Food Labelling in New Zealand - The Basics Explained

Here in New Zealand we have some of the strictest food labelling laws in the world. Any consumer would agree that strong food labels are great as they help them make informed choices about what they are consuming.

They are an integral part of our country’s high food safety standards. 

However, food labelling can be problematic. It is up to the food business to ensure their labels are absolutely correct and in-line with legislation, even when their suppliers are off-shore where different rules apply. These rules are strictly monitored and come with a high cost when mistakes are found. Businesses who get it wrong can find themselves on the receiving end of hefty fines as well as having to deal with the expensive drama of conducting a product recall.

Anyone caught up in the recent mass recall of chocolate products will understand this first hand. In this case the raw cacao supplier did not disclose the presence of milk, a notifiable allergen in New Zealand. Any Company (and at last count there were 19) who used the ingredient without milk being listed as an allergen were forced to recall their products and review their labels. A costly process for any business.

Of course, if your food business is required to label your products then getting it wrong is just not an option. However, it is also important to not lose sight of what their purpose is. Here are the answers to the five key questions I am asked regularly to help get you started.

If you manufacture or process and package food for sale you will need to label your products.

However, as with all rules there are exceptions. Foods that do not require any food labels are as follows;

• Unpackaged food.
• Food that is packaged where it is sold or it is packaged in front of the customer. For example; loaves of bread sold at the bakery.
• Ready to eat food made and delivered to order. For example; pizza.
• Fresh fruit and vegetables (including cut) that is in transparent packaging.
• Food sold at a fundraising event.

There are also some foods that, although need labels, have less requirements for what must be included. These are;

• Really small packets such as chewing gum.
• Foods for catering.
• Alcoholic drinks.

This is where it can get a little tricky. I find this question is often closely followed with ‘can I just copy off [similar product name]’s label? The answer to the second question is no. Every detail of the label from the nutritional information to date mark and everything in between is quite unique to the product you are manufacturing.

It is important that your label covers everything and so I would generally advise to get some professional advice, you can even outsource the production of your labels if you really want. However, to help you double check those labels are correct, or get you started on your project, here is a simple checklist for you to use.

It is important to remember you will need to be able to validate anything you claim on your label. Any health claims must be provable and certain foods may need their use by dates validated using laboratory tests. Food labels will be checked thoroughly by your verifier at audit time.

Packaged food that has a shelf life of up to 2 years needs to have a date mark on it. There are three types of date marks accepted in New Zealand with each one serving a different purpose.

1. Use By: If the food needs to be consumed by a certain date for health and safety reasons then a use by is the right one. Foods that would have a used by include; fresh meat products, fresh dairy products and prepared and packaged salads. It is illegal to sell food that is past its use by date.
2. Best Before: If the food remains safe to eat but the quality may deteriorate then a best before date is used. Foods that would use a best before include; frozen meat or vegetable products, shelf stable baked products and cereals. Food past its best before is still allowed to be sold as long as the customer is informed.
3. Baked on: This type of date mark is only used for bread and some other basic bread products.

You may have products that need two different date marks. For example, some frozen raw meat products. While frozen the best before date may be some time off but once the product is thawed it will need to be consumed within a few days.

4. I am supplying bulk for others to use and sell, do I need a label?

Selling wholesale product to another business, for example; crumbed chicken pieces that are sold to restaurants to cook and serve, may require different labels.

You will still need to label each bulk pack being sold but you may not need to include quite as much detail. The higher the risk the product is, the more information you are required to have on the label. Here is a checklist to help get you started.

5. How do I know what is being recalled?

Recalls happen. And they happen for more reasons than just a mistake on the label. If you use suppliers of food products it is important to know what is being recalled and why.

Every food product that is recalled in New Zealand is registered with MPI. MPI store this information on a database. In order to be informed of a recall when it happens simply sign up to the notifications through MPI. Click here and it will take you directly there.

If you would like to discuss anything raised in this article I would be happy to discuss it! Flick me an email on anna@foodcontrolplans.co.nz or click below to book a 15 minute chat.