Getting Your Food Labels Right

Food Recalls:

Last year MPI notified 68 food product recalls in New Zealand. Many of these were for non-compliant labels.

Recalls are conducted where there is likelihood that consumption of the foods may cause adverse impacts.  A fundamental requirement for all food businesses is to ensure that the products they deal with are safe and suitable.

The chart below breaks down the recalls into several categories:

Labelling:

The focus of this article is the largest category of food recalls: non-compliant labels.  Drilling into this a little further:

• 41 % were for incorrect allergen declarations (including warnings) of which

  • 26 % were not designed in compliance with the FSANZ requirements

  • 15 % were packed using incorrect packaging, or the wrong label was applied

• 3 % for incorrect date mark (Best before / Use by etc.)

Preparation of accurate retail food labels that comply with the Food Standards Code can be very complex, particularly for products that contain numerous ingredients.  This can be made more difficult for imported pre-packaged foods where the importer may not have intimate knowledge of the suppliers’ raw materials, ingredients and production processes.

To minimise the chances of labelling errors, all businesses should have procedures for; the preparation of food labels to ensure compliance with the Food Standards Code, and to ensure that the correct packaging and labels are used.

1.                  Label design

It’s important that all inputs to the process are known and their purpose understood.  This includes raw materials, ingredients, additives and processing aids.

Many things added to foods are compound ingredients – they themselves contain several sub-ingredients.  Do you know what these are and whether they must be labelled in the final food?

Do additives in one of the ingredients perform a technological function in the finished food?

Do processing aids or additives contain allergens that must be identified in the finished product?

Are all the additives in the food permitted for use in New Zealand?

What are the limits for additives and processing aids?

MPI provides several documents and checklists that can assist you to get your food labelling correct.

You can find the guides which include the checklists below:

• Retail Food Labelling Guide

• Allergen Labelling Guidance

• B2B Food Labelling Guide (for those selling foods not packed for retail)

We recommend that you utilise these guides and checklists if you choose to manage your own food labels. 

For single ingredient products, this may be relatively straight forward.  However for complex products it’s not for the faint hearted!  Give us a call if you would like to discuss your labelling requirements.

2.                  Packing and Labelling

Most aspects of labels are pre-prepared and either incorporated into the food packaging or applied as labels to other packaging.  However for many manufacturers there is an additional requirement for variable information to be applied to foods relating to the lot detail and date mark – which vary over time.

Procedures need to take both these labelling requirements into account.

To minimise the risk of incorrect information being applied to the products, its good to have line clearances procedures:

• Each time a product on a processing line has been completed, remove all packaging and labels that are specific to that product

• When the new product is introduced, have somebody independently check that the product and packaging/labels match, and independently check the variable information has been calculated and set up correctly.  It’s useful to keep records that these set-up and checking activities have been completed before commencement of packing/labelling commences

Good practice may take a little work up front but will save a lot of cost for rework and or recall if good practices are not maintained. If you would like a hand to understand how to manage your packing and labelling procedures, please contact us.

Food Labelling Changes for Sugar Claims

The Australia New Zealand Food Standards Code has recently been amended to restrict the claims able to be made by food suppliers regarding sugars.

Sugars in foods and beverages contribute more energy to typical diets in New Zealand than is recommended.  The regulatory changes have been made to prevent products that contain high levels of sugar, such as fruit juices, from being labelled as having no added sugar.

The reason for this is that research has shown that where “No Added Sugar” claims are made to products are naturally high in sugar, a large proportion of consumers believe them to be a healthy choice. 

The changes to the Australia New Zealand Food Standards Code (ANZFSC) took effect on 13 December 2023.  However, a transition period of 4 years has been granted before “no added sugar” claims must comply with these requirements.  Following this there is a stock in trade provision allowing products labelled prior to 13 December 2027 to be sold up until 13 December 2029.

No Added Sugar:

When implemented, these changes to Schedule 4 of the  ANZFSC will not permit claims of “No Added Sugar” when no sugar has been added, but:

• Foods contain more than 10 g of total sugars per 100 g of solid foods, or

• Beverages contain more than 7.5 g of total sugars per 100 ml of the liquid food

The code now also defines what constitutes ‘added sugars’.

Added Sugars include 13 different classes of sugars:

• hexose monosaccharides and disaccharides

• low energy hexose monosaccharide D-tagatose

• starch hydrolysate

• glucose syrup

• maltodextrin and similar products

• a product derived at a sugar refinery (including brown sugar, molasses, raw sugar, golden syrup & treacle)

• icing sugar

• invert sugar

• sugar and sugar syrup derived from plants

• honey

• malt

• malt extracts

• any of the following unless the food for sale is a prescribed beverage: concentrated fruit juice, concentrated vegetable juice, deionised fruit juice & deionised vegetable juice

When used in “prescribed beverages” the following are exempted: concentrated fruit juice, concentrated vegetable juice, deionised fruit juice & deionised vegetable juice.

Prescribed beverages are:

• brewed soft drinks

• formulated beverages

• juice blends

• fruit drinks

• fruit juices

• vegetable juices

• water-based beverages

Unsweetened:

Within the Conditions for nutrition content claims of section of Schedule 4 – 3 (Sugar or sugars) there have also been minor changes regarding “Unsweetened”  claims.  Now foods and beverages containing the intense sweetener erythritol, and the low energy mono-saccharide D-tagatose may not be described as “Unsweetened”.

Conditions for Nutrition Content Claims:

It’s important that any claims made in relation to products comply with the ANSFSC requirements.  The rules around claims are not limited to product labels.  Any advertising or publicity material (including websites) that presents or implies certain features in food products must both be truthful and comply with the requirements of the Code.

