Consultation on deferring ETS reporting obligations

// Climate Change

The Government’s latest consultation – the Deferral of NZ ETS reporting obligations for animals-farmer activities – relates to its recent announcement about agricultural emissions pricing.

trees and pine

We’ve provided the Government with our views on their proposal to defer the reporting of agricultural emissions within the NZ Emissions Trading Scheme (NZ ETS). We supported the deferral of emissions reporting requirements and reiterated that we do not support the pricing of emissions. 

About the consultation 

This consultation related to existing legislation. The Ministry for the Environment (MfE) released a proposal on 18 August to defer reporting obligations for agricultural emissions from 1 January 2024 out to 1 January 2026. In order to achieve this, MfE needs to change the Climate Change Response Act 2022 (CCRA) since the law currently requires farmers to monitor and then register in the NZ ETS from 1 January 2024.  

The current proposal moves that deadline out two years to 1 January 2026, to give the Government more time to develop a better system for registering, monitoring, and reporting agricultural emissions and create an alternative to the NZ ETS.   

Because this was a short legislation-related process, B+LNZ did not seek farmer feedback but used our existing positions that were informed by previous farmer feedback. 

B+LNZ submitted feedback on 6 September, the day the consultation closed. This was only two and half weeks after consultation opened.  

B+LNZ consultation feedback 

We supported the need for deferral as current timeframes do not allow for the implementation of a reporting system that is workable for farmers or the sector.  

However, we believe the current timeframe to start the reporting of agricultural emissions at the farm-level by 2026 is still overly ambitious. We want to take the time needed to set up a practical and cost-effective farm-level measurement and reporting system that works across the primary sector – our submission sets out some conditions for this. 

Despite the consultation’s focus being on the deferral of emissions reporting and not emissions pricing, we acknowledged that the reporting system will align with the pricing of agricultural emissions. In our submission, we emphasised that there is no justification for the pricing of agricultural emissions.  

We highlighted that the current targets for methane reductions are not scientifically robust nor justified, and that taxing farmers is not the best way to achieve emissions reductions.  

We made it clear that if the Government is to continue to price agricultural emissions, then they must include and acknowledge the following: 

  • strong consideration of the sector’s progress towards emissions reduction targets (the sheep, beef, and deer sector will likely hit the 10% by 2030 target regardless of any pricing mechanism) 
  • the likelihood and scale of emissions leakage as a result of emissions pricing and alignment with competitors’ emissions reductions obligations 
  • ability to fully recogise and reward sequestration taking place on farms 
  • the availability of mitigation tools before any emissions pricing is implemented 
  • equity and fairness within the sector, and with other sectors, is strongly accounted for as part of a just transition 
  • decision-making that is informed in partnership with the sector 
  • a full analysis of the financial, social, cultural, and environmental impacts on rural communities and the wider economy 
  • adequate alignment with other obligations and market expectations.  

Next steps 

Farmers don’t need to do anything at this stage.  

The government intends to introduce mandatory emissions reporting at the farm-level from the fourth quarter of 2024 and to start pricing farm emissions from the fourth quarter of 2025.  

B+LNZ’s advocacy is ongoing. We will continue to argue that the Government needs to take the time to get the system and infrastructure of reporting agricultural emissions right – and that it should not price agricultural emissions.   

We’ll keep farmers updated.  

Read B+LNZ’s consultation submission here (PDF, 651KB)