Risk management proposal: IHS SPECHUMN.ALL

Clause 2.1 (1)

Requirements for canned and other retorted animal products (excluding chicken and duck) from any country have been separated from those for products containing chicken and duck because the latter require different time/temperature cooking conditions to mitigate the risk of Infectious Bursal Disease Virus (IBDV), whereas products not containing chicken or duck, including those containing more than 5% beef derived from Bos taurus or B. indicus, are subject to different heat‑treatment parameters. 

Adherence to time and temperature combinations in Schedule 4 ensures effective pathogen inactivation for high-risk poultry items. The temperature/time requirements to achieve >4D reduction (or >99.99% reduction) for infectious bursal disease virus (IBDV) are based on the MAF CS88 predictive model as outlined in the Import risk analysis on chicken and duck meat for human consumption [PDF, 1.8 MB]

Clarification and requirements regarding edible bird’s nest products have also been added to the IHS. The IHS guidance box states that processed bird’s nest products that are ready‑to‑eat (commonly known as instant bird’s nests) and have undergone heat treatment in a hermetically sealed container to an F0 value of 3 or greater can be classified as retorted products. Therefore, processed edible bird’s nest products that meet these requirements will be categorised as ‘other retorted animal products’ and will also be eligible for import from all countries. As a result, the previous restriction on edible bird’s nests has been removed. 

Clause 2.1 (2) (b)

Mandating heat treatment in hermetically sealed containers to an F0 value of 3 or more ensures effective inactivation of bacterial spores and other pathogens. This recommendation is based on the  Technical review of animal feed processing methods [PDF, 1 MB]

Clause 2.1 (2) (c)

Applying BSE certification for beef products mitigates the risk of introducing BSE from countries or zones listed by the WOAH as having negligible or controlled BSE risk.

Clause 2.1 (2) (d)

Recognising Australia’s robust manufacturing processes and import systems allows products manufactured in Australia or those meeting its import conditions to be considered lower risk. These products must be commercially manufactured, hermetically sealed, heat‑treated to at least an F0 value of 3 and supported by labelling or manufacturer/exporter declarations confirming processing and origin.

The requirements for the commodities covered in clauses 2.2.1 to 2.2.4 inclusive have been adopted from the IHS SPECPROD.ALL without modification. However, a clarification has been added to explicitly exclude "mooncakes with discernible whole egg." The revision from "mooncakes" to "mooncakes with discernible whole egg" ensures consistency across the document.

Clause 2.2.1

Baked biscuits, bread, cakes, confectionery, crackers, and puddings containing dairy and/or egg products (excluding mooncakes with discernible whole egg).

Clause 2.2.2

Dry mixes for cakes and other baked goods, puddings, desserts, and sauces containing dairy and/or egg products.

Clause 2.2.3

Protein supplements and protein bars containing dairy and/or egg products

Clause 2.2.4

Pasta and noodles containing egg products.

Clause 2.2.5 Products containing 5% or less each of dairy, or egg products

Although this has been a long‑standing provision alongside aquatic animal products, the new standard proposes to include only dairy and egg products under a separate category. This change reflects the fact that requirements for aquatic animal products are being moved to a separate category, which will allow for specific requirements for products containing less than or more than 20% aquatic animal content. This change is based on a CTO decision relating to aquatic animal products. In addition, the previous requirement for products to arrive in their original sealed packaging has been removed, as this requirement is already covered under Part 1, clause 1.6 (Packaging and transport requirements) of the IHS.

Clause 2.2.6 Products containing more than 5% but less than 90% each of dairy, or egg products

In the previous IHS, no upper limit was specified for the proportion of dairy or egg content, which created potential overlap with commodity‑specific IHSs and reduced clarity at the border. The introduction of an upper limit of 90% in this IHS provides clearer guidance for importers and border inspectors and helps explain when products should instead be assessed under a relevant commodity‑specific IHS.

For products within this range, additional requirements such as being shelf‑stable, commercially manufactured in retail‑ready packaging, and officially certified as having undergone a heat treatment achieving an F0 value of 3 or higher are considered sufficient to manage the associated biosecurity risks. Based on these factors, MPI considers that these commodities pose a negligible biosecurity risk to New Zealand.

Clause 2.2.6 (2), 2.2.6 (3) and 2.2.6 (4)

The egg products section has been moved to the composite products section, under the category of products containing more than 5% but less than 90% of either dairy or egg products. The previous IHS did not specify an upper limit for the dairy and egg content in specified animal products, which would have resulted in overlap with commodity‑specific IHSs for dairy and egg products. 