If you currently make “No Added Sugar” claims on your products, you will need to check that they remain compliant and if not, ensure labels and supporting media have been revised to meet these requirements and are in use when the transition period ends.

For anyone wanting help with their Label Claims, or product formulations to allow specific claims to be made, please contact us.

Synthetic Foods

Animal product analogues have been around for a while.

Alternative Dairy products, extracted from vegetables include soy, oat and almond milks.

Similarly meat analogues have been made using vegetable proteins including gluten and soy, in combination with other ingredients to provide tastes, textures and visuals that are often designed to mimic those of meat products including bacon, sausages, meat patties etc.

Most of these products were intended to either provide vegan / vegetarian “alternatives”, and for some to avoid dairy allergen or lactose intolerance.

Increasingly environmental sustainability has become a driver for moving away from products derived from intensive livestock farming to production of synthetic ingredients and food:  dairy proteins, cultured meat and novel cellular proteins for example.

Farming of cattle, sheep, pigs and poultry results in high emissions of greenhouse gasses directly from the animals as well as from the husbandry practices (fuel for farming and transport and feed production).  Emissions of nitrogen into soils and waterways is also a feature of pastoral agriculture.  For many the desire for synthetic food products also includes elimination of animal welfare concerns associated with traditional farming and harvesting practices.

Many synthetic foods will require raw material inputs from agriculture with the associated environmental costs of inputs but with the anticipated benefits of:

• Better conversion rate of feeds to product outputs (only the edible part is produced – no organs, bones, fur, feathers or scales)

• Significantly reduced water use

• Limited discharges of nitrogen to soils and waterways

• Significantly lower overall requirement for agricultural land reducing the need for ongoing destruction of natural ecosystems, and allowing land to be returned to nature

Today, the direct dollar costs of producing many synthetic foods is generally orders of magnitude higher than that of traditional agriculture.  However, as these new technologies mature, costs will come down.

The ultimate in minimising environmental impact is represented by systems that utilise minimal inputs – Gases from the air (such as nitrogen, carbon dioxide and oxygen), water and a small amount of nutrients, driven using renewable electricity.  However many will still require huge investment and traditional agriculture (typically plant based) to produce inputs (sugars, amino acids and lipids) for the growth media in sufficient purity and quantity.

A range of different synthetic food production technologies are discussed below.

Cell Culture:

Growing foods in bioreactors or fermentation vessels provides the opportunity to greatly reduce the physical space required for food production, whilst simultaneously moving to a more sustainable future.

There are two key areas currently being explored intensively with the target of reducing humanities reliance upon traditional agriculture.  It may be considered that cell culture is at the heart of these technologies.

The first is to grow animal cells to replicate the flesh of farm animals, fish and poultry: cultivated meat. 

The second is to utilise fermentation: either directly as foodstuffs (Biomass Fermentation), or to produce specific compounds to be used as functional ingredients in foods (Precision Fermentation).

There are challenges to commercialising synthetic foods, though there are numerous governments, research facilities, and companies working in this space.  Requirements for commercial success of such products include having:

• the technical capability to produce the foods economically

• sufficient customers willing to purchase and consume the food

• legislation allowing these novel foods to be traded

Cell-cultured meat:

From the first synthetic meat made in 2013 in a Dutch laboratory, to commercial sale of synthetic chicken in Singapore in 2021, the scale and diversity of cultured meat continues to expand.  However it remains a drop in the proverbial ocean of global meat consumption.

Work is being done creating meat from a range of farm animals (beef, pork & chicken) and fish species (including eel, bluefin tuna and carp).  Other companies are working on providing meat from “exotic” species: products people wouldn’t ordinarily consume, but the novelty factor adding “value”.

The starting point for this process is typically stem cells that are extracted from live animals.  The stem cells, in an appropriate environment, will multiply and differentiate into muscle cells, collagen and fatty tissue, producing structures very similar to skeletal muscles from farmed animals.  The Nutritional characteristics are equivalent to those of the parent animal.

Many companies are operating in this space, though few are producing products for commercial sale.

Singapore is seeking to reduce its reliance on imported foods and their Government has legislated accordingly.  Singapore became the first country in which cultured meat was permitted to be sold to consumers – in the form of cultured chicken nuggets briefly in 2021, and currently cultured chicken via a Butchery & Bistro.  Only very limited quantities of cell cultured chicken are available.

The US approved 2 companies for sale of cell cultured meat in mid 2023 – to be sold as “cell-cultivated chicken”.  Very small quantities are available to the public via restaurants the businesses have partnered with.

Although widely anticipated to have a significantly lower environmental impact than traditional farming, different studies have produced vastly different outcomes in terms of environmental impacts.  Only as the cultivated meat industry scales up will compelling data become available.

In order for cell cultured meat to scale to a level that has a meaningful impact on global food supply, the following developments are required:

• Growth Media:  This is essentially the equivalent of blood plasma – providing the environment for cellular growth.  Traditionally Foetal Bovine Serum has been used at key stages culture, but this is both extremely expensive, and requires beef processing at scale to produce it.  Developing an animal free culture medium is high on the priority list for most organisations involved.  However the components must be of very high quality and purity to avoid contamination (microbiological & chemical).  Preparing the perfect balance of sugars, amino acids lipids and growth factors requires a whole suite of inputs and manufacturing processes.  It’s unlikely these materials will be easy to produce at scale, or cheap to ramp up.

• Meat Structure:  For many potential consumers, having products that replicate the products they are used to is critical.  Fermenters can produce tissue cells – akin to sausage meat in structure  once separated from the culture media.  A range of technologies are being developed to provide either bio-scaffolding or other means to encourage growth in natural meat like portions containing muscle, collagen, and fat tissues in appropriate proportion and structure.

