Land-based seafood processing premises

If you are a primary or secondary processor, the food safety requirements you comply with depend on whether your products are intended for the NZ market or export.

Identify the kind of processing you undertake to find the requirements you need to meet.

What is primary seafood processing

Examples of primary seafood processing on land include, but are not limited to:

  • heading, gutting, and filleting of fish
  • tubing of squid
  • tailing of crustaceans
  • shucking, heat shocking, land-based wet storage and depuration of bivalve molluscan shellfish (BMS).

Animal Products (Definition of Primary Processor) Notice (external website)

What is secondary seafood processing

Secondary processing of seafood products includes processes at any stage beyond primary processing. Examples of secondary processing include, but are not limited to:

  • acidification, salting, brining, smoking, thermal processing, refrigeration and storage
  • extraction, drying, blending of powders from fish or shellfish
  • addition of non-animal product ingredients to seafood products such as breadcrumbs and sauces.

Operating under legislation

Land-based seafood processing premises, which carry out primary or secondary processing must operate under one of the following:

  • the Animal Products Act 1999, using a registered Risk Management Programme (RMP)
  • the Food Act 2014, using an audited Food Control Plan (FCP)
  • the Food Hygiene Regulations 1974.

Operating under the Food Act

Rules for food businesses are changing – we're moving from the Food Act 1981 to the Food Act 2014. From 1 March 2016, all new businesses must operate under the Food Act.

Existing businesses (registered under the Food Act 1981 or Food Hygiene Regulations 1974 before 29 February 2016) will shift to the new Act between 2016 and 2019. Check the timetable to find out when your type of business has to transition.

Processors operating under an RMP

Almost all land-based seafood processing premises that undertake primary or secondary processing, especially for export, need to have a registered Risk Management Programme (RMP).

Processors who need an RMP

You need to operate under an RMP if you are a:

  • primary processor, whose product is intended for export
  • primary processor selling by wholesale only on the New Zealand market
  • secondary processor preparing seafood for export to markets requiring official assurances (export certificates).

You can find further information about RMPs for seafood processors under Managing risk in the left-hand menu.

You can find further information in the General requirements section of the site about developing, registering and operating your RMP. It offers links to all the relevant documents including Standards & notices.

Code of Practice for seafood processors

The Processing of Seafood Products Code of Practice (COP) can help you to prepare a successful RMP and manage the incidence of foodborne illnesses such as Listeriosis.

You can find further information about this COP under Managing risk in the left-hand menu.

Processors operating under the Food Hygiene Regulations (FHR) or using a Food Control Plan (FCP)

Processors exempt from, or not operating under an RMP must, depending on circumstances:

  • operate under the Food Hygiene Regulations 1974, which are administered by your local council (Territorial Authority), or
  • use an FCP, audited by an external expert.

If you choose to operate under an audited FCP, you will be exempt from the requirements of the FHR.

You can find further information about FSPs and the FHR for the seafood industry under Managing risk in the left-hand menu. The page includes a table which helps you decide which plan or programme applies to you.

Primary processors who do not need an RMP

You do not need an RMP if you:

  • sell seafood - both retail and wholesale - only on the New Zealand market
  • sell seafood - for retail - only on the New Zealand market
  • process fish bait, fish berley, chum or ground bait.

You can find out more about the exemptions and requirements for primary processors in this document prepared by MPI.

Seafood: When is it primary processing or just a "fish shop"?

Secondary processors who do not need an RMP

An RMP is not required, if you are a secondary processor who either:

  • processes fish only for the New Zealand market
  • exports to countries where there is no requirement for official assurances (export certificates).