Alcoholic drinks, including egg liqueur, advocaat, avocat or advokat, that contain at least 14% alcohol are considered low‑risk products based on the 2016 Rapid Risk Assessment on Miscellaneous Egg Products for Human Consumption, which evaluated the risks associated with beverages containing egg and confirmed their low risk profile, and since the IHS EGGPRODS.GEN generally applies to egg products requiring certification and MPI assessment, the RMP recommends retaining the existing import requirements for these products within the IHS SPECHUMN.ALL without any changes.

Mayonnaise and salad dressing containing no more than 20% egg ingredient are considered low‑risk products, as subsequent technical advice on the risk of Angara disease (November 2018) found that increasing the egg content in mayonnaise from 10% to 20% does not constitute a change in risk due to the very low exposure assessment. It concludes that ‘the following product may be imported from any country provided they are shelf stable and meet the additional requirements: Mayonnaise and salad dressing containing no more than 20% egg ingredient, where the percentage egg is stated on the product label or an accompanying manufacturer's declaration.’ This clause is only applicable to products in retail-ready packaging. Mayonnaise and salad dressings that are not in retail-ready ready packing or that contain more than 20% egg ingredients can be imported under the IHS EGGPRODS.GEN. The RMP recommends that the import requirements for this product be retained within the IHS SPECHUMN.ALL without any changes.

For mooncake with discernible whole egg, the requirements have been taken from the IHS SPECPROD.ALL without any changes.

Clause 2.2.7 Products containing less than 20% aquatic animal products, and Clause 2.2.8 Products containing 20% or more aquatic animal products

These are new commodity categories in the IHS allowing composite products for human consumption containing less than 20% and 20% or more aquatic animal products to be imported, provided they are commercially manufactured, sealed in their original packaging, and clearly labelled or declared as containing less than 20% or 20% or more aquatic animal product. This extension from the standard 5% threshold maintains biosecurity protection because these products are limited to human consumption, are packaged for direct retail sale, and are not intended for further processing, thereby significantly reducing opportunities for waste to enter aquatic environments and limiting exposure pathways to New Zealand’s aquatic animal populations. In addition, any spoilage event (such as refrigeration failure) does not materially increase risk, as it is not permitted to repurpose these products as fish bait or fish feed, and the nature of the products makes such misuse highly unlikely. Overall, the assessed biosecurity risks for this commodity remain effectively managed.

Clause 2.2.9 Pre-cooked heat-and-eat meals containing animal products

These are historic import health agreements with Australia, Canada and the USA, and are consistent with the risk assessments that support the IHSs for unprocessed animal products from these countries. The requirements for these commodities have been taken from the IHS Pre-cooked Heat-and-eat Meals Containing Animal Products for Human Consumption from Australia (HEAMEAIC.AUS, dated 1 November 2001) and Pre-cooked Heat-and-Eat Meals Containing Animal Products for Human Consumption from Canada and the United States of America (HEAMEAIC.SPE, dated 10 April 2014) without any changes. 

Recognising Australia’s established manufacturing processes and import systems, products manufactured in Australia using local or imported ingredients, as well as products that have met Australia’s import conditions, are considered eligible for importation into New Zealand. This reflects the original intent of IHS HEAMEAIC.AUS.

Clause 2.2.10 Processed meat-based foods

Clause 2.2.10(1)

The commodity covered under this clause – "processed foods containing less than 5% meat from any country" – has been relocated from the “Meat and Meat Products” section of the previous IHS (SPECPROD.ALL). This change reflects that the commodity is more appropriately classified under the definition of composite products. The requirements remain largely unchanged, with only minor wording revisions made to improve clarity and ensure alignment with other sections of the IHS, including replacing ‘5% or less’ with ‘less than 5%’.The previous requirement that packaging must not have been opened or broken has been removed, as this is already addressed under Clause 1.6 of Part 1 of the IHS.

Clause 2.2.10(2) and Clause 2.2.10(3)

The commodities covered under these clauses – "meat-based ingredients (such as broth, concentrate, meat extract, flavours, or stock) and processed foods containing meat-based ingredients from any country or Australia” have been separated from the broader category previously defined in the IHS SPECPROD.ALL.

Previously, these products were grouped together under a single category: “meat-based ingredients (broth, concentrate, meat extract, rendered fat, flavours, stock, or tallow), processed foods containing meat-based ingredients, or meat floss.” This grouping has been revised because meat floss is a distinct commodity with discernible meat fibres. The requirements for meat floss have now been separated and relocated to Clause 2.3.1 (pork crackling and meat floss). Further discussion on this change is provided in the following clause.

Rapid Risk Assessment Miscellaneous egg products for human consumption 2016 [PDF, 860 KB]

Import Health Standard: Egg Products 2023 (EGGPRODS.GEN) [PDF, 401 KB]

Clause 2.3.1 Pork crackling and meat floss

Meat floss was previously listed under the commodity category of meat-based ingredients, with a requirement that the product must not contain discernible meat pieces. However, the guidance in the IHS describes meat floss as a cooked and dried meat product with a light, fluffy, thread-like texture. This creates a discrepancy between the defined product characteristics and the applicable requirements. To address this inconsistency, meat floss is being reclassified under the broader commodity category of meat and meat products. The requirements for meat floss will be separated from those applicable to other meat-based ingredients, for imports from both Australia and all other countries, to ensure consistency, clarity, and appropriate risk management.