• Scaling up:  To displace an appreciable volume of meat sourced currently from agricultural practices, huge volumes of meat will need to be cultivated.  Currently the bioreactors are relatively small and conducted in conditions suitable for pharmaceutical grade products.  The cells being cultured have no immune system, so rely upon the culture environment and  all inputs being free of microbes – viruses, bacteria, yeast.  All phases of cell culture will need to remain free from biological contamination throughout the process.  So not only will the scale need to become vast to bring down costs, but to maintain the required hygiene the infrastructure and inputs will need to be “sterile”.

• Regulatory Considerations:  Only two countries have regulatory environments that permit the sale of cultured meat – Singapore and the US.  Issues that currently arise in many jurisdictions include the use of hormone growth promoters which is banned in the EU and many other areas.  The definition of these products needs to be settled in most countries, and this includes the naming – is it actually meat or muscle.  How the food safety Hazards are addressed also needs to be determined be each country.  Finally several countries have banned cell cultured meat!

Fermentation:

Bacteria, algae and fungi have been used for millennia to produce foods and beverages.  However in relation to synthetic foods most applications would produce novel products.

• Biomass Fermentation:  utilises the whole organism, typically protein rich, as the foodstuff.  Species are selected based on the characteristics desired.  Some sources in addition to providing excellent amino acid profile, also offer modest amounts “healthy” lipids, fibre and nutrients such as vitamins and minerals.  Genetic modification may be used to enhance the nutritional profile of the organism, or the substrates from which it is cultured.  Biomass fermentation probably offers the most significant opportunity for the reduction of resources used to create synthetic foods in comparison to traditional farming.  Many companies are currently using fermented biomass to produce “meat-like” analogues and provide viable alternatives to animal based agricultural products.

• Precision Fermentation:  Utilises microorganisms to produce functional products – typically proteins (including enzymes), but possibly also lipids and vitamins.  This technique has been used for decades to produce Insulin for diabetics, and rennet for cheese making – pharmaceuticals and high value food components.  Most applications rely upon gene manipulation (Genetic Engineering) to produce the intended product efficiently.  The target genetic material is inserted into a host organism which operates as a “cellular factory” churning out the target material in large quantity very efficiently.  Current food focussed developments include:

  • milk proteins (casein, lactoferrin)

  • meat proteins (myoglobin, collagen)

  • egg proteins

  • Lipids

  These technologies may allow the transition from dairy cow based human infant nutrition to utilisation of human identical milk components.

  Precision fermentation products are likely to contribute to improving the nutritional profile, taste & texture of non-animal foods to provide more “authentic” meat analogues.  This may also play a significant role in providing components for the growth media for cell-cultured meat.

  One significant issue associated with precision fermentation is the “unnaturalness” of such materials.  GMO foods are currently highly controlled in many countries and avoided by many consumers.

Outlook:

Biomass fermentation is in widespread use in the production of food alternatives to traditional animal farming and will continue to increase its market share as new technological developments are made.

Similarly Precision fermentation has been used for decades to produce high value proteins, enzymes, vitamins and food colours.  Advancements in gene manipulation technologies has opened the door to wide ranging advancements in this field.  These will be cheaper to produce and utilise significantly fewer resources than those from traditional sources.  New products will increasingly be available improving nutritional values. 

The most challenging technology to commercialise in a meaningful way will be cell-cultured meat.  Costs have reduced by several orders of magnitude from the initial successes a decade ago.  However, significant developments are required to allow cost parity with traditional agriculture.  Hurdles that need to be overcome include sourcing culture media that is not from animal source and scaling up to very high volume production.

The synthetic food sector is moving at pace and one of the greatest limitations is the regulatory environment which typically does not keep pace with science and technology.

Creating a Documented Risk Management Programme (RMP)

Why use a Risk Management Programme (RMP)?

“All” New Zealand food Businesses must operate according to the regulatory requirements of the Food Act or Animal Products Act.  Certain primary and secondary processors of animal products must operate a Risk Management Programme (including for some non-food animal products), whilst other operators may instead choose to operate under the Food Act.

Generally if exporting animal materials or products to overseas countries where Official Assurances are required (eg Health Certificates, or Export Certificates), then an RMP is generally required.

For many operators using the MPI “Food Safety Rules” tool will indicate whether an RMP is required.

If you’ve completed this tool and had an in interview with MPI to confirm the outcome is a Risk Management Programme (RMP), then the development phase begins.

The normal process for operating a RMP is as follows:

1. Document the RMP (the main focus of this issue)

2. Have your RMP evaluated (generally not required for those operating only a Template RMP)

3. Register your RMP with MPI

4. Operate your RMP

5. Have your RMP verified

For people establishing a new animal products business the process of establishing a RMP can be daunting.  For those in sectors where there is no industry Template RMP, it’s even more complex.  Understanding the RMP requirements is important both for developing the documentation but also to ensure that the buildings, facilities and equipment are fit for purpose.

Expensive mistakes can be avoided by gaining a good understanding of the requirements early on.  eg prior to investing capital in equipment that is not of hygienic design, or committing to a multi-year lease for a facility that needs significant refurbishment to meet the required hygiene criteria.

Although MPI has numerous documents to assist with this process, if you are new to RMP’s, finding guidance to all the parts required can be challenging – after all you don’t know what you don’t know.  Please get in touch if you would like some help.

For any new RMP – even if you are using a template, the best place to start is:  MPI Guidance Document: Risk Management Programme Manual. (RMP Manual)

For most businesses there are 3 or 4 key aspects of the RMP:

1. Information about the Operator and Scope of the Operation

2. Supporting Programmes (also known as Prerequisite programmes and Good Operating Practice)

3. HACCP

4. Validation

The RMP Manual provides a lot of detail about numbers 1 & 4 above, but less about Supporting Programmes and HACCP.  However I would suggest additional resources are utilised to assist with all aspects of establishing a new RMP.

