New Zealand’s ETS Changes and Tāmata Hauhā’s Kaupapa
Changes to the ETS
On 23 September 2025, the government’s latest set of changes to the New Zealand Emissions Trading Scheme (ETS) were signed into law via the Climate Change Response (Emissions Trading Scheme—Forestry Conversion) Amendment Bill. This was a result of an election commitment and:
“aims to address the widespread conversion of farmland into forestry by restricting the ability to register exotic forestry on certain types of land in the New Zealand Emissions Trading Scheme (ETS)”
In short, the changes include:
- Up to 25% of actively farmed land Land Use Capability (LUC) classes 1–6 can be registered in the ETS on a per farm basis
- LUC class 7-8 land does not have a registration limit
- Additionally, up to 15,000 hectares of LUC6 can be registered through a balloting process
- Transitional provisions for those who have demonstrable interests and investments before December 2024. These provisions are more stringent than originally proposed
- Clarification on key terms such as “unfarmed land”
- A review of the annual hectare limit in 2028
Our Thoughts
Tāmata Hauhā have been engaging with government throughout the consultation process, both through providing a submission, presenting to the Environment Select Committee and via Technical Advisory Groups.
Click the buttons below to read our submission on the proposed changes, or watch our oral submission.
We are supportive of the government’s intention to limit whole-scale conversions of farms to exotic (pine) forest. However, we had many concerns with the policy as introduced and later amended. Unfortunately despite our best efforts, the government did not implement the main policy changes we requested. These included:
- Extending Māori land exemptions to Moriori land on the Chathams
- Provisions for areas like the Chatham’s to be excluded from the LUC-based restrictions. Whilst the Chatham Islands get partial capture under the ‘un-mapped zone’ provisions – they could be mapped in future. The LUC classification system is not fit-for-purpose for the Chatham Islands
- Recommended broadening definitions (e.g., “qualifying forestry investment”) to capture the full picture of afforestation projects and clarifying other definitions
- Removal of the additional “clear interest” test alongside demonstrating a “qualifying forestry investment” to meet the transitional exemption. This was a change of position nine months after Minsters gave commitments to the sector. These commitments have been acted on as planting windows are seasonally constrained, with trees being grown for a whole year in advance of planting. No consideration has been given to the sector to allow for this.
- Excluding alternative forestry models, namely agroforestry (defined as the space planting of trees in a manner that allows pastoral farming to continue underneath) from the restrictions
Moving Forward
The changes outlined above have the ability to significantly affect how exotic forestry is undertaken in New Zealand. However, Tāmata Hauhā’s unique forestry models will largely be able to continue unaffected. How?
- We’re mainly interested in your marginal land, anyway. We want to work with your existing farming system and focus on your unproductive land. This tends to be LUC classes 6-8, or smaller parts of LUC 1-5, land.
- We work with a lot of Māori land which is largely excluded from these regulations
- We incorporate native and exotic planting and offer a tailored design approach
He whenua, he tāngata, he taurikura
Bryony Huirua, Policy & Planning Manager
Forestry regulation is a hot topic – whether that be the Resource Management Act, Emissions Trading Scheme or international policy. At Tāmata Hauhā, we keep our finger on the pulse of these discussions and have the expertise to participate meaningfully. If you have any questions, please don’t hesitate to reach out to us! You can contact our Policy & Planning Manager, Bryony Huirua, via bryony@tamata.co.nz