The requirements for pork crackling remain largely unchanged from the IHS SPECPROD.ALL. However, an additional requirement has been introduced for the product to be commercially manufactured and packaged, to align with other provisions in the IHS and ensure that risk is appropriately managed. Pork crackling may be imported from any country, provided it is commercially manufactured and packaged, and is accompanied by a manufacturer’s declaration confirming that it has been subjected to a heat treatment of F0 3 or greater (see Schedule 3 of the IHS for equivalent time - temperature combinations to achieve an F0 value of 3).

Clause 2.3.2 Alligator meat and alligator meat products

Alligator meat and alligator meat products are commodities being added to the IHS, and the requirements for these commodities are taken from the IHS Alligator (Alligator mississipiensis) meat from the United States of America (MEAALLIC.USA dated 26 August 1998) without any changes.

Clause 2.3.3 Crocodile meat and crocodile meat products

Crocodile meat and crocodile meat products are commodities being added to the IHS, and the requirements for these commodities are taken from the IHSs: Crocodile Meat Products from Australia (MEACROIC.AUS dated 18 January 2010) and Crocodile Meat from Papua New Guinea (MEACROIC.PNG dated 22 July 1999) without any changes.

Clause 2.3.4 Horse meat and horse meat products

Horse meat and horse meat products are commodities being added to the IHS, and the requirements for these commodities are being consolidated from the following three standards as well as a draft IHS on horse meat from all countries and the 

Meat and Meat Products and Other Products for Human Consumption Derived from Horses for Human Consumption from the European Community, MEAEQUIC.EEC dated 15 December 2010.

Horse By-products for Further Processing from Specified South American Countries and Mexico, INEHSPIC.SAM dated 21 December 2011.

Frozen Horse Spleens for Further Processing into New Zealand from Canada and The United States of America, INEHSPIC.SPE dated 28 June 2004.

MPI had been developing a new IHS to consolidate these existing standards, and accordingly a supporting risk advice on Horse Meat and Meat Products (February 2022) was published. Instead, these commodities are now being incorporated into IHS SPECHUMN. The proposed risk management measures are based on the findings of the risk review.

Clause 2.3.5 Rabbit meat and rabbit meat products

Rabbit meat rabbit products are commodities being added to the IHS, and the requirements for these products are taken from the IHS Rabbit Meat for Human Consumption from the European Community, MEARABIC.EEC (dated 4 October 2004) without any changes.

Clause 2.3.6 Camel meat and camel meat products

Camel meat and camel meat products are commodities being added to the IHS, and the requirements for these products are taken from the IHS Camel Meat and Meat Products for Human Consumption from Australia, MEACAMIC.AUS (dated 6 July 2004) without any changes.

Clause2.3.7 Macropod meat and macropod meat products

Macropod meat and macropod meat products are commodities being added to the IHS. The risk management measures are based on the Import Health Standard: Kangaroo Meat from Australia (MEAKANIC.AUS, dated 3 August 1998) and a Supplementary Risk Analysis conducted in November 2022 on the importation of macropod (kangaroo, wallaby, pademelon, and wallaroo) meat and meat products from Australia.

The risk management measures are based on the requirements in the IHS MEAKANIC.AUS and the new risk assessment, and propose the following measures:

• The product must be identifiable as originating from Australia.
• The product must be commercially manufactured and packaged.
• The product must be accompanied by an official certificate confirming that: 
  • The product is commercially harvested from areas not subject to anthrax‑related movement controls and where no anthrax cases have been reported in the 20 days before harvest.
  • Any offal or meat product containing offal is:
    • heat treated to a core temperature of at least 80°C for no less than 10 minutes; or
    • frozen to a core temperature of at least minus 20°C for no less than 2 days.

Biosecurity risk review: Horse meat and meat products 2022 [PDF, 1.4 MB]

Supplementary Risk Analysis: Importation of Macropod Meat and Meat Products from Australia 2022 [PDF, 943 KB]

Clause 2.4.1 Lanolin and lanolin-based products

The requirements for lanolin and lanolin-based products remain unchanged from the IHS SPECPROD.ALL. Commercially manufactured lanolin and lanolin-based products may be imported from any country.

Clause 2.4.2 Tallow and it derivatives

The requirements for tallow and its derivatives remain unchanged from the IHS SPECPROD.ALL. According to the BSE chapter of the Code, tallow and its derivatives with a maximum level of insoluble impurities of 0.15% by weight do not pose a BSE risk. MPI considers an official certificate attesting the maximum level of insoluble impurities of 0.15% in weight is required for biosecurity clearance. The following provision has been added: tallow and its derivatives from any country may be imported provided they are accompanied by an official certificate stating that the maximum level of insoluble impurities is 0.15% in weight.

