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Food Importer Standards Guidance

Requirements for sourcing imported food

What does the Standard require?

All importers of food for sale must take all reasonable steps to ensure that the food imported complies with all applicable legislation.

The importer must document the following:

• how the food product has been produced and managed in a manner that enables the food to be safe for human consumption; and

• a description of the product’s passage including the product flow (ie, port of entry, the carrier, and if applicable the import broker); and

• a supplier list and relevant supplier information.

Importers must keep purchase records (the quantity, the product code, the date and the buyer) for all products.

Why is this required?

Importers need to be confident that their products are safe and comply with all applicable New Zealand legislation. This relies on production and processing procedures and controls in place at the point of production and/or manufacture as well as during any further production, manufacture, transport and storage before it arrives in New Zealand. Traceability records for each consignment are important as in the event of a recall they allow importers to track the product to the next person in the food chain and back to their immediate supplier.

How can this requirement be met?

Importers must be able to provide evidence that their products comply with all applicable New Zealand legislation including the Food Act 1981, the Wine Act 2003, and the Animal Products Act 1999. Importers must be able to provide evidence from their supplier that food has been produced and managed in a way that ensures it is safe and suitable. The type and amount of evidence that importers request from their suppliers should be appropriate for the level of risk posed by the particular food.

NZFSA adopts a risk-based approach towards ensuring food safety. Food products identified as having a high potential health risk or a history of poor food safety are placed under strict import control (high regulatory interest). Specific evidence may be required to demonstrate that these products meet New Zealand standards.

Relevant product information

Importers must hold:

• Relevant product information such as product specifications and lists of ingredients.

• Traceability information including: product code, brand name, common name for product, container size, Lot ID, batch code and date marking eg, Best Before or Use by Date or other shelf life information.

Many of these may be recorded as part of purchase information and product specifications. All products should enter the country with identifying code marks or lot number on the label or container.

Other relevant product information may include:

• A certificate of conformance (CoC) stating that the product complies with the agreed specification.

• A certificate of analysis (CoA) detailing testing results of the specific batch of product. CoAs should only be accepted from laboratories accredited to ISO 17025, which is an international standard for testing laboratories.

• A completed Product Information Form (PIF) for each product eg, Product Information form issued by Australian Food and Grocery Council.

• Where specific international or relevant domestic codes exist in the country of origin, importers should obtain evidence the food is produced in accordance with these, eg, canned foods manufactured under the relevant Codex Alimentarius Commission code of practice.

The product’s passage to New Zealand

Key information about how the product got from point of purchase to New Zealand (including port of despatch, port of entry, carrier and import broker) should be readily available to assist with an investigation in the event of a recall.

Parts of this information may be recorded on the Bill of Lading and Biosecurity Authority/Clearance Certificate (BACC), eg, supplier – transport by truck – consolidator warehouse – transport by truck to port – port of despatch – transport by ship – port of entry into New Zealand.

Relevant supplier information

Importers must maintain a list of suppliers and their contact information, including but not limited to, each supplier’s company name, address, phone numbers, email address, contact person and products supplied.

Relevant information can be used by an importer to determine the appropriateness of a supplier:

• supply contract/or purchase agreement stipulating the agreed food safety measures.

• documented details of supplier’s procedures, quality assurance measures and food safety systems, eg. Supplier Questionnaire.

• documentation that the supplier has any relevant legal approval to operate in the country of production and certification that the products are made in premises verified by a competent authority as meeting hygiene standards, controlling hazards and following controlled procedures to ensure production of safe food.

• documented details of manufacturing processes and conditions that demonstrate that hazards have been identified and critical steps of the manufacturing process are adequately controlled to ensure safety and prevent misrepresentation and fraud.

• verification by a recognised third party that products are manufactured to internationally recognised standards, such as Codex Standards, Hazard Analysis Critical Control Point (HACCP), British Retail Consortium(BRC), Safe Quality Food (SQF) etc. Third party auditors should be accredited to internationally recognised standards and accredited certification bodies. Certification should be specific product or process and for a specific site.

• independent external audits of premises, processes and food safety systems. The evaluation may be carried out by a technically competent person working on behalf of the importer.

• a consistent and good history of sampling and testing or increased product controls such as sampling, laboratory testing, third party review etc.

• official assurances, eg, export certificates that contain statements made by a foreign government or agent of that government attesting that one or more things have occurred in relation to the food product.

Purchase records

Purchase records and invoices which provide proof of ownership and traceability information. Purchase records should include:

• The quantity of the food imported in each transaction / consignment

• The product code or other traceability information such as product name and batch code or date marking

• Date of purchase from the supplier, wholesaler or manufacturer

• Buyer information is important where the buyer is not necessarily the importer such as a wholesaler in an exporting country or where an importing company has more than one buyer.

Other useful information that may be recorded on the purchase records could include:

• Supplier information

• Date of despatch

• Date of receipt

• Country of origin

• Country of export

• Transport details.