 
 
Risk Management Proposal:  
Amendments to  the Import Health Standard   
Importation of Nursery Stock  
155.02.06  
 
 
 
 
 
 
 
 
 
 
Prepared for public consultation  
by Plant Germplasm Import Team  
Animal and Plant Health Directorate  
 
 
 
 
 
 
 
 
June  2023 
 
 
Disclaimer  
 
While every effort has been made to ensure the information in this publication is accurate, the  Ministry  for 
Primary Industries does not accept any responsibility or liability for error of fact, omission, interpretation 
or opinion that may be present, nor for the consequences of any decisions based on this information.  
 
This publication is also available on the Ministry for Primary Industries website at  
http://www.mpi.govt.nz/news -and-resources/publications/   
 
 
© Crown Copyright – Ministry for Primary Industries   
i Contents  
1 General information  1 
1.1 Purpose  1 
1.2 Who should read this document  1 
1.3 What is changing  1 
1.4 How the changes will affect you  1 
1.5 What you can do  1 
1.6 Legal notice about your feedback and the Official Information Act 1982  2 
2 Biosecurity risks associated with Vitis nursery stock  2 
2.1 Likelihood of entry and establishment  3 
2.2 Impacts in New Zealand  4 
2.2.1 Grapevine fabavirus  4 
2.2.2  Grapevine leafroll -associated virus 2 red globe  5 
2.2.3  Grapevine virus E  5 
3 Rationale for the proposed risk mitigation measures  6 
3.1 Why the current measures are no longer a ppropriate  6 
3.2 Why the proposed measures are appropriate  7 
4 Removing the option to import Vitis sourced from open -ground mother plants  8 
References  9 
  
1 1 General information  
1.1 Purpose  
(1) This document explains MPI’s proposed new testing requirements for Vitis nursery 
stock and asks for feedback.  
1.2 Who should read this document  
(2) Read this document if you are or represent:  
• A New Zealand importer of Vitis nursery stock,  
• A PEQ facility in New Zealand that holds Vitis,  
• Anyone with an interest in Vitis nursery stock imports to New Zealand.  
1.3 What is changing  
(3) We are adding three viruses to the pest list for Vitis nursery stock.  
a) Grapevine fabavirus (GFabV)  
b) Grapevine leafroll -associated virus 2 red globe (GLRaV -2-RG) 
c) Grapevine virus E (GVE)   
(4) We propose requiring PCR tests during growing season inspection for the three 
additional viruses on imported Vitis nursery stock.  
(5) We propose  removing the option to import Vitis nursery stock from open -ground 
mother plants  when imported from an offshore MPI -approved facility . 
1.4 How the changes will affect you  
(6) If you are a Vitis importer, your costs will increase, but you will have more confidence 
that your  imported  plants are healthy , and the Vitis industry will be better  protected 
from biosecurity threats.  
a) Each cultivar will need three  additional PCR tests during post -entry quarantine.  
b) A positive result for GLRaV -2-RG will need to be confirmed using Sanger 
sequencing.  
(2) If you are a Vitis importer, you will no longer be able to import Vitis sourced from 
open -ground mother plan ts when importing from an offshore MPI -approved facility . 
1.5 What you can do  
(7) If you want to comment on the proposed requirements, we are accepting feedback until 
5 pm 13th of July . If your feedback arrives after the closing date, we will hold i t on file 
and consider it the next time we review Vitis requirements. Email your feedback to 
PlantImports@mpi.govt.nz .  
 
