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Options for export exemptions from New Zealand composition and/or labelling requirements under the Food Act 2014

UPDATE – 8 October 2024

Export exemptions under the Food Act 2014 – Summary and analysis of submissions

MPI has released a summary of submissions from this consultation.

If you have any questions, email Food.Policy@mpi.govt.nz

Summary of submissions [PDF, 418 KB]

Consultation background

All food produced for sale in New Zealand must comply with the applicable composition and labelling requirements of the Australia New Zealand Food Standards Code, and certain New Zealand specific food standards.

Sometimes, New Zealand requirements for composition and/or labelling differ from the importing country’s requirements. In these cases, food businesses are currently required to submit an application to the Ministry for Primary Industries (MPI) to have their food export exempted from New Zealand composition and/or labelling requirements to meet the importing country requirements.

There are limitations with the current individual exemption process, and this consultation sought feedback on some alternative options.

What was proposed

We've proposed 3 options, alongside the status quo, to better enable food exporters to comply with overseas composition and/or labelling requirements.

  • Option 1: Maintain the status quo. This option uses section 347 of the Food Act 2014 to continue to provide exemptions on an individual application/case-by-case basis. This approach means each exemption is specific to a particular food exported to a particular market.
  • Option 2: An exemption in regulations for all food exports from New Zealand standards relating to composition and labelling, with conditions.
  • Option 3: An exemption in regulations for all food exports from New Zealand standards relating to labelling (no conditions to be met) and composition (with conditions to be met, potentially including where health claims are made or government assurances are required).
  • Option 4: An exemption in regulations for all food exports, with a differentiated approach for different classes of product or market. For example, foods that are intended for consumption by a higher-risk population group may have some specific conditions that are different from another class of products.

All options, except the status quo, proposed creating new regulations under the Food Act 2014. The details for each option are set out in the discussion document. 

Submissions closed on 26 July 2024.

Discussion document

Proposed options for export exemptions from New Zealand composition and/or labelling requirements under the Food Act 2014 [PDF, 1.4 MB]

Related information

Food Act 2014 – NZ Legislation

Submissions are public information

Note that all, part, or a summary of your submission may be published on this website. Most often this happens when we issue a document that reviews the submissions received.

People can also ask for copies of submissions under the Official Information Act 1982 (OIA). The OIA says we must make the content of submissions available unless we have good reason for withholding it. Those reasons are detailed in sections 6 and 9 of the OIA.

If you think there are grounds to withhold specific information from publication, make this clear in your submission or contact us. Reasons may include that it discloses commercially sensitive or personal information. However, any decision MPI makes to withhold details can be reviewed by the Ombudsman, who may direct us to release it.

Official Information Act 1982 – NZ Legislation

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