Medicinal Cannabis Agency - Pesticide use during cultivation

The Misuse of Drugs (Medicinal Cannabis) Regulations 2019 (the Regulations) set the minimum quality standard that medicinal cannabis products and ingredients must meet before they can be supplied in New Zealand.

Under regulation 18, the following must not be treated with a pesticide unless the pesticide is a trade name product that is registered under the Agricultural Compounds and Veterinary Medicines Act 1997 (ACVM Act) for use on cannabis:

  • any starting material intended for export
  • cannabis from which a cannabis-based ingredient is extracted
  • an ingredient of a medicinal cannabis product.

The Medicinal Cannabis Agency (the Agency) is aware that some growers wish to use pesticides on their crops and the Regulations do not currently allow this. While this issue is explored further, we propose an interim solution of allowing certain pesticide active ingredients to be used on medicinal cannabis crops.

Compliance with the Misuse of Drugs (Medicinal Cannabis) Regulations 2019

Regulation 7, which specifies pesticides that must be tested for and their limits, still applies under this interim solution.  A product assessment application must still include pesticide testing data for the pesticides specified in Regulation 7 in order for a product to be verified against the minimum quality standard.

Compliance with other legislation

Users, importers, and manufacturers of pesticide products in New Zealand must also be aware of their obligations under other pieces of legislation.

All hazardous substances and new organisms are required to have an approval under the Hazardous Substances and New Organisms (HSNO) Act. This includes substances that are imported into New Zealand and/or manufactured here, even if the manufactured substance is intended for export. The Environmental Protection Authority (EPA) is responsible for approving hazardous substances and new organisms for use in New Zealand.

If you want to import, manufacture, sell or use an agricultural compound or veterinary medicine  in New Zealand, you must make sure it is authorised first under the Agricultural Compounds and Veterinary Medicines (ACVM) Act 1997.

Pesticide active ingredients

The following pesticide active ingredients may be used during the cultivation of medicinal cannabis without objection from the Agency.

Please be aware that products containing some of these active ingredients may not be available, or approved for use, in New Zealand.

  • Fatty acids of 8 carbons or more in their chains, and their salts, including ammonium salt of fatty acid (Fatty acids, C8-18 and C18 unsaturated, ammonium salt) and potassium salts of fatty acids (Fatty acids, C8-18 and C18-unsaturated, potassium salts)
  • Active ingredients that are foods or permitted food additives, including canola oil, garlic powder, and potassium bicarbonate, except where the food is deemed a novel food as defined in section 1.1.2 of the Australia New Zealand Food Standards Code and/or the composition of the active ingredient deviates from the physicochemical range or has undergone refining to a level exceeding that accepted as common for the food
  • Sulphur
  • Hydrogen peroxide
  • Products containing ‘mineral oils’ as the active ingredient approved by the Canadian regulatory body, the Pest Management Regulatory Agency (PMRA), for use on cannabis
  • Products containing paraffin oils (CAS: 8042-47-5; 72623-86-0; and 97862-82-3) that are exempt from the requirement of a Maximum Residue Limit (MRL) as published in Schedule 2: Exemptions from Maximum Residue Levels for Agricultural Chemicals, of the New Zealand Ministry for Primary Industries - Food Notice: Maximum Residue Levels for Agricultural Compounds
  • Microbial Active Ingredients1 that are active ingredients in trade-name products registered under the ACVM Act, limited to those active ingredients specifically listed below:
    • Aureobasidium pullulans (strains DSM 14940 and DSM 14941)
    • Bacillus amyloliquefaciens (strain MBI600)
    • Bacillus subtilis (strain D747)
    • Bacillus subtilis (strain ATCC 6051)
    • Bacillus subtilis (strain QST 713)
    • Bacillus subtilis (strain GBO3)
    • Beauveria bassiana (strain ATCC74040)
    • Streptomyces lydicus (strain WYEC 108)
    • Ulocladium oudemansii (strain U3)
    • Indigenous strains of Beauveria bassiana
    • Indigenous strains of Lecancillium lecanii
  • Lactic acid and citric acid - present as fermentation products of Lactobacillus casei strain lpt-111
  • Bacillus thuringiensis subspecies kurstaki
  • Specified microbial active ingredients that are active ingredients in products approved for use on cannabis by the Canadian Pest Management Regulatory Agency (PMRA), limited to those active ingredients specifically listed below:
    • Autographa californica nucleopolyhedrovirus fv11 (baculovirus: nucleopolyhedrovirus Autographa californica (ACMNPV))
    • Beauveria bassiana (strain ANT 03)
    • Beauveria bassiana (strain GHA)
    • Gliocladium catenulatum (strain J1446)
    • Metarhizium anisopliae (strain F52)
    • Trichoderma asperellum (strain T34)
    • Trichoderma harzianum Rifai strain KRL-AG2 (also known as strain T-22)
    • Trichoderma virens (strain G-41)

1. Where Microbial Active Ingredients means any organism classified as a microorganism including but not limited to bacteria, protozoa, fungi and viruses, or the genetically modified or naturally occurring mutants of any of these microorganisms. This includes whole organisms (either viable or non-viable), organism organelles, organism metabolites, organism spores, or occlusion bodies.

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