RMP Templates:

Several Industry sectors have RMP Templates that have been developed by MPI in conjunction with industry bodies to assist the membership meet the regulatory requirements primarily drawn from the following:

• Animal Products Act 1999

• Animal Products Regulations 2021

• Animal Products Notice: Production Supply and Processing

By their nature the templates must be somewhat generic, so tend to cover simpler operations,  such as transport and industry sectors generally comprising small operations where there is limited capacity for dedicated Food Safety / Compliance resources.

RMP Templates that have been recently revised to align with current regulatory instruments include:

• Bee Products

• Storage and Transport Operators

• Farm Dairies and Dairy Products

• Dual Operator Butchers & Micro Abattoirs

• Poultry (meat, eggs & breeding)

These Templates cover most of the RMP requirements for specified activities.  However it should be noted that businesses using templates will need to:

• complete details throughout the template

• develop records to meet the monitoring and operator verification requirements

• create procedures to detail how specific tasks are done (eg cleaning, inventory control and lot identification procedures)

• document any activities not included in the RMP template and have these evaluated

• carry out validation for processes that require it

Each supporting programme in the templates states the types of records that need to be kept, and any associated procedures that should be written by the operator.

Templates, (along with other useful resources) can be found on the following Web Page under RMP Templates and Models:

Custom RMP’s:

If there is no suitable RMP template for your business a custom RMP will need to be created.  Custom RMP’s must be evaluated prior to registration.  This evaluation process is necessary to ensure that it meets the legislative requirements.  MPI Recognised evaluators must be engaged for this work. 

The following Web Page references RMP templates and Industry Operational Codes which are a good source of information.

RMP Supporting Programmes:

Supporting programmes must cover your business activities from reception materials to dispatch of product, meet the regulatory requirements so that the products processed are fit for their intended purpose. Section 4.11.1 of the RMP Manual provides a list of the types of items that should be covered by supporting systems.  Templates from similar industries may be useful starting point for developing your own supporting programmes.

Hazard Analysis and Critical Control Point (HACCP):

If a template is unavailable, you will need to carry out the Hazard Analysis and Critical Control Point.  This is a system to systematically identify significant Food Safety Hazards and implement procedures to manage them. 

Evaluation of all inputs, and process steps is required to determine the significant hazards and identify control measures for them.  Hazards include:

• Biological:  Pathogens such as bacteria, and protozoa.  The specific pathogen must be identified in relation to the specific process step, or input.  Eg Giardia in water supplies, Campylobacter in chicken, and the control required will be specific to the species of concern

• Chemical:  Includes biotoxins (eg in shellfish), allergens, heavy metals and other environmental toxins, drug residues, spray residues, and food additives

• Physical:  Objects that may be harmful including fish bones that might become a choking hazard, or glass fragments that may cause physical damage

HACCP relies upon Good Operating Practice (GOP), typically in the form of documented supporting programmes, and monitoring systems.  Any Food Safety Risks that cannot be suitably managed by these supporting programmes, are deemed Critical Control Points (CCP’s).  Not all businesses require CCP’s.

Resources for developing HACCP plans include

• MPI Standardisation of Hazard Analysis and Critical Control Point

• Codex HACCP (FAO and WHO. 2023. General Principles of Food Hygiene (CXC 1-1969))

RMP Validation:

Certain processing activities require validation – to ensure that certain of your process will result in the required outcome each time.  This applies to those using RMP Templates, and those creating a Custom RMP.  

To find out whether any of your processes require validation, check: RMP Manual, Appendix D: Procedures and processes requiring validation.

The following typically require validation:

• Operator supplied water

• Pasteurisation / heat treatment to achieve food safety outcomes (eg hot smoking etc)

• Fermentation

• Acidification

• Drying / concentration

Exporting Animal Products:

Whether or not you utilise a template, or develop a custom RMP, if you are also exporting you may also need to:

• Understand the requirements of the countries to which you wish to Export your products (OMARS) – which may influence the content of the RMP

• Seek listing to supply certain products to some countries

• Register with MPI to use the Certification tool (eg Ecert)

• Receive and dispatch all animal products for which official assurances may be required using the certification system *

• Register as an Exporter

• Develop a documented programme describing how you are going to meet the “Official Assurances requirements”

* MPI is currently reviewing the Animal Products Official Assurances Requirements and changes will be rolled out over 2024 and 2025

Call or email me if you require any assistance with you RMP requirements.

SALMONELLA - THE COMMON LINK BETWEEN CHOCOLATE, PEANUT BUTTER AND TAHINI

Chocolate, peanut butter and tahini have been recalled due to the presence of Salmonella in New Zealand and globally in recent times.  Many of the affected products have resulted in widespread hospitalisation of consumers, predominantly in children who are generally more susceptible to salmonella infection.

Salmonella Risk in High Lipid, Low Water Activity Foods

These three products share characteristics including high fat and very low moisture content / water activity: a­w.  Although Salmonella is unable to grow in these conditions, some strains appear to be protected, allowing them to survive for long periods of storage.  Most significantly these high fat low moisture products provide conditions for salmonella to survive in routine cooking conditions which effectively kills salmonella in other types of food:

• Typically salmonella is killed instantaneously by cooking at 70°C

• In high fat, low aw foods: chocolate, tahini and peanut butter; temperatures of 80°C for 220 minutes and 90°C for 50 minutes are not wholly effective at eliminating salmonella

Raw materials for these foods generally includes a roasting step which should eliminate salmonella.

