Re-opening or making changes to a food business in Alert Level 3

There are requirements food businesses must follow to ensure their food is safe for consumers. New Zealand Food Safety has developed easy ways for businesses to meet these requirements so they can get up and running under Alert Level 3, including making changes to the way they operate.

We understand that some food businesses have faced significant challenges under the COVID-19 restrictions. In recognition of this, New Zealand Food Safety has waived the fees that would normally apply to registering a change in scope to your operation. This covers food businesses operating under the Food Act 2014 and the Animal Products Act 1999.

We have waived charges for the required Scope Change Check for food businesses who want to expand their business into making packaged chilled or frozen food for retail sale.

In addition, we have developed material for animal products businesses wanting to add additional procedures into their existing Risk Management Programme, such as packaging, labelling and delivery.

The first step is for you to check if your businesses can operate at Alert Level 3. Visit the Government’s COVID-19 website to learn more about Alert Level 3.

Alert Level 3 - COVID-19

All businesses must follow a COVID-19 safe practice plan

Making changes to a Food Act business

The following steps are for businesses which operate under the Food Act 2014, including butchers, fishmongers, bakeries, delicatessens, cafes, restaurants, takeaways, food service, manufacturers, food transporters, cheesemakers, winemakers and horticultural growers.

These steps will help businesses wanting to add delivery, transport, breaking bulk food into smaller packaging and making chilled/ frozen food. 

Guidance for running a food business during COVID-19 [PDF, 491 KB]

  1. Check your existing Food Control Plan or National Programme to see if you already have all the required food cards ("Transporting food" and/or "Packaging") for your change of scope. If you do, you are all set, just make sure you follow your COVID-19 safe practice plan.
  2. Download the relevant cards for your change of scope and attach these to your plan or programme. This material has been pre-evaluated and does not require further evaluation.
  3.  Let your Registration Authority (New Zealand Food Safety or your local council) know, by email or phone, that you want to add the operation to your scope.
  4. Complete the Re-opening a Food Business Checklist
    Re-opening a Food Business Checklist [PDF, 232 KB]
  5. Start following the additional requirements within your business operation. 
  6. Follow your Safe Practice plan
    COVID-19 Safe Practice plan - Worksafe
  7. Once the COVID-19 restrictions are lifted, you will need to formally advise MPI Approvals if you want to continue with the additional or changed operations.

For food businesses that want to expand their business into making prepared chilled or frozen meals and food, New Zealand Food Safety has set up a Scope Change Check to ensure they are managing the associated food safety risks. The business will be contacted for an off-site interview with a food safety expert within seven (7) working days from when MPI receives the request from the business’s Registration Authority. We have waived the charge for the Scope Change Check.

Making changes to an Animal Products Act business

The following steps are for businesses that operate under the Animal Products Act, including egg producers, dual operator butchers, dairy producers and suppliers of raw drinking milk.

It will help those producers who want to add packaging, labelling and/or delivery of animal products to the scope of their Risk Management Programme (RMP).

  • Download A1 RMP Template for Packaging, Labelling and Delivery of Animal Products. This has been pre-evaluated and does not require further evaluation.
    A1 RMP Template for Packaging, Labelling and Delivery of Animal Products [PDF, 488 KB]
  • Attach this to your current RMP. Including this pre-evaluated RMP template will be considered to be a minor amendment of your RMP.
  • Notify your verifier and MPI Approvals ( that you have added the respective operation(s) to the scope of your business’s RMP.
  • Start following the additional procedures within your business operation.
  • Once the COVID-19 restrictions are lifted, you will need to formally advise MPI Approvals if you want to continue with the additional or changed operations.

Note, farmers selling and delivering raw drinking milk to consumers who are registered under the raw drinking milk Regulated Control Scheme (RCS), must continue to follow the requirements of the Raw Milk for Sale to Consumers Regulations 2015 and Animal Products Notice: Raw Milk for Sale to Consumers as well as meeting the COVID-19 rules for home delivery.

Raw Milk for Sale to Consumers Regulations 2015

Animal Products Notice: Raw Milk for Sale to Consumers [PDF, 926 KB]

Any questions?

For Food Act questions, contact us at or phone 0800 00 83 33.

For Animal Products Act questions, email or phone 0800 00 83 83.

For latest sector-specific advice on COVID-19:

Re-opening your food business since Alert Level 4

If you are permitted to open, what you do next will depend on the condition of your premises and equipment, the availability of services and staff, the condition of food in stock and the type of food you want to sell.

The following points and the Re-opening a Food Business Checklist provide a summary of the most important food safety things to consider when re-opening for business.

This guidance is relevant to all food and beverage businesses.

For more information about what Alert Level 3 looks like and where your business fits in, go to the Government’s COVID-19 website.