Clause 2.4.3 Lard and non-ruminant rendered fats

Lard and non‑ruminant rendered fats are commodities being incorporated into the IHS. The requirements for these commodities have been adopted without change from the IHS: Lard and Rendered Fats for Human Consumption from the European Community (MEATALIC.EEC, dated 13 October 2004) and Pig By-products from Canada and/or the United States of America (MEBYPORIC.NAM, dated 18 March 2011). The associated veterinary certificates for these commodities have also been incorporated into this IHS. 

Clause 2.4.4 Emu oil and products containing emu oil

The requirements for emu oil and products containing emu oil remain unchanged from the IHS SPECPROD.ALL. The IHS SPECPROD.ALL state that emu oil and products containing emu oil may be imported from Australia when accompanied by a government-endorsed manufacturer’s declaration that certifies that the emu oil was subjected to a heat treatment process that is effective in raising the core temperature of the product to a minimum of 100°C for at least 1 minute during manufacturing. This requirement remains unchanged. These commodities are assessed as posing a very low risk to New Zealand and are therefore eligible for biosecurity clearance.

Clause 2.5.1 Insect and arachnid-based food products

The requirements for insect- and arachnid-based food products (excluding bee products) have been taken from the IHS SPECPROD.ALL without any changes.

Insect and arachnid-based food products, such as insect-containing hard candy and cricket flour, are becoming a more commonly traded commodity globally. MPI's Technical Advice on the Biosecurity Risk of Insect-based Products Intended for Consumption by Humans and Animals (2015) found that insect products intended for human or animal consumption pose a very low biosecurity risk to New Zealand if:

• The commodity contains insects that were reared in a commercial environment using a formulated insect diet and standard hygienic insect rearing techniques; and
• The commodity is not produced from insects that are wild caught.

The technical advice states that most commercial insect food manufacturers are registered with the US Food and Drug Administration (FDA), apply the processing principles set out in the Codex Alimentarius, including Hazard Analysis Critical Control Point (HACCP), or follow Good Manufacturing Practices (GMP). Some manufacturers may comply with all or a combination of the above systems. Out of the above systems, HACCP is an internationally recognised system commonly applied by food industries.

Commercial manufacturing of insect-based food products commonly involves cooking, freeze-drying or dehydration, all of which makes the insect and any associated pathogens non-viable. The technical advice also states that transmission of plant pathogens can only occur when the insect is alive. While the scope of the risk advice includes only insect-based food products, it would also apply to arachnid-based food products that follow the same harvesting and processing.

MPI has identified recurring importation issues relating to ‘carmine powder’, a food colouring derived from a cochineal insect. MPI has determined that insect‑derived carmine powder is a non‑risk good and therefore is not subject to the requirements that apply to insect‑ and arachnid‑based food products. To reflect this determination, guidance has been added to Clause 2.5.1 to clarify that this clause does not apply to carmine powder, and this product may be imported without a manufacturer’s declaration.

The RMP proposes that insect and arachnid-based products may be imported from any country provided the product is accompanied by a government-endorsed manufacturer’s declaration stating that:

• The insect or arachnid is raised in farms specifically for human consumption; and
• The product is processed in facilities operating a current Hazard Analysis and Critical Control Point (HACCP) programme; and
• The product does not contain viable insects or arachnids.

Clause 2.5.2 Cell cultured/ cell cultivated poultry products

Cell cultured/cell cultivated poultry products are new commodities proposed for inclusion in the IHS based on new market access requests. A technical advice completed by MPI in October 2025 on the biosecurity risks associated with cultured poultry products derived from embryonic fibroblasts concluded that no biosecurity risks were identified. This conclusion was based on a negligible exposure assessment under predicted trade conditions for this commodity. Cultured poultry product is currently expected to be imported in small volumes as high‑value products for human consumption. Waste from these products is anticipated to be minimal, and any agents present are unlikely to come into contact with susceptible hosts and therefore unlikely to cause infection. As cultured meat is an emerging industry, regular review of trade volumes and end‑use will be important to ensure this assessment remains valid.

Based on this technical advice, we are proposing that cell‑cultured poultry products derived from embryonic fibroblasts may be imported from any country, provided they are commercially manufactured and packaged. The product, or the originating cell bank, must be tested and confirmed free of Mycoplasma spp., Newcastle disease, avian influenza virus, Chlamydia spp., E. coli, and Salmonella spp. All additional ingredients must comply with relevant IHSs, and the product must be accompanied by a valid import permit.

Clause 2.6.1 Cultures, enzymes, yeasts, microorganisms and associated products for use in food

The IHS SPECPROD.ALL has following requirements for cultures, enzymes, yeasts and probiotic microorganism and associated products:

• Brewer’s yeast, baker’s yeast or any other yeast products used in the food industry may be imported from any country.
• Commercially manufactured food cultures, enzymes, or starters derived from or consisting of microorganisms (e.g. yoghurt, cheese and sausage starters, enzymes or cultures) may be imported from any country.
• Commercially packaged isinglass air bladder of fish (clarifying agent for alcoholic beverages) may be imported from any country.

These commodities are considered low risk due to their microbial or highly processed nature. Many of these products (such as yeast, food cultures, and enzymes) are widely used in food production around the world and have a long history of safe use. Their commercial manufacture and packaging further ensure consistency, traceability, and appropriate risk management. Importation from any countries continues to be allowed and the IHS now provides clarity that the only requirements are unchanged and are in relation to the status of microorganism in New Zealand. 

In the new IHS, probiotics may now be imported under Clause 2.7.1: Therapeutic products (including dietary and cosmetic products, and traditional and homeopathic medicines), as this category more appropriately reflects their use. Dietary supplements and therapeutic products (excluding those containing bee products) may be imported from any country if intended for human use and meet the specified processing and manufacturing requirements.

Clause 2.6.2 Specified porcine enzymes

These enzymes may be granted clearance provided the product is commercially packaged.

The IHS requires the product is commercially packaged with tamperproof seals applied to bags, and is accompanied by a manufacturer’s declaration which states:

• The product was derived from pigs born, raised and slaughtered in Canada or the USA; and
• The pigs have passed veterinary ante-mortem and post-mortem inspection; and
• The pigs were processed in meat packing premises inspected by and registered with the government veterinary authority of the country of origin of the pigs.

For the purpose of preventing post-processing contamination, tamperproof sealing is deemed as equivalent as hermetic sealing.

The requirements in the veterinary certification stating that African swine fever, foot and mouth disease, hog cholera (classical swine fever), and swine vesicular disease have not occurred in the country of origin of the pigs during the twelve months prior to export to New Zealand have been taken from IHS SPECPROD.ALL without any changes.

Clause 2.6.3 Porcine thyroid powder and thyroid gland

Porcine thyroid powder intended for further processing into a human medicine at a compounding pharmacy may be imported from any country. The thyroid powder will not be in retail-ready packaging, nor will it be further processed into a therapeutic product at a transitional facility. Instead, it will be manufactured into a human medicine at a compounding pharmacy.

We consider that any potential biosecurity risks associated with the product (e.g. African swine fever, classical swine fever, foot and mouth disease, etc.) can be effectively managed through end use. Further processing at a human pharmacy means the likelihood of exposure to susceptible animal species (e.g. pigs) is negligible. The biosecurity risk is effectively managed when the product is accompanied by: 

• An import permit directing the product to a compounding pharmacy for further processing into a human medicine; and
• A manufacturer’s declaration stating that the product has been commercially manufactured and packaged at premises following Good Manufacturing Practice and the principles of Hazard Analysis and Critical Control Points, is shelf-stable, and in dry powder form.

Clause 2.6.4 Horse by-products for pharmaceutical or technical use

The import requirements for horse by-products intended for pharmaceutical or technical use have been adapted from the IHS for the importation into New Zealand of cattle, sheep, goat, deer, horse and pig by-products derived from Category 3 material only, for pharmaceutical use, technical use or pet food from the European Community (INERMLIC.EEC, dated 11 October 2004). Following an amendment to that IHS on 22 September 2022, its scope is now limited to products derived from non-ruminant species, including horses. The associated veterinary certificate for this commodity has also been incorporated into this IHS.

Clause 2.6.5 Pig by-products for pharmaceutical or technical use

The import requirements for pig by-products intended for pharmaceutical or technical use have been adapted from the IHS for the importation into New Zealand of cattle, sheep, goat, deer, horse and pig by-products derived from Category 3 material only, for pharmaceutical use, technical use or pet food from the European Community (INERMLIC.EEC, dated 11 October 2004). Following an amendment to that IHS on 22 September 2022, its scope is now limited to products derived from non-ruminant species, including pigs. The associated veterinary certificate for this commodity has also been incorporated into this IHS.

