Proposals to strengthen food recalls and risk-based plans and programmes

Closing Date:
Contact: Food policy

Have your say

We want your feedback on proposed changes to strengthen food recalls and improve risk-based plans and programmes. These proposals have their origins in the recommendations made from the independent Government inquiry into the Whey Protein Concentrate (WPC) Contamination Incident.

We are consulting to find the most effective ways to improve food recalls and risk-based plans and programmes through implementing the lessons learned from the WPC incident. We also want to avoid placing unnecessary compliance burdens on businesses. Your responses will enable us to better understand the effects of the proposed changes on you or your business before final recommendations are made to Cabinet.

The consultation runs from 25 October 2018 to 7 December 2018.

Consultation documents

Summary of the food recall proposals

  1. Identifying who must maintain food recall processes: Make the current requirements explicit and ensure that all relevant businesses, including exporters of food, are covered.

  2. Clarifying what traceability procedures should cover and achieve: Businesses must keep accurate records of the foods and products they have brought or sold, and from whom or to whom they have bought or sold them (excluding sale to final consumer). These records must allow them to effectively trace and recall food products. Additional options are presented around tracing ingredients to final products and the tracing of packaging.
  3. Adjusting how long traceability records should be kept for: Same time as currently required, or 1 year past the shelf life of the food product, whichever is longer.
  4. Adjusting how quickly information must be shared during a food safety incident: Traceability information is to be provided to the Ministry for Primary Industries (MPI) within the time specified by a food safety officer, or within 24 hours, whichever is shorter.
  5. Requiring mock recalls to be held: Mock recalls are to be held each year unless a genuine recall has occurred over the past 12 months.
  6. Format of traceability information: Explicit requirement for information provided to MPI to be in a format that is easily usable.

Summary of the risk-based plans and programmes proposals

  1. Requiring hazard management information: Hazard analysis information will be required to be sent in when registering an outline of a risk management programme. This will align with the Food Act and the Wine Act.
  2. Differentiating food safety matters and related regulatory requirements from non-food safety matters: Operators will be required to differentiate their food safety legal requirements from their non-food safety material if they have incorporated both into their risk-based plan or programme. A number of options are presented as to how this may be achieved.
  3. Improving operator access to legal requirements: The main requirements for the contents of a risk management programme will be moved into one set of regulations (currently they are in a number of Notices).

Who do the proposals apply to?

The proposed food recall requirements will apply to all food businesses that either operate under a risk-based plan or programme, or that import or export food for the purposes of trade.

The proposed changes to risk-based plans and programmes apply to businesses that operate under a custom risk-based plan or programme. This includes custom risk management programmes under the Animal Products Act, custom food control plans under the Food Act, and custom wine standards management plans under the Wine Act.

Making your submission

Send us your feedback on the consultation documents by 5pm on 7 December 2018.  

You can email your feedback to

We encourage you to use this template to help you make your submission:

While we prefer email, you can send your submission by post to:

Food Recall and Risk-Based Plan and Programme Proposals
Ministry for Primary Industries
PO Box 2526
Wellington 6140
New Zealand.

What to include

Make sure you include in your submission:

  • the title of the consultation document (in the subject line of your email if applicable)
  • your name and title (if applicable)
  • your organisation's name (if you are submitting on behalf of an organisation, and whether your submission represents the whole organisation or a section of it)
  • information about the size of your organisation (such as annual average turnover, number of employees, or the number of members you represent)
  • your contact details (such as phone number, address, and email)
  • your thoughts on the proposals, including reasons for your views
  • the possible impacts of these proposals on you or your business
  • any changes you would suggest to these proposals and why.

Next Steps

We'll make a summary of the information received from consultation publicly available and will use submissions to inform further analysis.

Submissions are public information

Note, that any submission you make becomes public information. People can ask for copies of submissions under the Official Information Act 1982 (OIA). The OIA says we have to make submissions available unless we have a good reason for withholding it.  That is explained in sections 6 and 9 of the OIA.

Tell us if you think there are grounds to withhold specific information in your submission. Reasons might include that it's commercially sensitive or it's personal information. However, any decision MPI makes to withhold information can be reviewed by the Ombudsman, who may tell us to release it.

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