Re-opening a Food Business Checklist [PDF, 232 KB]

Safe work practices for businesses and workers

Alert Level 3 - COVID-19

Businesses permitted to open

Food businesses can operate under Alert Level 3 so long as they deliver or offer pre-arranged collection of goods bought online or by phone. Some specific examples include butchers, bakeries, greengrocers and takeaways.

Sales of primary produce direct to consumers can likewise only be done only by contactless delivery or pre-arranged contactless pick up. This will mean that farmers’ markets cannot be held, but pre-arranged collection of goods bought online or by phone can be arranged.

Businesses that require face-to-face contact, or people congregating in a specific area, remain closed under Level 3.

Safety and hygiene checks for reopening food businesses

Food businesses reopening under Alert Level 3 should go through the following checks to ensure food safety and hygiene practices.

  1. Are premises OK for preparing or handling food?
    • Once your building has formally re-opened, you will need to make sure that nothing has happened during the closure that stops you from operating safely. Is there a chance that food will become contaminated from something that happened when the business was closed, such as maintenance activities, or a leaking pipe? Make sure the services you need for power, water supply and drainage are working as intended.
    • Have pests become a problem? Check for signs of insect pests (e.g. cockroaches) and rodents (rat, mice droppings, gnawed food and food packaging). Get rid of pests before re-opening. Throw away food exposed to pests and in gnawed packaging. Clean other packaging and follow steps in 2 below before opening.
  2. Are toilets and personnel hygiene facilities working?
    • Make sure toilets and handwashing facilities for staff are in working order and have soap and towels. 
  3. Can the premises be thoroughly cleaned before use?
    • Areas used for food preparation and serving will need to be thoroughly cleaned, and food preparation surfaces and utensils cleaned and sanitised before use to ensure there is no risk to food safety.
  4. Is the water safe to use?
    • Follow information from the Ministry of Health for flushing-through water systems before you start to clean and sanitise food areas. If you notice anything unusual with the colour or cloudiness or smell after this, contact your water supplier for advice. If you know of a water supply issue near your business, confirm with your supplier it is OK to use the water. Further information about water in food businesses can be found at:
    • Don’t forget to flush clean water through machines that are plumbed into the water supply, such as ice machines, drinking fountains, coffee machines, slush-ice makers, post mix guns, self-service soft drink machines and water coolers, especially if these haven’t been turned off during lock-down.
    • Further information about water in food businesses
  1. Is food still safe to use?
    • Check whether fridges, chillers and freezers have been without power, as the safety of stored food may have been affected. As a 'rule of thumb':
      • If power was off for more than 24 hours, or chillers were opened, potentially-hazardous foods (such as foods that contain meat, fish and dairy products) should be thrown away.
      • If power to fridges and chillers was off for less than 24 hours, and chillers were not opened, contents must be checked for odours and other signs of spoilage before using.
      • Perishable foods in the chiller, for example fruit and hard cheeses, may still be safe to use if these are not showing obvious signs of spoilage.
      • If a freezer was full, power was off for less than 4 days and the freezer was not opened during the power cut and there is no evidence of thawing, contents should be OK to use.
      • If the freezer was opened during the power cut, the freezer was not full, there is any evidence that contents have completely thawed, or have thawed then refrozen, throw this food out. Don’t feed it to pets or use as pig food.
      • Throw out any food beyond its use-by date. And don’t feed it to pets or use as pig food.
      • Throw out any food beyond its Use-By date.
      • All opened ready-to-eat food (such as processed meats), should be thrown out, even if it is within the Best-Before or Use-By date.
      • If in doubt, throw it out.
    • Food still frozen with ice crystals throughout can continue to be kept frozen, if you are sure it did not thaw out and then re-freeze when the power came back on. Frozen food that has defrosted and was refrozen when the power was restored should not be used. This will not always be obvious, but important signs of defrosting and refreezing will be: misshapen products; drip from packaging that has become frozen; packages stuck together; or the pooling of frozen fluids in the bottom of sealed packages. Again, if in doubt, throw it out.
  2. Is refrigeration working?
    • Make sure chillers, freezers, display cabinets and other equipment will work as intended.
  3. Food for sale or wholesale
    • For restaurants and cafe businesses, think about providing food that needs minimum handling and is thoroughly cooked; particularly until you have identified what normal trading will look like for you and your staff, and you get back into routine.
  4. Sourcing new supplies
    • If you are restocking chilled and frozen food from suppliers that were not trading during COVID-19 Level 4, check your supplier has taken the steps in 5 above.
    • If you are supplied with different products or brands, check they meet your recipes and/or processes and don’t contain unexpected ingredients or allergens. If these do, you will need to let customers know what these are.
  5. Are your staff available and know what to do?
    • Any new or replacement staff must receive food safety training before starting work. It is a good idea to remind staff of sickness policies, and that it is always vital that hands and food preparation surfaces and equipment are kept clean, even more so at this time. If in any doubt about what you should do, contact your food safety verifier.
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