Clause 2.6.6 Collagen

Collagen may be produced from a range of different animal tissues including bovine tendons, calf skins, sheepskins, pigskins, sheep gut and bovine bones. BSE controls are only relevant to products produced from Bos taurus or B. indicus. Tendons are not a BSE risk material and hides and skins are BSE safe commodities according to the WOAH. Thus, collagen produced from species other than Bos taurus or B. indicus; collagen prepared exclusively from tendons; and collagen prepared exclusively from hides and skins, in accordance with the Code do not pose a BSE risk. Therefore, the requirements for the importation of collagen under the IHS SPECPROD.ALL was categorised under four subclasses as discussed below:

• Collagen derived from any animal species from Australia
• Collagen derived from Bos taurus or B. indicus and prepared from hides and skins, tendons, or cartilage from any country
• Collagen derived from B. taurus or B. indicus, and prepared from bones from any country
• Collagen derived from animal species other than B. taurus or B. indicus from any country

There were no biosecurity controls with regards to scrapie in the IHS SPECPROD.ALL. There is inherent scrapie risk associated with imported collagen due to its wide use in non-food sectors such as the building industry, where it can be incorporated into adhesives, binders, insulation, and other composite materials. These applications can result in diffuse environmental distribution and less controlled handling, increasing the likelihood of occupational and environmental exposure, including through waste streams. Given the persistence of prions in the environment and the significant animal health, trade, and biosecurity consequences of establishment of scrapie, it is necessary to manage the biosecurity risk associated with imported collagen. The Code recommends that hides and skin and collagen prepared from hides or skins of sheep or goat are safe commodities for scrapie. Scrapie controls are only relevant to products produced from sheep or goat. Thus, collagen prepared exclusively from hides and skins, or sheep or goat in accordance with the Code do not pose a scrapie risk.

Although the Code does not provide recommendations relating to BSE for collagen produced from tendons, and from species other than B. taurus or B. indicus, and does not recommend official certification for collagen prepared exclusively from hides and skins, official certification for these variations of collagen will be required to positively attest to these details.

For collagen prepared from non-BSE or non-scrapie risk materials, commercial manufacturing ensures that other risk organisms are managed.

Recognising the manufacturing processes and import systems in Australia, products that are manufactured in this country using local or imported ingredients, or products that have met import conditions of this country are eligible for importation into New Zealand.

Highly processed collagen/ protein product from the IHS SPECPROD.ALL is moved to the IHS MOBIOCELL because it is primarily used in laboratory or research settings within the scope of the IHS MOBIOCELL, rather than for human use as covered under the IHS SPECHUMN.ALL.

Therefore, the import requirements for collagen, when produced from specific animal species (bovine and sheep/goat), have changed significantly for all countries due to revisions in the Code Chapter and the inclusion of Scrapie‑related safe‑commodity provisions in the IHS. However, the requirements for importation from Australia remain unchanged. The following updated measures are proposed for collagen:

Collagen from bovine sources may be imported from any country, provided that it is commercially manufactured and packaged, as collagen is recognised as a safe commodity for BSE in accordance with the WOAH Code, and the controlled processing methods used in commercial manufacture, together with secure packaging, further reduce the likelihood of contamination. Additionally, the previous requirement for an official certificate for collagen from countries other than Australia has been replaced with a manufacturer’s declaration in the new IHS, as the requirement for the product to be commercially manufactured and packaged, together with collagen being recognised as a BSE‑safe commodity, is considered sufficient to manage the associated risk.

Collagen prepared from hides or skins of sheep and goat may be imported from any country, provided that it is commercially manufactured and packaged, as, under the WOAH Code, hides and skins of sheep and goat are recognised as safe commodities with respect to scrapie, with commercial processing and secure packaging further reducing the likelihood of contamination.

Collagen, excluding those of bovine origin and excluding products derived from sheep or goat hides or skins, may be imported from any country provided that, they are commercially manufactured and packaged, and are accompanied by an official certificate that identifies the animal species of origin and confirms that the product is not derived from sheep or goats. This reflects that the primary risk relates to transmissible spongiform encephalopathies (TSEs), which are associated with specific species and tissues, and that certification of species of origin, together with commercial processing and secure packaging, provides assurance that the product does not present an unmanaged risk.

Collagen derived from any animal species may be imported from Australia if it is commercially manufactured and packaged, and either:

• is clearly identifiable as being manufactured in Australia (using Australian local and/or imported ingredients), or
• is accompanied by an exporter’s declaration identifying the product, the country of origin, and the date the product was released in Australia, if it was manufactured in a third country and later imported into Australia.

Clause 2.6.7 Elastin Peptide

Elastin peptide is a new commodity being added to the IHS based on new market access request. The Code recommends that hides and skins are safe commodities for BSE. Therefore, elastin peptide derived from Bos taurus or B. indicus and prepared from hides and skins, may be imported from any country and does not pose a biosecurity risk when other requirements of the IHS are met. For elastin peptide derived from other species of animals, requiring commercial manufacturing process and packaging is likely to manage the risk.

Clause 2.6.8 Gelatine and products containing gelatine

For gelatine and products containing gelatine, the Code recommends that gelatine is a safe commodity for BSE. Commercial manufacturing of gelatine and products containing gelatine is considered sufficient to manage other risks in the commodity. Accordingly, these products may be imported from any country. The requirements for this commodity remain unchanged.