 2 (8) We value all feedback, whether complimentary or critical. If we’ve done something 
well, let us know so we can keep heading in the right direction. The questions below 
may help guide your submission.  
• Do you believe we are managing the risk  appropriately?  
• Is there anything that is not clear in our rationale for risk management?  
• Do you have information about these pests that may influence our decision?  
• Is there a risk we have not considered?  
(9) We base our requirements on the best scientific knowledge  we have  at the time. If you 
have evidence that could change our conclus ions,  please  include this in your feedback.  
(10) This is a public consultation . We compile all  feedback into a document and publish it  on 
our website. This document includes our responses to scientific evidence  and details of 
any changes we make as a result.  Your feedback, along with your name and 
organisation, will be online and may be read by anyone. See the legal notice below.  
1.6 Legal notice about your feedback and the Official Information Act 1982  
(11) Your submission is public information, and it is MPI policy to publish submissions and 
a review of these submissions on the MPI website. Submissions may also be the subject 
of requests for information under the Official Information Act 1982 (OIA). The OIA 
specifies that information is to be made available to requester s unless there are 
sufficient grounds for withholding it, as set out in the OIA. Submitters may wish to 
indicate grounds for withholding specific information contained in their submission, 
such as information being commercially sensitive or personal. Any d ecision to withhold 
information requested under the OIA is reviewable by the Ombudsman.  
2 Biosecurity risks associated with  Vitis nursery stock  
(12) Grapevine fabavirus ( GFabV ), grapevine leafroll -associated virus 2 red globe  (GLRaV -
2-RG) and grapevine virus E  (GVE ) are viruses that present a risk to New Zealand on 
imported Vitis plants.  Until now, Biosecurity New Zealand has  not had specific 
measures in place to manage the risks posed by these pests . Instead, we managed the 
risks posed by these pests to the best  of our ability using the basic pest management 
measures that mitigate many risks.  
(13) When the risk of GFabV was first assessed  in 2019 , there was no  feasible option to 
manage the increased risk. Biosecurity New Zealand and New Zealand Winegrowers  
agreed that the increased level of risk caused by GFabV could be temporarily accepted 
to allow for trade to continue, until a  more effective risk management option  was 
developed.  We now have a PCR test that can detect this virus, which allows us to 
manage the risk mo re effectively.  
(14) The biosecurity risks posed by GLRaV -2-RG and GVE were captured by Biosecurity 
New Zealand’s emerging risk system and logged for amendment at the next review of 
the Vitis schedule.  
(15) This section outlines the biosecurity risks  posed by  these pests and their potential 
impacts.     
3 2.1 Likelihood of entry and establishment  
(16) We assessed the  biosecurity  risks posed by  these  viruses in 2019  (GFabV) and 2021 
(GLRaV -2-RG and GVE ) and  concluded that they all have high likelihood s of entry and  
establishment in New Zealand on Vitis nursery stock imports . This section outlines the 
information we used to reach this  conclusion.  
(17) New Zealand regularly imports Vitis from countries that have these viruses.  
(18) The viruses can survive the journey to New Zea land on infected plant material.  
• All three viruses infect the whole plant (systemic infection) and will survive on 
live plant material (Stevens, 1983; Angelini et al. 2017 ; Minafra et al. 2017 ). 
(19) Plants infected by these viruses can be asymptomatic  even aft er the PEQ period , so may 
evade visual inspection upon release from PEQ.  
• There is evidence for plants infected by GFabV remaining asymptomatic 
during  two years of inspection (Jo et al.; 2017; Fan et al. 2020).  
• Symptoms of GLRaV -2-RG will only present on specific rootstock and may 
not be visually detectable for up to two years after grafting  (Uyemoto et al., 
2001; Rowhani et al., 2017) .  
• It’s not known how long it takes for plants infected with GVE to develop 
symptoms, but there is evidence of asymptomatic infection (Nakaune et al. 
2008; Rasool et al. 2019) . 
(20) The New Zealand climate is suitable for these pests.  
• All three viruses have been reported in areas with climates that are similar to 
New Zealand’s climate.  
(21) If importers propagate and distribute infected plants, these viruses could spread between 
vineyards in New Zealand.  
• Grapevine fabavirus  and GLRaV -2-RG are graft -transmitted ( Uyemoto et al. 
2001 ; Fan et al. 2007 ; Rowhani et al. 2017 ). 
• Grapevine virus E  is a vitivirus. Vitiviruses are commonly spread through 
grafting. We assume GVE  can also be transmitted in this manner (Minafra et 
al. 2017).  
• Because plants infected by these viruses can be asymptomatic, infection may 
not be detected before distribution.  
(22) Insec t vectors may spread these viruses within vineyards in New Zealand.  
• We have no reports of GFabV or GLRaV -2-RG spreading via insects, but 
other viruses in the same genus ( fabavirus es and closterovirus es respectively ) 
are spread by aphids (Lisa et al. 1998 ; Ferriol et al. 2013 ; Angelini et al. 201 7), 
and it may be possible for New Zealand aphids to spread these viruses too.  
• Grapevine virus E  is spread by two species of mealybug ( Pseudococcus 
comstocki and Planococcus ficus) . While these specific species are not found 
in New Zealand, there are other mealybug species in New Zealand,  and these 
may pose a risk ( Nakaune et al. 200 8; Sabaghian et al. 2020 ).  
 
