Dairy Traceability Working Group report

Traceability is important to rapidly identify the quantity and location of food in the supply chain and to facilitate effective recalls, and/or withdrawals of product, if they are potentially unsafe or not fit for purpose.

A Dairy Traceability Working Group was established in 2014 following the recommendations of the Government Inquiry into the Whey Protein Concentrate Contamination Incident, which were all accepted by the Government.

The working group was tasked with:

  • considering the most appropriate regulatory provisions for the traceability of dairy products; and
  • developing a code of practice or similar document to guide the dairy industry in implementing the requirements.

More detail about the purpose and the functions of the Dairy Traceability Working Group is set out in the Terms of Reference.

The Working Group has provided its reports to the Director-General of MPI. These reports are:

Proposed regulatory requirements of the Working Group

The Working Group’s recommendations are broadly consistent with those in key New Zealand export markets such as Australia, the European Union, and the United States.

The recommendations for regulatory changes are evolutionary improvements, rather than revolutionary. The main improvement on the existing requirements are to tighten how traceability information is provided to MPI. This will improve the accuracy and speed with which companies provide comprehensive traceability information to MPI. Full implementation of the proposals will help provide full supply chain traceability.

Given the importance of traceability in managing food safety, the recommendations of the working group will be considered for all food sectors not just dairy.

At a high level the working group’s proposed regulatory requirements are:

  • Continuing the existing ‘one up, one down’ record-keeping requirement, where companies must keep a record of the product they have sourced from suppliers, and sold to customers.
  • That traceability information must be provided:
    • electronically on demand to MPI, or an independent verifier;
    • as quickly as practicable, within 24 hours, or as specified by MPI or the verifier; and
    • in a standard data format that is directly accessible and intelligible.
  • Companies must hold independently verified practical tests of traceability processes, if a product recall has not taken place in the past 12 months.
  • Proposals should be reviewed three years after implementation, or earlier if a significant traceability event negatively affects “Brand New Zealand”.

Implementing the proposals

MPI is using the proposals as a basis for new traceability regulatory requirements. Minor changes to the primary legislation will be needed to implement the proposals. These will be made through the Food Safety Law Reform Bill to clarify and make traceability more explicit in primary legislation.

More extensive changes to the regulations and notices issued by MPI will be needed to implement the proposals. MPI will consult publicly on these proposed changes.

To minimise the impact of the new traceability requirements on businesses, MPI will consider whether a transitional period is required. MPI will also develop guidance material to assist the industry to comply with the new regulatory requirements.

The working group also made 13 other recommendations on issues that were outside of the group's scope. MPI is considering how far existing work can be expanded to cover these recommendations, or where additional activity should be undertaken.

Who to contact

If you have questions about MPI's plan to implement the proposals, email info@mpi.govt.nz.