Clause 2.6.9 Dicalcium phosphate

For dicalcium phosphate, the Code recommends that dicalcium phosphate (with no trace of protein or fat) is a safe commodity for BSE. MPI considers an official certificate attesting the product has no trace of protein or fat is required for biosecurity clearance. The RMP proposes that dicalcium phosphate derived from degreased bones from any country may be imported provided it is accompanied by an official certificate stating that it has no trace of protein or fat. The requirements for this commodity remain unchanged.

Clause 2.6.10 Bile derivatives and concentrated bile derived from bovine and ovine animals

This advice recommends heat treatment of at least 100°C for a minimum of 8 hours, and further processing by treatment with sodium hydroxide, to manage biosecurity risks.

The existing requirements for bile derivatives, and bovine and ovine concentrated bile in the IHS SPECPROD.ALL were as follows:

Bile derivatives, and bovine and ovine concentrated bile may be imported from any country provided the product is accompanied by an official certificate that states the product:

• Has been collected from animals that have passed ante- and post-mortem inspection at premises with Competent Authority oversight.
• Has undergone a heat treatment of 100°C for a minimum of 8 hours.
• Has been managed in a way that prevents contamination before dispatch from the processing premises.
• Is in packaging that is clean and free from visible signs of contamination.

For concentrated bile, the technical advice concluded that complete inactivation of Rift Valley Fever Virus (RVFV) and prions cannot be guaranteed by treating at 100°C for 8 hours but subsequent treatment with sodium hydroxide will inactivate RVFV and BSE prion. Therefore, based on this advice the previous IHS SPECPROD.ALL required initial thermal processing at a minimum of 100°C for 8 hours and further processing by treatment with sodium hydroxide in the IHS SPECPROD.ALL.

However, the requirement for sodium hydroxide treatment to manage these two risks was later removed. For BSE, this change was based on evidence showing that PrPC (the normal harmless protein) is barely detectable in liver tissue, meaning PrPSC (the abnormal protein) would be unlikely to be present because it forms only through an in‑vivo conformational change from PrPC; if PrPC is not expressed, PrPSC cannot be produced (WHO Guidelines on Tissue Infectivity Distribution in Transmissible Spongiform Encephalopathies). For Rift Valley fever virus (RVFV), WOAH updated its disease card to state that the virus is destroyed by heating serum at 56 °C for 120 minutes. Therefore, the remaining hazard identified in the technical advice is likely to be inactivated by treating bile at 100 °C for at least 2 hours, instead of the previous requirement of 100 °C for 8 hours.

As these bile derivatives are highly processed and undergo a series of successive chemical treatments, no documentation relating to processing, collection method, or country of origin is required. Similarly, where concentrated bile, regardless of the original time and temperature treatment is further processed into bile derivatives in a transitional facility, the associated risk is likely to be managed.

Bile derivatives may include mixed bile acids, cholic acid, deoxycholic acid, sodium deoxycholate, dehydrocholic acid, ursodeoxycholic acid, bile salts, special bile, bile powder, bile extract, and natural taurine. Because these derivatives are highly processed and undergo a series of chemical treatment steps, no documentation relating to processing, collection method, or country of origin is required. Similarly, when concentrated bile, regardless of the original time and temperature treatment is further processed into bile derivatives in a transitional facility, the associated biosecurity risks are considered effectively managed.

Therefore, MPI proposes that bile derivatives may be imported from any country and no documentation on processing, collection method, or country of origin is required whereas bovine and ovine concentrated bile may be imported from any country provided the product is accompanied by an official certificate that states the product:

1. has been collected from animals that have passed ante- and post-mortem inspection at premises with Competent Authority oversight.
2. has undergone a heat treatment of 100°C for a minimum of 5 hours.
3. has been managed in a way that prevents contamination before dispatch from the processing premises.
4. is in packaging that is clean and free from visible signs of contamination.

Clause 2.6.11 Glycosaminoglycans (GAGs)

GAGs are new commodities proposed for inclusion in the IHS based on new market access requests. GAGs are sugar heteropolysaccharides found in the gel‑like extracellular matrix that surrounds and supports animal cells, alongside fibrous proteins like collagen, elastin, fibronectin and laminin. Chondroitin sulfate is one of the major GAG types. Chondroitin sulphate is abundant in all mammalian connective tissues, especially in the cartilage, skin, blood vessels, ligaments and tendons​. It plays structural role (composition of extracellular matrix and formation of organs and tissues, such as cartilages and bones) and is involved in biological processes (e.g. inflammation, infection and wound repair)​. Chondroitin sulphate is commercially manufactured from bovine, porcine, chicken or cartilaginous fish by-products, in particular cartilaginous tissues, as raw material.