 4 (23) New Zealand grows many Vitis species commercially and in home gardens, so there are 
many hosts available for the viruses ( AsureQuality 2021; NZPCN 2021 ). 
• Hosts include table grapes, wine grapes and Vitis rootstock (Rowhani et al. 
2000; Angelini et al. 2003; Jarugula et al. 2010; Fan et al. 2015; Al-Rwahnih et 
al., 2016 ; Jo et al. 2017 ; Fan et al. 2017 ; Chiaki et al. , 2020 ; Fan et al., 2020) . 
2.2 Impacts in New Zealand  
(24) New Zealand imports Vitis plants for table and wine grape production. If the viruses 
become established here, they  could have unacceptable  negative impacts on crop  health 
and the profitability  of the Vitis industry . The Vitis industry is very high value in 
New  Zealand,  with an export value of $1 .935 billion  in 2022 ( MPI, 2022 ). Even small 
effects on plant health and grape production could translate to unacceptable  economic 
loss for New Zealand.  
(25) This section outlines the  potential  consequences of these viruses  becoming established 
in New Zealand . 
(26) Within this section, we highlight  uncertainties around  potential impacts. Uncertainty 
arises when the likelihood of a poten tial impact is not clear due to conflicting 
information, gaps in information, or relevance of information not  being  clear.  Because 
of the high value of the Vitis industry in New Zealand  there is a lot at stake if impactful 
pests establish . Consequently, i n our interpretation of the evidence , we have considered 
the worse -case outcome . 
2.2.1 Grapevine fabavirus  
(27) Grapevine fabavirus  has moderate -to-high potential to cause unacceptable impacts in 
New Zealand .  
(28) Leaf malformation and minor reductions in plant health are symptoms of GFabV  
(Al Rwahnih et al., 2016; Fan et al., 2017).  
• We do not know how these symptoms affect plant productivity.  
• As a result, we are uncertain about the impacts of GFabV  infection alone.  
(29) GFabV  can infect a plant alongside  other viruses and form disease complex es (Chiaki et 
al., 2020). One significant complex is made up of hop stunt viroid 1 (HSV -1), grapevine 
yellow speckle viroid 1 (GYSV -1) and grapevine geminivirus A (GGVA)  (Chiaki et a l., 
2020). There is some likelihood of this disease complex forming in New Zealand if 
GFabV becomes established here.  
• HSV -1 and GYSV -1 are both present and non -regulated in New Zealand 
(ONZPR, 2023).  
• GGVA  was detected in New Zealand in 2020, but the regula tory status has not 
been officially assessed  (Veerakone et al., 2020).  
(30) We expect that the symptoms caused by  this complex  will negatively affect production, 
although we have no specific evidence for this , meaning there is some uncertainty about 
effects on production .  
5 • Vitis plants infected with a disease complex of GFabV , HSV -1 and GYSV -1 
show significant plant dwarfing, leaf malformations and vein chlorosis (Chiaki 
et al., 2020).  
• Plants infected with different complexes of these viruses had no healthy leaves 
(Chiaki et al., 2020)  
2.2.2 Grapevine leafroll -associated virus 2 red globe  
(31) Grapevine leafroll -associated virus 2 red globe  has moderate potential to cause 
unacceptable impacts in New Zealand .  
(32) The symptoms of GLRaV -2-RG are severe when infected cuttings are grafted to 
“incompatible” rootstocks ( Uyemoto et al. 2001; Rowhani et al. 2017) . 
• Symptoms only appear on some species of rootstock. We know that some 
species are definitely affected, but there may be more species that  can be 
affected that we do not yet know about ( Uyemoto et al., 2001; Fan et al., 2015; 
Rowhani et al., 2017) . 
• Symptoms include leaf mottling and reddening, necrosis of the rootstock and 
eventual death of the plant ( Uyemoto et al. 2001; Rowhani et al. 2017 ). 
(33) GLRaV -2-RG could spread significantly in New Zealand before it is detected.  
• There is evidence of infected plants remaining asymptomatic for up to two 
years. If we rely on plants showing symptoms for growers or workers to detect 
the virus, any industry a nd biose curity response could begin a long time after 
the spread has occurred  (Uyemoto et al., 2001).  
(34) If GLRaV -2-RG spread s significantly, there could be  large  crop loss es. 
• Of the 11 known susceptible grape varieties, six are table grapes, four are wine 
grapes, and one is rootstock (Rowhani et al. 2000; Angelini et al. 2003; Jarulga 
et al. 2010; Fan et al. 2015) . 
(35) Biosecurity New Zealand has assessed the risk of two other GLRaV -2 strains (“H4” and 
“PV20” ) and  determined that there is not sufficient evidence to justify regulating these 
strains alongside GLRaV -2-RG. 
2.2.3 Grapevine virus E  
(36) Grapevine virus E  has a moderate potential to cause unacceptable impacts on 
New  Zealand .  
(37) The effect of GVE infection on plant pro ductivity is not known. As a result, we are 
uncertain about the effects of GVE infection alone . 
• Symptoms of GVE include necrosis, chlorosis, mottling, mosaic, and leaf 
deformations (Sabaghian et al. ; 2020 ).  
(38) Some viruses cause more severe symptoms when the y infect a plant alongside  other 
viruses  (Moreno and López -Moya, 2020) . 
• Other vitiviruses ( such as GVA and GVB) cause more significant symptoms 
when the plants are also infected with grapevine leafroll -associated viruses 
(Rowhani et al. 2017; Rowhani et al. 2018) .  
 
