Options for export exemptions from New Zealand composition and/or labelling requirements under the Food Act 2014
MPI is currently consulting on options for export exemptions from New Zealand composition and/or labelling requirements under the Food Act 2014.
MPI is proposing the below options, alongside the status quo, to better enable food exporters to comply with overseas composition and/or labelling requirements.
- Option 1: Maintain the status quo. This option uses section 347 of the Food Act 2014 to continue to provide exemptions on an individual application/case-by-case basis. This approach means each exemption is specific to a particular food exported to a particular market.
- Option 2: An exemption in regulations for all food exports from New Zealand standards relating to composition and labelling, with conditions.
- Option 3: An exemption in regulations for all food exports from New Zealand standards relating to labelling (no conditions to be met) and composition (with conditions to be met, potentially including where health claims are made or government assurances are required).
- Option 4: An exemption in regulations for all food exports, with a differentiated approach for different classes of product or market. For example, foods that are intended for consumption by a higher-risk population group may have some specific conditions that are different from another class of products.
All options, except the status quo, propose creating new regulations under the Food Act 2014. The details for each option are set out in the discussion document.
Discussion document
Proposed options for export exemptions from New Zealand composition and/or labelling requirements under the Food Act 2014 [PDF, 1.4 MB]
Have your say
Submissions close on the 26th July. NZFGC is preparing a submission, if you would like to include your feedback in this please email admin@fgc.org.nz.
SUBMISSION TEMPLATE QUESTIONS
Questions on problem definition
- What impacts, if any, does the current section 347 export exemption process have on your ability to export, including to compete and meet customer requests for new products?
- Are there any other problems/advantages of the current section 347 Food Act exemption? How significant are they?
- Can you provide evidence of the impacts on your business to further inform the analysis of the problem?
Questions on criteria for assessing options
- Do you agree with the proposed criteria? Why or why not?
- Would you propose any other criteria not covered?
Questions on the proposed options
- Which of the proposed options do you prefer and why?
- If you have an alternative option that has not been considered above, please describe this option, including the rationale and how it would perform relative to the five criteria.
- Are there any unintended consequences of the proposed options?
- Do you agree with the proposed conditions associated with Options 2, 3 and 4? Please explain your answer.
- What minimum protections, if any, should we have in place to ensure that all food products exported from NZ are safe and suitable and maintain our reputation as a trusted producer of high-quality food?
- Do you agree with the evaluation of options against criteria as presented in Table 7? If not, why not? Please provide details to support your answer.
Questions on Cross Border eCommerce
- What export statements do you consider may be needed to accompany exported foods that do not meet New Zealand requirements, but are produced to meet importing country requirements?
- Are there any further allowances or protections that could be considered for direct-to-consumer cross-border eCommerce? If so, please specify.
Submission template [DOCX, 57 KB]