However, finished products infected by salmonella are generally contaminated after the roasting process.  No typical heat treatment thereafter will disinfect such products.  These products are also often ready to eat, so no treatments are provided prior to consumption.

Controls to Manage Salmonella in Chocolate, Peanut Butter and Tahini

To manage salmonella risk, very good hygienic practices are required to prevent contamination of these foods after the roasting step.  Managing salmonella in these products requires:

• Validated heat treatment to prevent survival of salmonella in the roasting step

• Good hygiene management after heat treatment until the product is packed.  This includes:

  • Hygienic design & maintenance of the facilities and equipment

  • Controls on the movement and hygienic practices of staff moving into the high hygiene zone

  • Controls and disinfection procedures for the movement of materials and equipment into the high hygiene zone (including machinery & packaging)

  • Robust sanitation procedures for processing equipment and facilities

  • Cleaning verification activities, including monitoring the product and environment for salmonella

Where such products are sold as ingredients to other food processors, all products made using contaminated materials are also likely to be implicated in food recalls.

For businesses using tahini, chocolate or peanut butter products as ingredients, development of robust procurement procedures and relationships with your suppliers is recommended.  Requesting Certificates of Analysis for each batch that include relevant parameters such as Salmonella may be appropriate.

The attached report Salmonella in High Lipid Foods produced by ESR for NZ Food Safety in 2010 provides more detail on this subject.

The MPI website details controls for “Imported Foods that Require Food Safety Clearance”.  However of the three product types discussed here, only Crushed Sesame / Tahini has an import control for Salmonella. 

The attached Food Notice: Requirements for Registered Food Importers and Imported Food for Sale specifies the controls for different food types in the Schedules.

NEW RMP TEMPLATES TO MANAGE SE IN COMMERCIAL CHICKEN FLOCKS

Salmonella Enteritidis:

The detection of Salmonella Enteritidis (SE) in New Zealand chicken flocks has resulted in changes to the industry.  These have been managed under temporary measures, but now the legal and regulatory changes have been put in place the risks associated with SE in chickens are managed under Risk Management Programmes (RMP’s).

Risk Management Programme Templates:

MPI has just issued two RMP templates to assist the industry to meet the new requirements:

1. An updated template for Egg Production and Rearing of Layer Chickens

2. A new template for Production of Broiler and Layer Chickens, Day-old Chicks and Broiler Chicken Production

The key features are that all commercial producers of chickens (with more than 100 birds) must operate under an RMP that meets the current legislative requirements by 1 November 2023.

Both templates have been published with a detailed guidance section (at the start) that does not form part of the template.

Egg Production:

Previously only egg producers & processors (including other poultry species) required to operate under an RMP.   The previous Template which came into effect on 3 February 2020, covered only Harvesting, Candling and Packing Eggs.  It has now been updated to comply with the changes resulting from the regulatory re-design that have been rolled out over the last ~two years.  It also addresses the SE management requirements including:

• SE management (previously a SE Management Clip On to the RMP)

• layer rearing (previously required to be documented as an SE plan for rearing for operations where this was undertaken).

To accommodate the wider scope of the new template modules may be selected based on the activities of the operator to include:

• Rearing of Layer chickens

• Harvesting, candling and packing of eggs

• Transport

Secondary processing (eg pulping) remains outside the scope of the revised template.

For those egg producers & processors who have a custom RMP / or custom sections, the relevant changes will need to be incorporated into their RMP by 1 November 2023.  So long as the scope of operations does not change, the RMP amendments are minor and MPI does not need to be notified.

Chicken Production:

Producers of broiler chickens, layer chickens and day old chicks must operate under a RMP which must be registered by 1 November 2023.

For operators who do not currently have an RMP, there are numerous steps required to become registered:

1.       Complete the RMP template (or write your own to meet the requirements).  If you write your own or include activities outside the scope of the template, you will need to have these aspects evaluated prior to registration

2.       Select a verifier (auditor) and have a letter from the nominated verification agency

3.       Complete the application forms (AP4, AP49)

4.       Apply for registration

These steps can take some time, so commencement as soon as possible is suggested to ensure it’s completed by 1 November 2023.

Where the template does not cover the scope of operations, or you chose to write your own RMP, these deviations must be evaluated prior to registration further extending the timeframe for completion.

FOOD CONTROL PLAN TEMPLATE UPDATES

MPI has updated the Food Control Plan template Simply Safe & Suitable S39-00004 to ensure that changes to legislative requirements are met by food and beverage businesses.  The template is now also easier to use and more technically correct.

Why has the Food Control Template changed?

There have been changes to regulatory requirements that means the templates needed to be revised to:

• reflect FSANZ Food Labelling Changes (allergens and pregnancy warnings for alcoholic beverages)

• meet the new recall requirements, including the requirement for simulated recalls

• maintain consistency with the Water Services Act 2021

• update formatting (page numbering, colours of cards, links between cards, provide more detail, make corrections)

When do the changes take effect?

New Zealand food and beverage businesses using Food Control Plan templates are required to update their food control plans.  The whole plan must be updated to the current version of S39-00004 by 20 February 2024.

Additionally there sections that must be updated by 30 June 2023 which is the date that Food Notice: Food Service and Food Retail Business Food Control Plan templates issued under section 39, takes effect.