 6 (39) Grapevine virus E  coinfects with many viruses, including other vitiviruses, 
ampeloviruses, a closterovirus and a foveavirus (Jooste et al. 2015; Vargas -Asencio et 
al. 2016; Diaz -Lara et al.  2019) . 
• This list includes grapevine leafroll -associated virus 3 (GLRaV -3), the most 
important virus disease of grapevine in New Zealand (New Zealand Wine, 
2020).  
i. Based on the effects that other vitiviruses have, we expect that 
coinfectio n could  lead to  more significant GLRaV -3 symptoms, 
exacerbating the overall impact of this virus.  There is no specific 
evidence for this.   
(40) There is experimental evidence of GVE infecting non -Vitis plants, but the possibility  of 
natural transfer from Vitis to other plant species is not known.  
• Sabaghian and others  (2021) demonstrated mechanical rub -inoculation of 
Nicotiana occidentalis and Gomphrena globosa.  
(41) We have a lot of uncertainty a bout the extent of the impacts GVE would  have on 
New  Zealand , and we are limited to estimating impacts based on what is known about 
other similar viruses.  
(42) There is potential for GVE to cause unacceptable negative impacts if it becomes 
establish ed in New Zealand.  
3 Rationale for the proposed risk mitigation measures  
(43) Our current measures for Vitis nursery stock reduce the risk of these viruses  somewhat , 
but Biosecurity New Zealand believes that the likelihood  of these viruses evading 
detection , combined with the potential economic impacts to the Vitis industry indicates 
that there is an unacceptable level of unmanaged risk.  
(44) Biosecurity New Zealand believe that  the level of remaining risk justifies the proposal 
to require specific PCR testing  for these viruses  to achieve  a greater  level of protection .  
(45) When  Biosecurity New Zealand  first became aware of the risk of these viruses,  we did 
not have tests available to detect them, so  we decided to temporarily accept this higher 
level of risk. We were c omfortable accepting the risk temporarily to enable trade to 
continue, in the knowledge that  Vitis nursery stock require a long PEQ period, giving  
MPI time to develop and/or validate  an adequate testing protocol for these viruses on 
imports.   
(46) Now that we h ave PCR tests for these viruses, we can  reduce  the risk to a greater extent . 
This section outlines the unmanaged risks and why the additional measures are being 
proposed.  
3.1 Why the current measures  are no longer  appropriate  
(47) Now that we have a test method to detect these viruses, the current measures are no 
longer appropriate on their own .  
(48) Current measures  for Vitis cuttings include  visual inspection, hot water treatment and 
sodium hypochlorite dipping  on arrival . Plants in v itro (tissue cultures) are subject to 
visual inspection  without treatment . Following these measures, a ll Vitis imports must  
7 enter  PEQ  for 6 or 16 months . During PEQ, plants are tested for other pests , but these 
tests do not detect GFabV, GLRaV -2-RG or GVE . 
(49) The current requirements on arrival do not provide adequate protection against these 
viruses  on imported cuttings or plants in vitro  because:   
• Imports infected with GFabV alone, or GVE alone,  may be asymptomatic, so 
may evade visual inspection  on arrival  in New Z ealand . Symptoms of GLRaV -
2-RG do not present on the commodity types that are eligible for import, so 
this virus will evade visual detection  on arrival in New Zealand . 
• All three viruses infect plants internally (systemic infection), so the viruses 
will survive hot water and sodium hypochlorite treatments on imported 
cuttings . 
(50) The mandatory  6 or 16-month PEQ period , including regular plant inspection,  is likely 
not suffic ient to manage the risk of these viruses.   
• It is known that plants infected with GFabV can remain symptomless for at 
least two years (Fan et al. 2020), and symptomless infections are reported 
elsewhere (Jo et al.; 2017).   
• Plants infected with GLRaV -2-RG c an remain asymptomatic for longer than 
the mandatory PEQ period of 16 months ( Uyemoto et al., 2001) . Infected 
plants will only show symptoms if incompatible rootstock is used for plant 
growth in PEQ ( Uyemoto et al., 2001; Rowhani et al., 2017) .  
• There is e vidence that plants infected with GVE can be asy mptomatic  
(Nakaune et al. 2008; Rasool et al. 2019) . There is other evidence that plants 
can develop symptoms, but  time-to-symptom expression is not known  
(Sabaghian et al. 2020 ). Consequently,  GVE may evade detection in PEQ 
There is a large amount of uncertainty regarding this.  
3.2 Why the proposed measures are appropriate  
(51) Molecular  testing using PCR, or PCR combined with nucleic acid sequencing, is a 
reliable and trusted method for detecting viral infections. The c urrent requirements for 
Vitis imports include testing for other viral pests using PCR. Adding tests for GFabV, 
GLRaV -2-RG and GVE  is consistent with the level of protection against  other  pests 
established on this pathway.  
(52) MPI’s Plant Health & Environment Laboratory (PHEL) has validated  tests which will 
detect GFabV , GLRaV -2-RG and GVE .   
• The PCR  test for GLRaV -2-RG can produce false positives, so a positive result 
will require Sanger sequencing to confirm a diagnosis . PHEL is developing a 
test with an increased sensitivity to GLRaV -2-RG, which may replace the 
current test once it is validated.  
i. We expect that th e new  test will be available in 3 –6 months from 
June 2023, provided that preliminary testing confirms the primers are 
specific for GLRaV -2-RG.  
 
