1 March 2026
Department of Health, Disability and Ageing
Sirius Building
23 Furzer Street
PHILLIP ACT 2606
By email: gene.technology.implementation@health.gov.au
To Whom It May Concern,
RE: Proposed Amendments to the Gene Technology Regulations 2001
AgForce Queensland Farmers Limited (AgForce) is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool & goat producers. The cane, beef, broadacre cropping and sheep, wool & goat industries in Queensland generated around $11.2 billion in on-farm value of production in 2022-23. AgForce’s purpose is to advance sustainable agribusiness and strives to ensure the long-term growth, viability, competitiveness and profitability of these industries. Over 6,000 farmers, individuals and businesses provide support to AgForce through membership. Our members own and manage around 55 million hectares, or a third of the state’s land area. Queensland producers provide high-quality food and fibre to Australian and overseas consumers, contribute significantly to the social fabric of regional, rural and remote communities, as well as deliver stewardship of the state’s natural environment.
AgForce Grains welcomes the opportunity to provide feedback to the proposed amendments to the Gene Technology Regulations 2001 with focus on the overall regulatory architecture, coherence and long term operability of the National Gene Technology Scheme.
While AgForce Grains supports efforts to modernise and streamline the Scheme toward a more risk-proportionate framework, it raises concerns that prolonged reform—spanning more than eight years—has deferred key policy decisions to future instruments, undermining confidence in a stable and predictable regulatory endpoint. There is ongoing reliance on undefined or discretionary concepts such as “novelty,” designation and regulatory familiarity, which create uncertainty across consultation triggers, licensing pathways and assessment thresholds. This is a missed opportunity to promote regulatory harmony, reduce duplication and have real world benefits to cop production in Australia.
The grains industry in Queensland also have concerns around the increasing complexity within the Scheme. Despite its prominence in the Third Review, gene editing has not been addressed through a clear, coherent policy framework, with indirect regulatory mechanisms risking the capture of low-risk organisms without a strong risk-based rationale. The growing number of notifiable, non-notifiable, licensed and permit-based pathways—combined with containment-based descriptors—may add unnecessary complexity for routine low-risk activities. Additionally, broad regulatory discretion to revisit risks already assessed by specialist regulators risks duplication, inconsistent expectations and gradual expansion of scope.
Overall, AgForce Grains would like to see greater precision, codification and coherence to ensure the Scheme remains transparent, administrable and fit for purpose over the long term.
AgForce Grains has a number of policy positions regarding gene technologies, biological and biorational applications within our broadacre cropping systems. These policy positions highlight the importance of Gene Technologies within the cropping industry of Queensland and Australia for industry progression and food security broadly.
AgForce Grains supports continued research into trialling and testing of individual agricultural products.
The development of biotechnology in plant breeding has the potential to offer significant benefits in production and addressing agronomic difficulties. Ensuring our industry is at the forefront of research and development is critical for Australia to compete internationally.
AgForce Grains supports outcomes-based scientific assessment of gene technologies, genetically modified species and products.
AgForce Grains believes that gene technology is vital to the ongoing success of Australian agriculture and that it delivers huge benefit to the broader Australian economy. The importance of this technology will increase as we strive to build resilience in the face of harsher climatic conditions while remaining globally competitive. Crop technologies must continue to deliver agronomic improvements and environmental benefits to society and our economy. The regulatory scheme must not impede this essential need for biotechnology but rather help facilitate it. The Scheme must focus its regulatory effort towards the highest risk and similarly, be less interventionist where there is no scientific evidence that there will be adverse impacts on human or environmental health. This will ensure the regulatory costs are minimised and that the developers of technologies are rewarded for lower-risk developments. AgForce Grains believe certain novel crop breeding technologies should be excluded from the regulations due to the minimal risk they pose.
AgForce Grains supports the Office of the Gene Technology Regulator (OGTR) in ensuring that research trials and commercial releases are undertaken responsibly and strictly contained within the legislated guidelines.
The Gene Technology Regulator is the legislated body to control the release of any genetically modified organism through its oversight of the Gene Technology Act 2000. OGTR assesses each new Genetically Modified (GM) variety ensuring it does not have safety implications for human health and environmental outcomes. These regulatory mechanisms ensure the controlled development and release of genetically modified crops.
AgForce Grains encourages commercial providers and regulators to develop, accredit and release genetically modified varieties for commercial production in Queensland.
Current biotechnology has benefits for farmers, the environment and consumers, but none are available to Queensland grain growers. AgForce Grains encourages the introduction of commercially available cultivars that suit Queensland conditions.
AgForce Grains supports grain growers having access to an affordable choice of the latest research technology that is best suited to their production needs.
The agronomic options available to producer affect their ability to compete in a chosen production environment. It is critical that growers have access to the best production systems suited to their environments. Access through affordable choices of the latest research technology ensures a more uniform distribution of productive advantage within the industry.
AgForce Grains encourages further education and balance in information to the public regarding the uses of gene technology.
Consumer satisfaction and confidence is essential in maintaining, developing, and providing food and fibre to the community. Public knowledge on gene technology is poorly understood and often misleading. Further education and balanced information is vital to ensure consumers have access to a range of views on gene technology.
AgForce Grains supports individual grain growers having the right to maintain their current farming and marketing practices in the event of the release of GM crop varieties for commercial production.
In the event of the release of GM crops for commercial purpose, producers choosing to utilise their traditional or current marketing and production systems should not be negatively impacted regarding supply chain costs or market access.
AgForce Grains also supports the indepth submission provided by CropLife Australia.
Should you have any questions, or would like to discuss this submission further please contact Brendan Taylor, Grains President on grainpresident@agforceqld.org.au
Sincerely,
Brendan Taylor
Grains President
AgForce Queensland