The sections in all Template Food Control Plans required to be updated by 30 June 2023 are:

• Recalling your food – updated to include the new simulated recall requirements

• Separating food – to meet the new allergen identification requirements

• Knowing what’s in your food – to meet the allergen requirements

• Packaging and labelling – To meet the new labelling requirements

If your business uses the following cards, then these also need to be updated by 30 June 2023:

• Making sushi – changes to the pH requirements for acidifying white rice

• Hot smoking to control bugs – cooking time & temperature requirements have been added for seafood

• Managing self-supply water – to meet the requirements of the Water Services Act 2021

• Using acid to control bugs – Scope of acidification broadened, and pH limits revised

• Using water activity to control bugs – separated out from the other cards. (To replace this aspect of the current section “Using water activity, acid or hot-smoking to control bugs” print pages 73 – 76 of the Simply Safe & Suitable S39-00004 template.)

For businesses operating Custom Food Control Plans that utilise template sections, the individual sections must be updated as per the dates referenced above.

How can the changes be made?

Updates to the food control plan may be carried out by:

• Printing the new Simply Safe & Suitable S39-00004 template (or relevant cards), completing the plan and replacing the previous cards.

• Purchasing the new cards (links not active at the time of writing)

• Going to the website page “MPI Food Safety Rules” and using the tool to customise the food control plan for your business.  This can be printed and completed.  (Note that at the time of writing, the MPI tool does not have the latest Simply Safe & Suitable template)

MPI has instructions for:

updating specific cards (by 30 June 2023)

updating your full template FCP (due by 20 February 2024)

FOOD AND BEVERAGE LABELLING CHANGES

There are several changes affecting the labelling of Foods and Beverages in New Zealand.

Pregnancy Warning Labels on Alcoholic Beverages

What are the New Pregnancy Warning Label Requirements?

There are two parts:

1. In 2020 the Food Standards code was updated to mandate pregnancy warning labels on alcoholic beverages for retail sale.

2. Earlier in May further requirements for warning labels on outer corrugated cardboard outer packaging were introduced.

Both these requirements exclude beverages:

• containing no more than 1.15% alcohol

• packed or poured in the presence of the purchaser

When are the Pregnancy Warning Labels Required?

• Outer corrugated cardboard containers must comply with the new pregnancy warning requirements from 2 February 2024

• Individual alcoholic beverage containers and other packaging must comply with the requirements from 1 August 2023

What are the Requirements of the Pregnancy Warning Labels?

The form of the pregnancy warning label is prescribed. The FSANZ website provides downloadable files, along with details of required colours, sizes, fonts and clear space around the images.

FSANZ has guidance in the form of FAQs on Code requirements for pregnancy warning labels.

MPI has updated their Pre-Packaged Alcoholic Drink Labelling Guide to include these requirements. On page 4 of the guide MPI has included a link to the downloadable pregnancy warning labels.

Plain English Allergen Labelling

Food Safety Australia New Zealand (FSANZ) have revised the allergen labelling requirements to make it easier for consumers to find and identify the allergens present in foods and beverages they purchase.

When do the Allergen Labelling Changes take effect?

The FSANZ rules for labelling allergens changed in 2021 and business have until 25 February 2024 to comply with these rules. (Any food packaged and labelled prior to this date may be sold for up to 2 years from this date: eg. up to 25 February 2026)

What are the new Allergen Labelling Requirements?

The key changes include the terms that must be used for identifying allergens, and the format for declaring them:

• specific names of tree nuts must be stated (rather than using generic term “tree nuts”

• molluscs must be identified separately

• individual cereals that contain gluten must be listed

• allergenic ingredients must be identified in bold in the ingredients list

• a separate allergen summary statement in bold font must be immediately above or below the ingredients list and in the same field of view, prefixed with “Contains” followed by the list of allergens

For products with labelling exemptions, there remain requirements to provide suitable allergen information.

MPI has provided a Plain English Allergen Labelling Guide that details the new requirements providing multiple examples of each of the new requirements.

BEE PRODUCTS RMP TEMPLATE

RMP Templates

MPI have issued several Templates for Risk Management Programmes (RMP’s). These are particularly useful in industries where there is a predominance of small operations (eg farms and family businesses) that cannot justify dedicated staff specialising in RMP compliance.

MPI has provided RMP templates for several industry sectors (Eg micro abattoirs, farm dairies and egg producers). However the first RMP templates issued since the recent changes to the animal products regulations and notices are for bee products operators and honey storage.

• Bee Products RMP template

• Honey Storage RMP template

The new Bee Products RMP template has also expanded on the previous version which was issued in 2005.

Whereas the Initial template provided no supporting systems and covered only honey, beeswax and pollen, the new template:

• includes a section for all supporting systems

• has a series of modules that now also includes: propolis, royal jelly and bee venom

These modules allow the operator to identify the relevant products and identify the processing steps they utilise, and these link to the Hazard Analysis in a streamlined way.

New Bee Products RMP’s

With the revised template, creating a new RMP for export eligible bee products is a significantly easier process compared to the previous system.

However any products & processes outside the scope of the new template (eg honey blended with other ingredients), need to be written by the operator and such documents evaluated prior to registration as a significant amendment.

Alternatively operators may create a custom RMP, noting that these will need to be evaluated prior to registration.

Existing Bee Products Template RMP’s

For Bee Products RMP operators who have been using the 2005 template, there is no compulsion to transfer to the new template. However there is a requirement to update to the new features from the regulatory re-design. These amendments must be completed by 1 November 2023. Such changes are a minor and do not need to be advised to MPI approvals.

The new features relate to the new regulatory tools:

• Animal Products Regulations 2021

• Animal Products Notice: Production, Supply and Processing

Operators now also have a mandatory requirement to undertake a simulated (or actual) recall within every 12 month period. The simulated recall requirements are more comprehensive that previous “mock recalls”. MPI have provided excellent guidance on simulated recalls.

If operators wish to add new products that are included in the new template to their RMP, then use of the relevant modules will streamline the process as evaluation will not be required for these significant amendments.