 8 (53) We expect the proposed testing measures  to be feasible for importers. The extra tests do 
not add any time to the quarantine period , and  we do not expect the cost of the tests to 
impact importer business models . Please let us know if this is not the case. Current test 
prices are on our website: https://www.mpi.govt.nz/science/laboratories/plant -health -
and-environment -laboratory/send -a-sample -for-laboratory -testing/tests -and-charges/ . 
4 Removing the option to import Vitis sourced from open -
ground mother plants  
(54) Under our current regulations, Vitis imports from an MPI -approved offshore facility can 
be sourced from mother plants grown in insect -proof houses or grown in open -ground 
fields.   
(55) The option to import material sourced from open -ground mother plants  is an o ld 
regulation that was in place to allow trade from facilities that did not have insect -proof 
houses. That option is no  longer feasible.  It is impossible for open -ground plantations to 
meet the facility hygiene requirements in MPI’s  Standard for Offshore Facilities 
Holding and Testing Plants for Planting , meaning they would not be approved by MPI . 
(56) The updated requirements for offshore facilities were introduced in 2019, and the Vitis 
import requirements have not been updated since th ose measures were introduced.  
Removing the option  to source Vitis from open field  mother plants when imported from 
MPI-approved fa cilities will bring the Vitis import requirements in line with MPI’s  
other standards . 
(57) Removing the option to import Vitis sourced from open -ground mother plants will not 
disrupt or significantly affect trade, as this pathway (importing from an offshore MPI -
approved facility) is not currently active.  
(58) Vitis plants sourced from open -ground mother plants are still eligible for importation 
from non -approved facilities in any country. That import pathway involves importing 
cuttings or tissue culture into Level 3B  post entry quarantine facility in New Zealand.  
 
   
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