulations continue to escape serious scrutiny.
So yes, we celebrate. But we also recognise this isn’t the end of the story — it’s a checkpoint. The system has been nudged in the right direction, but unless enforcement is strengthened and transparency extended, we’ll be back here again when the next residue review comes around.
The real question isn’t just “What’s the limit?” It’s “Who’s making sure it means something?”
What We’re Asking For Next
This outcome shows that public voices can shift policy. But to turn a headline into real protection, regulators need to go further. Here’s what we’re calling for next:
- Enforcement with teeth
Breaches can’t be brushed aside. If residues exceed the legal limit, there must be clear, transparent consequences — recalls, fines, and public reporting. - A produce roadmap
Cereals got attention, but many fruits and vegetables carry far higher glyphosate limits. NZFS should publish a plan to review high-consumption produce and bring limits in line with cereals. - Formulation transparency
Roundup® isn’t just glyphosate. Co-formulants like POEA need to be disclosed, monitored, and regulated, with routine formulation-level testing, not just active-ingredient checks. - Updated dietary data
Risk models built on surveys from the 1990s and 2000s are out of date. We need fresh New Zealand nutrition data to understand how glyphosate exposure really plays out across today’s diets. - Clarity for consumers
If MRLs aren’t safety limits, then say so plainly. The public deserves straightforward explanations, not technical reassurances buried in submissions.
Looking Ahead
This decision proves that collective voices can move the dial — but it also shows how much work is left to do. Limits only matter if they’re enforced, and safety only holds if the data behind it is current and credible.
So where does this leave us? With a win worth celebrating, yes. But also with a challenge: to keep pushing, keep questioning, and keep shining light on the gaps regulators would rather not talk about.
Because if glyphosate has taught us anything, it’s this: the real story isn’t just what’s written in the rules, it’s how those rules are lived out in practice.
Resources & References
When regulators tell us “trust the science,” it pays to ask: whose science, and whose rules? The resources below shed light on how glyphosate is assessed, where the gaps remain, and why public pressure is still needed.
NZFS Summary of Submissions (October 2025)
The official government document outlining the consultation feedback, themes, and the final decision on glyphosate residue limits.
Why Raising MRLs Threatens Public Health (NoMoreGlyphosate.nz)
Our earlier analysis of MPI’s proposal to increase glyphosate limits, and why public submissions were vital in stopping it.
Roundup vs Glyphosate Toxicity (NoMoreGlyphosate.nz)
Glyphosate is only the active ingredient — the real exposure comes from full formulations like Roundup®. We explore why co-formulants matter.
Glyphosate in NZ Honey: Independent Test Results (NoMoreGlyphosate.nz)
Our independent testing showed glyphosate residues in New Zealand honey — sometimes above the legal limit. Proof that rules mean little if not enforced.
The Monsanto Papers: Glyphosate on Trial
Investigative reporting on how internal company documents revealed efforts to ghostwrite science and influence regulators.
PAN Europe: Hidden Pesticide Formulants
European advocacy highlighting the risks of “inert” ingredients in pesticides and why regulators must assess full formulations, not just actives.
These documents don’t close the debate — they open it wider. If limits aren’t enforced, if formulations are ignored, and if data stays outdated, then what else are we missing? The more we know, the better questions we can ask — and that’s how real change happens.
Image Source & Attribution
The feature image on this page is a screenshot of the Ministry for Primary Industries (MPI) website page: Summary of Submissions on the Proposed Amendment to some Maximum Residue Levels for Glyphosate
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