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Farmers who want to have their say on the National Animal Welfare Advisory Committee (NAWAC) consultation had better be in quick - the submission deadline is today at 5 pm.
It was important that dairy farmers were aware of the proposed changes in the consultation, DairyNZ lead advisor for animal care Katie Saunders said.
"This is a significant consultation for dairy farmers with many changes proposed," Saunders told The Country Sport Breakfast's Brian Kelly.
The biggest changes related to body condition scores, calf-rearing, winter grazing, provision of lying surfaces and the use of top and backing gates, Saunders said.
DairyNZ has also been collecting farmers' feedback for the last six weeks, online and in-person, to help inform its submission.
Despite this, the sheer size of the consultation made it difficult to understand, or foresee its effect on-farm, Saunders said.
"Overall, the scale of change is overwhelming and it's been hard for farmers to assess the impact it will have on their farms.
"The volume of change also makes the code challenging to read."
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Inconsistencies in how minimum standards had been drafted had created more confusion, Saunders said.
"It's added unnecessary text and complexity - making it hard for farmers to know what outcomes they need to achieve and how."
DairyNZ supported a code of welfare that outlined clear minimum standards but some of the current proposed changes didn't appear to meet the guidelines for writing codes, Saunders said.
"[Guidelines] state that the minimum standards should be outcome-focussed and not overly prescriptive. We want to make sure any changes ensure the code is useful and practical."
There are some changes DairyNZ agreed with and others where the intent is right – but DairyNZ has suggested changes to improve clarity or practicality.
For example, they supported strengthening the current body conditioning score minimum standard - rather than the proposed change which provides less clarity for farmers.
The proposed changes for calf-rearing, however, were "too prescriptive," in the volume, frequency and duration of feeding, Saunders said.
"They remove the farmer's ability to decide how to best achieve good welfare outcomes."
For lying surfaces, DairyNZ backed keeping the current minimum standards that had a clear outcome, Saunders said.
"[The focus should be] that dairy cattle must be able to lie and rest comfortably for sufficient periods to meet their behavioural needs."
Saunders said this was preferable to "making prescriptive changes".
While DairyNZ has prepared a detailed submission on the proposals on behalf of its farmers, there is still an option for those who wish to have their say individually as well.
"We've also developed a template to help farmers with making their own submission and we've encouraged farmers to do their own submission over the past few weeks.
"However, if farmers haven't been able to complete that, they can be assured that we're doing a submission on their behalf."
Find out more about the proposed changes and the submission template on DairyNZ's website.