The New Zealand Food Bill is being passed amidst stern criticism of its content and the influence on it by multi-national corporations and the Codex Alimentarius Commission, whose food-safety standards motivated the bill. These concerns illustrate the large democratic and legitimisation deficits in global governance. One response to these criticisms and concerns is global administrative law, which focuses on promoting administrative law tools to enhance accountability. However, an examination of the Food Bill reinforces two main critiques of global administrative law: that it excludes addressing substance of international law and brackets democracy. I argue the limited GAL approach cannot be justified and the significant gaps in its approach require that it engage with democracy. I analyse the possibilities of global administrative law to engage with (to acknowledge and adopt) three theories of global democracy - deliberative, cosmopolitan, and radical pluralism. I argue deliberative democracy offers the most accessible option.

The New Zealand Food Bill is being passed amidst stern criticism of its content and the influence on it by multi-national corporations and the Codex Alimentarius Commission, whose food-safety standards motivated the bill. These concerns illustrate the large democratic and legitimisation deficits in global governance. One response to these criticisms and concerns is global administrative law, which focuses on promoting administrative law tools to enhance accountability. However, an examination of the Food Bill reinforces two main critiques of global administrative law: that it excludes addressing substance of international law and brackets democracy. I argue the limited GAL approach cannot be justified and the significant gaps in its approach require that it engage with democracy. I analyse the possibilities of global administrative law to engage with (to acknowledge and adopt) three theories of global democracy - deliberative, cosmopolitan, and radical pluralism. I argue deliberative democracy offers the most accessible option.