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NEW RULES FROM 25 SEPTEMBER 2025

The way composition and labelling exemptions are handled for some exported food products is changing.

  • From 25 September 2025, exporters will be exempt from meeting specific composition and labelling requirements without making an application. These are called "section 345 exemptions" (a reference to section 345 of the Food Act 2014).
  • If the product is not eligible for a composition exemption under section 345, exporters can make an application to MPI. This is called a "section 347 exemption".

More details about the changes and transition periods are on this page.

Government media release

Big win for food exporters as red tape slashed – Beehive

Two exemptions

All food and dietary supplements made in New Zealand must meet New Zealand’s food composition and labelling rules. This includes products that will be exported.

However, there are 2 exemptions that allow products to be made to the importing country’s composition and labelling requirements, instead of New Zealand’s.

On this page, you can find details about:

Composition and labelling exemptions under section 345 of the Food Act

From 25 September 2025, new regulations come into effect.

Food (Exemption of Food for Export) Regulations 2025 – NZ Legislation

The Food (Exemption of Food for Export) Regulations 2025 will allow certain products to be exempted from most of the food composition and labelling requirements of the:

  • Food Standards Code
  • New Zealand Food (Supplemented Food) Standard
  • Dietary Supplements Regulations 1985.

No application will be required, but there are conditions to meet.

The guidance document can help you meet the conditions.

Section 345 exemption guidance [PDF, 600 KB]

Products that can be exempted from most New Zealand composition requirements are:

  • animal products that are food and have been processed or packaged for export under a Risk Management Programme (RMP)
  • dietary supplements that are animal products and have been processed or packaged for export under an RMP.

Products that can be exempted from most New Zealand labelling requirements are:

  • any foods or dietary supplements (excluding wine, non-dairy-based infant formula products, and non-dairy-based formulated supplementary foods for young children) that have been processed or packaged for export under a food control plan, a national programme, a risk management programme, or a regulated control scheme.

There are specific labelling requirements that must be met for exports of dairy-based infant formula products and formulated supplementary food for young children. More details are on this page under the heading 'export requirements for dairy-based infant formula products'

Foods and dietary supplements for export cannot be associated with therapeutic claims or claims of a therapeutic nature.

Transition period

There is a 12-month transition period. During this time, operators can either:

  • use the new section 345 regulations to exempt their products, or
  • continue to use any existing section 347 composition exemptions for up to 12 months.

Related legislation and standards

Food Standards Code legislation – Food Standards Australia New Zealand

New Zealand Food (Supplemented Food) Standard 2016 [PDF, 288 KB]

Dietary Supplements Regulations 1985 – NZ Legislation

Exemptions under section 347

During the 12-month transition period until 25 September 2026, exporters of all food types may continue to use any existing section 347 exemptions. 

However, from 25 September 2025, new section 347 applications will only be granted if the product is not covered by the composition exemptions under section 345.

To get a section 347 exemption, you'll need to apply to MPI by sending us a completed application form.

Application form: FA14 Food Act Section 347 exemption for export [DOCX, 121 KB]

Guidance: Exemptions from domestic food standards under section 347 of the Food Act 2014 [PDF, 423 KB]

Food Notice: Food for Export – Exemptions from Domestic Compositional Requirements 2024 [PDF, 847 KB]

Transition period

Existing section 347 exemptions can continue to be used during the 12-month transition period. From 25 September 2026, any section 347 exemptions that are within the scope of the section 345 regulations will be revoked and operators must instead use a section 345 exemption that meets the conditions specified in section 345 regulations.

Export requirements for dairy-based infant formula products

There are specific conditions that must be met for dairy-based infant formula products and formulated supplementary food for young children.

The specific conditions for infant formula products and formulated supplementary food for young children are in the  Animal Products Notice: Labelling Requirements for Exports of Dairy Based Infant Formula Products and Formulated Supplementary Food for Young Children 2022 [PDF, 276 KB]

Who to contact

If you have questions about export exemptions, email exporterhelp@mpi.govt.nz

MPI business units