Risk management programmes for egg production and processing

If your food business produces eggs, or you're a secondary processor exporting with an official assurance, you probably need a risk management programme (RMP). Find out how to develop your RMP and get it registered, and if your egg business is exempted from registration.

Egg producers and processors must have an RMP

Under the Animal Products Act 1999, most primary processors of eggs need to have a registered and independently verified risk management programme (RMP). If they don't have an RMP they can't trade any eggs.

Primary processing includes:

  • harvesting eggs
  • candling eggs (assessing eggs for freshness, fertility, or defects by use of light, or other candling or defect assessment method, if validated)
  • grading eggs
  • packing whole shell eggs.

The RMP must apply from the layer farm (where the harvesting occurs) through to the packhouse (where the candling occurs).

Secondary processors break eggs open and make egg products. Any secondary processor that needs official assurances for export will also need to have an RMP. Secondary processors that only supply the domestic market can operate under an RMP instead of a registered food control plan (FCP).

If you are operating under a registered FCP you may use it as the basis for an RMP.

Find out how to convert your FCP to an RMP

Purpose of RMPs

An RMP covers good operating practice and manages:

  • hazards to human health (consumers)
  • hazards to animal health (where eggs are used for pet food or animal feed)
  • risks to wholesomeness (anything that is offensive or unexpected in that type of product)
  • risks from false or misleading labelling.

Find out more about risk management programmes

Develop your RMP

You can use our RMP template or write your own.

Risk management programme template for harvesting, candling or packing eggs [PDF, 1.2 MB]

If you write your own RMP, make sure all relevant legislation is met and the programme is shown to be effective.

Egg legislation roadmap [PDF, 1.1 MB]

This guidance document helps businesses to develop their RMP or FCP for pulping eggs:

Guidance document: Egg pulping for RMPs and FCPs [PDF, 710 KB]

RMP evaluations

You may need to get your RMP evaluated by a recognised evaluator.

Your RMP won't need to be evaluated if you use our template and don't change the pre-written parts (except as recommended by MPI).

Waiver of the requirement to provide a copy of an independent evaluation report [PDF, 117 KB]

If you have changed the template or written your own RMP, evaluation is required. You must hire an RMP evaluator to do this.

Find an evaluator working under the Animal Products Act

Register your RMP

Your RMP needs to be registered with MPI before you can start operating. This applies whether or not your RMP needs to be evaluated. Apply for registration of the RMP using the application form AP4. Include the evaluation report, if it's needed. Use Form AP49 to identify the scope of your RMP.

AP4 – Registration of RMP [PDF, 907 KB]

AP49 – Processing categories tables [PDF, 389 KB]

Guidance on applying for RMP registration

Application guidelines for approvals under the Animal Products Act [PDF, 327 KB]

Get your RMP verified

Once the RMP is registered, you must get it checked by an MPI-recognised verifier. They will check the RMP has been implemented effectively. Further verification visits will be done annually, or more frequently if needed.

Find a verifier working under the Animal Products Act

Exemption from RMP requirement

Some smaller egg producers may be eligible for an exemption from having an RMP (clause 11F of the Animal Products (Exemptions and Inclusions) Order 2000). But exemption from the RMP requirement does not exempt you from any other legal requirements.

You qualify for this exemption if you:

  • produce eggs from 100 female birds or fewer (all species included), and
  • sell all eggs direct to the consumer or end-user, and
  • do not sell any eggs to any person for further sale (such as a café, shop, or other third parties).

Female bird count

All your female birds on the laying farm are counted as part of the 100 birds. This is regardless of:

  • their age
  • location
  • whether they are currently in lay
  • whether eggs are the main reason for keeping the birds.

Exceptions include female birds whose eggs are not meant for consumption, such as pet budgies or birds specifically grown for meat production.

If you have clearly separated rearing and laying farms, then you may count only those female birds on the laying farm. But all birds on the rearing farm must be young birds not yet in lay.

If a property is shared by 2 or more egg producers, each would be allowed to have 100 female birds. But they would need to show that their operations are separate (throughout harvesting and packing). However, it is best to keep their operations separate throughout housing, rearing, harvesting, candling, and packing.

Selling eggs

If a person you sell your eggs to on-sells or uses them to prepare food that is sold to someone else, you cannot claim the exemption. You may not know what people use your eggs for, but if you sell them to another business the exemption probably won't apply.

You must sell the eggs yourself. This is normally done at the laying farm, a farmers' market, or by delivering the eggs yourself to the consumer. You cannot have someone else sell your eggs for you at farmers' markets (or any other places) and claim the exemption.

You need to be able to show you meet the requirements for the exemption. This can be done by:

  • having a physical count of the female birds
  • notifying customers that eggs are only for sale to the final consumer and are not allowed to be on-sold or used to make other foods that are then sold.

Who to contact

If you have questions about RMPs for egg processing, email info@mpi.govt.nz

Last reviewed: