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Proposed framework for the manufacture, importation and sale of raw milk products

7 Conclusion

NZFSA’s preferred option is to enable the manufacture and sale (both within New Zealand and for export) of some raw milk products, and allow for the importation and sale of a similar range of raw milk products, while maintaining an acceptable level of consumer protection.

NZFSA is proposing to introduce a framework that would allow for the assessment and identification of those raw milk products that could be safely produced, imported and sold in New Zealand, and any specific requirements that would need to apply to these products. While the framework would cover all raw milk products for human consumption, only those that could be produced safely (that is, present a low food safety risk to the general population) would be able to be legally produced and imported. If the proposed framework was to be progressed, regulations and associated guidance information would then be introduced to enable its implementation. The framework would include provision for consumer education and informative labelling of raw milk products.

The proposed framework is based on a ‘category approach’ with raw milk products being placed in one of three categories according to their food safety risk. The category approach has been developed after consideration of the FSANZ and NZFSA risk assessments of raw milk cheeses currently able to be sold in New Zealand and Australia, and EU assessments for other European-style raw milk cheeses. It has also been informed by other NZFSA risk assessment work on the public health risks associated with the consumption of raw milk and raw milk products. The category approach would assist NZFSA to develop risk management options for each of the categories, removing the need for case-by-case assessments of some individual processes and products. It is likely that technical criteria would not be initially developed for all raw milk products categories, with priority instead being given to raw milk cheeses.

If, following the consultation initiated by this discussion document, a decision is taken to advance the proposed framework for raw milk products, a second round of public consultation would be initiated on the draft technical and legal requirements necessary to implement the framework outlined in this document. The proposed regulatory framework would apply to products that fall under the Animal Products Act 1999, the Food Act 1981 and the proposed new Food Bill. Associated implementation matters including the interface with the Imported Food Review, MAF Biosecurity Import Health Standards, and any monitoring programmes needed, along with a regulatory impact assessment on any proposed regulations, would also be considered in the preparation for any further public consultation.