Compliance Costs and Barriers for Micro-Producers

Hayden made this Official Information request to Ministry for Primary Industries

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From: Hayden

Dear Ministry for Primary Industries,

Kia ora,
Under the Official Information Act, I request:

Any analysis, research, or estimates held by MPI of the total first-year compliance costs for a new micro-scale food producer (annual revenue under $60,000) to begin operating under a National Programme Level 1, including council registration fees, food control plan or template costs, and verifier visit costs.

Any analysis, research, or estimates held by MPI of the ongoing annual compliance costs for a micro-scale food producer operating under a National Programme.

The number of food businesses registered under the Food Act 2014 that have annual revenue under $60,000, and any data on the number of such businesses that have ceased operations since March 2016.

The number of applications for individual exemption under section 33 of the Food Act 2014 received since March 2016, and the number granted, refused, or withdrawn.

Any analysis or assessment of whether the current Schedule 3 exemptions are adequate to enable community food networks — specifically, cooperative models where multiple local producers sell through a shared logistics and ordering platform with community collection points.

Any assessment of whether a person who operates a volunteer-based food delivery or collection service connecting local producers to consumers is operating a "food business" within the meaning of section 8 of the Food Act 2014.

Any analysis of the food safety incident rate (complaints, illness notifications, recalls) arising from food businesses operating under Schedule 3 exemptions, compared with food businesses operating under registered food control plans or national programmes.

Any assessment by MPI of whether informed consumer consent, combined with producer competency and batch documentation, could achieve equivalent food safety outcomes to institutional verification under a food control plan, at lower cost.

I am documenting the evidence base for legislative reform to enable community food networks. The Commerce Commission has found that the grocery duopoly earns approximately $1 million per day in excess profits, yet community alternatives face compliance costs that MPI's own regime imposes. If MPI holds no analysis of whether these costs are proportionate to the actual food safety risk from micro-scale local production, that gap is itself the finding.
If any information is to be withheld, please specify the grounds under the OIA for each withheld item.
If this request requires substantial collation or research, please contact me to discuss narrowing the scope before refusing under section 18(f).
this request relates to matters of significant public concern regarding food affordability and competition.

Hayden

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From: Official Information Act
Ministry for Primary Industries

Tēnā koe Hayden,

Thank you for your official information request received on 27 February 2026.

Your request below will be considered, and a decision provided in accordance with the requirements of the Official Information Act 1982.

If you have any questions regarding this request, please email [email address].

Kā mihi,

Official Information Act Team
Government Services | Public Affairs
Ministry for Primary Industries – Manatū Ahu Matua
Charles Fergusson Building, 38-42 Bowen Street | PO Box 2526 | Wellington 6140
Telephone: 0800 00 83 33 | Email: [email address] | Web: http://www.mpi.govt.nz/

-----Original Message-----
From: Hayden <[FOI #33880 email]>
Sent: Friday, 27 February 2026 4:13 pm
To: Official Information Act <[email address]>
Subject: Official Information request - Compliance Costs and Barriers for Micro-Producers

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Dear Ministry for Primary Industries,

Kia ora,
Under the Official Information Act, I request:

Any analysis, research, or estimates held by MPI of the total first-year compliance costs for a new micro-scale food producer (annual revenue under $60,000) to begin operating under a National Programme Level 1, including council registration fees, food control plan or template costs, and verifier visit costs.

Any analysis, research, or estimates held by MPI of the ongoing annual compliance costs for a micro-scale food producer operating under a National Programme.

The number of food businesses registered under the Food Act 2014 that have annual revenue under $60,000, and any data on the number of such businesses that have ceased operations since March 2016.

The number of applications for individual exemption under section 33 of the Food Act 2014 received since March 2016, and the number granted, refused, or withdrawn.

Any analysis or assessment of whether the current Schedule 3 exemptions are adequate to enable community food networks — specifically, cooperative models where multiple local producers sell through a shared logistics and ordering platform with community collection points.

Any assessment of whether a person who operates a volunteer-based food delivery or collection service connecting local producers to consumers is operating a "food business" within the meaning of section 8 of the Food Act 2014.

Any analysis of the food safety incident rate (complaints, illness notifications, recalls) arising from food businesses operating under Schedule 3 exemptions, compared with food businesses operating under registered food control plans or national programmes.

Any assessment by MPI of whether informed consumer consent, combined with producer competency and batch documentation, could achieve equivalent food safety outcomes to institutional verification under a food control plan, at lower cost.

I am documenting the evidence base for legislative reform to enable community food networks. The Commerce Commission has found that the grocery duopoly earns approximately $1 million per day in excess profits, yet community alternatives face compliance costs that MPI's own regime imposes. If MPI holds no analysis of whether these costs are proportionate to the actual food safety risk from micro-scale local production, that gap is itself the finding.
If any information is to be withheld, please specify the grounds under the OIA for each withheld item.
If this request requires substantial collation or research, please contact me to discuss narrowing the scope before refusing under section 18(f).
this request relates to matters of significant public concern regarding food affordability and competition.

Hayden

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