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Clarification for Ingredient Exports

Food Standards Code (FSC) compliance

October 2008

This document is intended to provide guidance to exporters of dairy products which may contain levels of permitted additives above the levels stated in the Food Standards Code.

FSC 1.3.1, Clause 8 Food for use in preparation of another food

“Any Food additive permitted in a food may be added to an ingredient intended for use in the preparation of that food provided that the level in the final food when prepared complies with the maximum permitted level in this standard.”

Classifications of dairy products

Ingredients – products which are:

• Intended as an ingredient for further processing, including repackaging into consumer packs; and

• Not consumed or normally consumed in their present form; and

• In a bulk package; and

• Not labelled with any directions for consumer use (including reconstitution rates) on the package; or

• Nutritional products with all four above attributes, and where the customer undertakes further processing by addition of ingredients, blending, and repacking

Note: It is the importer’s responsibility to ensure that the imported ingredient (as sold to the consumer) meets all requirements of the country in which it is being sold.

Foods – products which are:

• In a consumer package; or

• In a food service or catering package; or

• Labelled with directions for consumer use; or

• Bulk products which are consumed without changing their form, notwithstanding repackaging into smaller consumer packs.

Nutritional – products which are:

• Specifically intended for consumption by ‘at risk’ consumers, in any packaging size or format.

Certification of Ingredients

NZFSA requires confirmation from the exporter, for products being sold as ingredients (which do not meet the FSC requirements for permitted ingredients) that the product being exported meets the above definition of an ingredient.

This confirmation can be either via a statement by the exporter or included within the specification information (where the specification is only sold as an ingredient).

For products that are within the Foods and Nutritional product groups the normal exemption process will apply if the level of permitted ingredients is outside the FSC requirements.