Should operators using the 2005 template wish to transition to the new template this is also a minor amendment that does not require notification to MPI approvals.

Use of the new Bee Products RMP template

It should also be noted that the supporting systems are generic, so there are several sections that require further supporting procedures that define how the operator will manage specific activities. Sections likely to need supporting documents include:

F – Design, Construction and Maintenance of Buildings, Facilities and Equipment

• Procedures for monitoring conditions of buildings & facilities, the actions taken when undertaking maintenance to prevent product contamination

H – Cleaning and Sanitation

• A detailed cleaning programme or schedule for cleaning and sanitizing all areas of the operation

J – Traceability, Inventory and Labelling

• A traceability and identification system that allows the tracing of all animal products back one step to the supplier and forward one step to the receiver

• Labelling procedures to ensure that labels meet the regulatory requirements (retail & transportation units), and accurately reflect the product contained

L – Calibration

• Procedures that identify measuring equipment used to provide critical measurements, the frequency of calibration and by whom

M – Chemical Control

• An up-to-date register of all chemical held on the premises

Depending on the operation there may be other areas where additional procedures should be documented.

Methods of record keeping must also be determined by the operator and suitable systems devised to ensure that records for all required monitoring activities are undertaken and kept securely for 4 years. The template identifies the record keeping requirements for each supporting programme. The MPI RMP Operator Resource Toolkit provides record examples that may be used or adapted to meet the operators needs for records.

NATURAL DISASTERS & EMERGENCIES

Recent extreme weather events in the top of the south – Buller, Tasman, Nelson & Marlborough, have had a major impact on peoples’ lives.

Damage to housing, businesses, roads and infrastructure because of flooding and high winds has been significant.

The regional authorities affected by these events have all posted details on their websites to inform the public and business owners/managers.

It is notable that many regional authorities are now utilising a mobile app – Antenno - to push notices to subscribers using the free app based on “addresses” of interest.   The user does not need to actively monitor anything – they will be notified of anything relevant to their places of interest.

Individuals download the app and list addresses of interest.  These may be their homes or those of family members’, places of work, schools etc.  Any notices relevant to the specific locations raised by the relevant Authority are pushed to the Antenno app users. 

Antenno also allows users to advise their council of problems or provide suggestions.  These reports allow the authorities to respond directly to the person keeping them informed about what’s happening.

Marlborough District Council, Nelson City Council and the Tasman District Council all utilise the Antenno app.

I’d recommend individuals in these areas download the Antenno app.  Similarly managers and owners of food businesses may benefit from being provided with these notifications.

In this recent weather event water supplies have been affected necessitating boil water notices for several potable water schemes.  This affects not only domestic users but also the food businesses.  One would hope that individuals and businesses in the areas affected by boil water notices were notified by the Antenno App.  If you subscribe to Antenno and have an address in one of the areas affected by the boil water notices, it would be interesting to confirm that you received such a notification.

For food businesses affected by flooding, the consequences may also include sewage contaminating buildings, facilities and water supplies. The MPI website has guidance for food businesses under the title Food safety in natural disasters and emergencies. Preparing for such events and having an Emergency Response Plan may allow you to get your business up and running again quickly.

FOOD PACKAGING

When I was a small boy the food was quite different from what we have today: -

• milk came in glass bottles with a foil cap

• bread either had no packaging, or was wrapped in waxed paper

• ice cream came in cardboard cartons

• fruit and vegetables were loose and could be packed in paper bags

• fresh meat (and our fish & chips!) was put in grease proof paper and wrapped in newsprint

• paper sacks or cardboard boxes were used for groceries

There was hardly any plastic to be found.  Three types of packaging material predominated:  natural fibre (paper & cardboard / hessian), glass & metal.

Roll on more than 40 years and most foods come wrapped in plastics.

During the last decade, the packaging used for some products has been criticised for excessive and unnecessary use of packaging materials.  More recently the use of plastics for packaging foods has been under scrutiny for their environmental impacts: -

1.     Greenhouse gas emissions where petrochemicals are used as raw

materials for making plastics

The life cycle emissions should be used for comparison of packaging materials rather than limiting it to the carbon dioxide equivalents of just the source material.  In many cases the emissions from manufacturing far outweigh the “carbon footprint” of the packaging item itself.

For example work has been done that demonstrates the comparative impacts on global warming from different types of shopping bags:  A paper bag would need to be used 3 or 4 times before its emissions fell below that of a lightweight single use plastic shopping bag; a cotton bag would need to be utilised about 150 times to achieve the same.

2.     Environmental contamination from used plastic packaging

Plastics have been formulated to be resilient and impervious and it’s these properties that enhance food quality, safety, and shelf life.   These characteristics of plastics also make them persistent in the environment:  Plastic particles and microplastics pollute soil & water and are increasingly being found within living organisms.

There are several alternatives to petroleum sourced plastics including bioplastics (made from biological sources rather than petroleum) and biodegradable / compostable materials.  However, the key with all of these is the ability for the waste packaging to be managed effectively:  by way of re-using, recycling, and composting.   In New Zealand because of our small population and remote location the infrastructure to deal with plastic packaging waste is poor to non-existent.

When selecting food packaging it’s important to ensure that the food safety / quality needs are satisfied, and then to choose a system that minimises the environmental costs (including the ability to re-use, recycle and dispose of the packaging).  If there are non-plastic options what are the impacts of these materials by way of greenhouse gas emissions?  Are there practical options to re-use / recycle?

FUTURE (OF) FOOD

What foods will we be producing and consuming in 5 – 10 – 20 years?

The food industry is experiencing huge pressure for change:

• Climate change is affecting primary production (where things will grow, new diseases etc.)