Chondroitin, ligament and cartilage are not in the list of WOAH’s safe commodity for BSE. Bovine origin chondroitin sulphate may pose BSE risks due to the possible presence of BSE prions due to contamination and remnants of BSE risk tissues when the product is sourced from bovine tissues from a country with non-negligible or undetermined BSE risk. BSE prions associated with the raw material from a BSE-infected animal may not be completely inactivated by the commercial production process of chondroitin sulphate. Chondroitin sulphate sourced from bovine animals from countries with a WOAH’s negligible BSE risk status does not pose any BSE risk.

The RMP recommends that GAGs sourced from non‑bovine animals from any country or sourced from bovine animals from countries with a negligible BSE risk status as recognised by WOAH, may be imported provided the product is commercially manufactured and packaged and is intended for human use. These requirements are considered sufficient to manage the biosecurity risks associated with this commodity.

Clause 2.7.1 Therapeutic products (including dietary and cosmetic products, traditional and homeopathic medicines)

This section incorporates the requirements in Schedule 3 - Biological products for therapeutic use on or in humans of the IHS BIOLOGIC.ALL.

Now SPECHUMN.ALL brings all therapeutic product types, including dietary supplements, cosmetic products, and traditional and homeopathic medicines, under one framework. The updated requirements focus on key risk factors such as whether the product is processed, shelf‑stable, and intended for human use. New and updated requirements have been introduced for these commodities, allowing products to be imported if they are in retail‑ready packaging, supported by a manufacturer’s declaration, or approved through a product assessment with an import permit and supplier’s declaration. It also allows microorganisms for human consumption (e.g. probiotics) if they are properly labelled and packaged in retail-ready packaging. These changes set practical requirements that reflect how products are manufactured, traded and used.

These new requirements will benefit importers by providing more clarity about how to meet entry conditions. 

The previous requirements for surgical implants in IHS BIOLOGIC.ALL stated that the packaging must identify the product as sterile. To streamline the requirements across commodities, align with the scope of the new IHS, and provide greater clarity, we have introduced specific requirements for surgical implants that they must be intended for human use and be commercially manufactured.

Clause 2.8.1 Mushrooms for propagation and consumption

Mushroom spawn for propagation was previously imported under the IHS for Microorganisms from all countries (MICROIC.ALL, 31 January 2010). Specific requirements, including eligible species, were applied through permit assessments but were not formally published. The current IHS sets out requirements for mushroom “mother cultures” (pure cultures in agar or broth), mushroom spawn, and inoculated substrates, and brings all related commodities together under the new IHS SPECHUMN.ALL as the most appropriate standard for products intended for human use.

The requirements for pure cultures, mushroom spawn, and inoculated substrates remain consistent with those previously applied through permits but are now explicitly published to improve transparency and enable stakeholder feedback. A minor update has been made to sterilisation parameters for mushroom substrates or spawn in carriers, aligning them with standard autoclaving conditions (121°C, 205 kPa, 30 minutes) in place of the previous parameters (100°C, 100 kPa, 30 minutes), for which no supporting risk assessment could be identified.

At this time, the IHS SPECHUMN.ALL is considered the most appropriate standard to cover these commodities, as they are part of the Animal Kingdom and ultimately intended for human use. This IHS also includes a relevant category (Clause 2.6.1: Cultures, enzymes, yeasts, microorganisms and associated products for use in food), which supports the inclusion of these products.

Clause 2.8.2 Samples of products

Samples of specified animal products are being introduced as a new commodity category in the IHS to allow importers to bring in small quantities of non‑commercial trade samples or samples for analysis before commencing commercial imports. This addition provides a controlled pathway for early‑stage product assessment while ensuring that these goods still fall within the scope of the IHS and meet the necessary biosecurity requirements.

Under the proposed measures, all such samples require a restricted import permit directing them to an appropriately approved transitional facility, subject to a biosecurity risk assessment in accordance with Section 1.8(3) of the IHS. These measures are considered sufficient to effectively manage the biosecurity risks associated with this commodity category.

Clause 2.8.3 Other types of products specified under the categories in Part 2 of this IHS

Novel specified animal products continue to emerge on the market, and it is expected that the scope of this IHS will expand in the future. To accommodate these developments, a separate commodity category is being established to support the importation of such products through a risk‑based approach, ensuring they can be effectively assessed, imported, and incorporated into the IHS SPECHUMN.ALL.

For other specified animal products, the RMP proposes a set of measures that allow goods containing animal products intended for human use and not listed in Part 2 of the IHS, to be imported from any country, provided they undergo a biosecurity risk assessment in accordance with Section 1.8(3) and meet the relevant documentation requirements. Depending on the outcome of the risk assessment, the product may require a general import permit, a restricted import permit directing it to an approved transitional facility, or it may be deemed ineligible for import. These measures are intended to effectively manage the associated biosecurity risks.