OIA26-0143
27 March 2026
Hayden
[FYI request #33880 email]
Dear Hayden,
Thank you for your email of 27 February 2026 requesting information relating to compliance
costs for food producers. Your request has been considered under the Official Information
Act 1982 (OIA).
All New Zealand food businesses are required to ensure the food they sell is safe and
suitable for consumers. Both food safety and suitability are defined in the Food Act 2014 (the
Food Act). The operator must comply with the Food Act. A requirement of the legislation is
that required food businesses are registered and regularly checked by an independent
verifier appointed under the Food Act.
If there is a food safety or suitability concern, the food business is supported to make
changes and put in place the necessary corrective actions to ensure the food they sell is safe
and suitable. If the food business does not put in place the necessary corrective actions, New
Zealand Food Safety (NZFS) can use enforcement tools to correct the situation. You can
read more about NZFS’s compliance and enforcement approach here:
www.mpi.govt.nz/food-business/running-a-food-business/enforcement-food-act-2014 You requested the following. Please note your questions have been re-ordered for the ease
of response.
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 first year compliance costs for
new micro-scale food producer businesses operating under the
National Programme 1 include registration (every two years) and an initial verification. No further
verifications are required unless there is a cause for concern. Fees are set by individual councils
based on their individual operating budgets and constraints, therefore fees vary across the country.
A survey of the fees councils charge for Food Act requirements is currently underway. Tentative
figures indicate an average cost of around $310 for registration of a National Programme and an
average cost of $467 for an initial (and only) verification.
Ongoing costs would include registration every two years (average of $310 per registration).
Verification costs would only apply if there were ongoing food safety concerns (average of $467
per verification).
Ministry for Primary Industries
Charles Fergusson Building
38-42 Bowen Street
PO Box 2526
Wel ington 6140, New Zealand
mpi.govt.nz
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
NZFS does not hold data on food businesses’ revenue. This part of your request is refused
under section 18(g) of the OIA –
that the information requested is not held by the department
and the person dealing with the request has no grounds for believing that the information is
either held by another department or connected more closely with the functions of another
department.
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.
Table One Applications for exemption under section 33 of the Food Act 2014
Year
Active
Expired
Pending
Refused
Withdrawn
Total
2016
0
0
0
0
2
2
2017
1
6
0
4
0
11
2018
2
6
0
11
6
25
2019
9
7
0
5
4
25
2020
4
14
0
2
5
25
2021
4
8
0
4
5
21
2022
1
7
0
2
0
10
2023
5
2
0
0
2
9
2024
12
1
0
2
4
19
2025
16
0
0
1
2
19
2026
1
0
1
0
0
2
Total
55
51
1
31
30
168
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 col ection points.
Any analysis of the food safety incident rate (complaints, il ness notifications, recal s)
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.
MPI has not undertaken any analysis or assessments on your questions above. Therefore,
these parts of your requests are refused under section 18(e) of the OIA –
that the document
alleged to contain the information requested does not exist.
MPI intends to do a targeted review on the Food Act schedules this year, which wil include
consultation with food businesses. It is possible that Councils wil hold information relating to
food safety incidents in their own areas.
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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.
Under the Food Act 2014, whether a volunteer-based food delivery or collection service is
considered a food business, depends on the activities it carries out. The Act applies broadly
to persons who make, grow, sell, transport, or otherwise trade in food. The absence of profit,
or the use of volunteers, does not remove an activity from the scope of the Act.
Should you have any concerns with this response, I would encourage you to raise these with
the Ministry for Primary Industries at
[email address]. Alternatively, you
are advised of your right to also raise any concerns with the Office of the Ombudsman.
Contact details are: Office of the Ombudsman, PO Box 10152, Wellington 6143 or at
[email address]. Yours sincerely,
Jenny Bishop
Director Food Risk Management
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