• The impacts of fertilisers and wastes on waterways are leading to restrictions on land use

• Animal welfare considerations are fundamentally altering permissible farming techniques

• The carbon footprint of food products from farm to fork is being scrutinised

• Access to water to undertake production is limited via climate change and resource allocation

• Loss of plastics into the environment is changing acceptability of plastic packaging

• An increasingly multicultural society is leading to new types foods being available

• Food technology is being used to develop novel foods (eg meat analogues)

Some of these things are forcing changes on the food industry, and others are the food industry providing new options.  The pressures for change are taking place both in New Zealand and overseas.

These changes will affect all food producers to a greater or lesser degree.  Have you considered how to ensure your business remains sustainable in the future: environmental impacts via emissions, water use and plastics use; maintaining a social licence to operate; and ensuring that your business remains financially viable?

Further to this, these changes will also put pressure on the regulatory systems used to manage food safety and ensure food suitability.

MPI’s New Zealand Food Safety business unit is currently consulting on their draft strategy.  This strategy is aimed at ensuring that the food safety systems can keep up with changes in demographics, novel foods and processing methods.  Their responsibility to influence and lead internationally, to facilitate trade is also critical.

Take the opportunity to consider this and have your say.  Search on A strategy for New Zealand Food Safety

FOOD RECALLS

Many businesses have found themselves in a situation that nobody desires – needing to recall foods that expose consumers to food safety risk.  Since the start of 2018 there have been well over 100 food recalls in New Zealand.

A food recall can have serious repercussions on the financial health of food and beverage businesses.  It’s important for everybody involved to actively connect to the fact that what they do has a bearing on the health of their customers.

It’s sobering to note that even with the best systems in place, business owners can find themselves involved in recalling their food products.  Many of the businesses & brands involved in food recalls did so, not because of failures in their own processes, but because of the inputs that they purchased.

If you are a food & beverage business owner, I’d strongly recommend that you subscribe to the MPI food recall updates.  (Search on Subscribe to MPI).  It’s a good way to learn from others’ mistakes!  Ask yourself could something like this happen in our business?  If the answer is “Yes” then you can make changes to reduce food safety risks.

More than 80% of food recalls related to 3 areas:  undeclared food allergens, foreign matter and pathogens detected in the food.  Below is a short summary of each.

Food Allergens

Almost half of all food recalls were associated with the presence of undeclared allergens.  It’s also fair to note that almost half of these recalls appear to be associated with one ingredient used by many businesses containing an allergen that was not declared in the finished product.

Understanding what’s in the foods you produce is important.  Take the time to obtain and check the specifications and labels of ingredients that you purchase. 

If you make claims about your foods in relation to the absence of certain allergens, the duty of care goes further.  You are responsible for having systems in place that demonstrate that the claims you make are true.

Ensuring robust control of pre-printed packaging/labels is something that can prevent mis-labelling.  You want to ensure your operation cannot use the wrong label or package.

Foreign Matter

About a quarter of all food recalls were associated with the presence of foreign matter.  Minced meat was the biggest culprit.  Any size reduction activity can take a contaminant, make it smaller, and spread it widely though the product / batch.  What can you do to minimise the risks?  Prevention is better than cure.  Introduce best practice – preventive maintenance and work procedures.  If the risks are still high look at equipment for defect detection & removal.

Microbiological

Raw milk products dominated the products recalled for the presence of pathogens. Businesses producing high risk ready to eat foods need to focus on good hygienic practices and ensure that all personnel – including contractors are aware of what they need to do to keep food safe.

MPI LAUNCHES NEW FOOD SAFETY TOOLS

New Zealand Food Safety has been working with industry to make it easier for food businesses to comply with their food safety obligations.

These new tools were publicly launched in Nelson at NIMIT on Friday 19 June 2019 by the Hon Damien O'Connor, Minister for Food Safety and Bryan Wilson, Deputy Director General for Food Safety.

It was noted by both the Minister and Deputy Director General, that the cost of compliance can be very high for small businesses.  Although the food safety standards themselves cannot be reduced, the compliance costs to businesses can be reduced by improving processes.

Remote Verification

The Hon Damien O'Connor set the challenge for remote verification.  Many food businesses in his constituency are remote.  This makes the verification processes more expensive compared to food businesses operating in larger centres where verifiers are close at hand.

New Zealand Food Safety is a global leader, introducing remote verification for food safety.  Very few if any food regulators offer this option.  Remote Verification allows audits to be conducted using skype and smart phones over a good broadband connection.  Most people and businesses have access to these tools.

Remote verification is currently only available to lower risk food businesses operating under National Programmes.  Physical on-site audits will still be required but less frequently.  Although the audits may take a little longer – there can be significant overall savings by reducing the costs of travel and accommodation associated with getting the auditor to and from the food business.

Remote verification will take additional auditing skills, as senses such as touch & smell are not available to them.  Verifiers will need to specifically register as remote verifiers.

My Food Rules

A couple of weeks ago, I discovered “my food rules” which is a tool that has superseded “where do I fit”.  At the time I realised what a big improvement this was.  It is quite broad and includes businesses that may not operate under the Food Act 2014 including those needing to operate under the Animal Products Act and the Wine Act.  Where appropriate, it produces a template programme, and relevant guidance.  For example, if it determines that you need a custom food control plan, the generic pre-evaluated programme elements will be provided, and it will advise sections that need to be developed that are specific to your business.  Existing templates have been incorporated into this updated tool.

New Zealand Food Safety will continue to develop this tool, as new pre-evaluated templates are developed, to cater for more businesses.

If you want more detail on either of these tools, there is good detail in the MPI website. Search using the following terms:

MPI My Food Rules

MPI Remote Verification

Mark