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Allergy Today: What’s Up with Food Recalls in New Zealand?

What’s Up with Food Recalls in New Zealand?

Allergy New Zealand volunteer, Delwyn Robinson, wrote to the Prime Minister in December 2019, expressing her concern as a mum of a child with multiple food allergies and anaphylaxis.
Keeping her child safe was hard enough, she said, but it was made even harder by the fact that ‘food is allowed in the country when it is not correctly labelled’.

She cited a report from an Australia study in 2019, which found nearly half of the 50 imported packaged foods purchased from six Asian grocery stores in Melbourne*, were found to contain an allergen that wasn't listed on the label. Even worse, 18 per cent of the products contained multiple unlisted allergens.


Her question was “Why do we even allow this food to be imported when there is no regulation around food labelling from the country importing? None of the ingredients are checked or tested. The same foods are being imported into New Zealand.”

The email was referred to the Hon Damien O’Connor, Minister for Food Safety. He replied by letter in February, acknowledging Delwyn’s concerns and describing the New Zealand legislation and regulations relating to food allergens.

At the same time, Allergy New Zealand was also becoming concerned at the number of food recalls relating to undeclared allergens. There have been 10 allergen-related recalls in the first two months of this year alone, although not all related to imported products.

To understand the issues better, Allergy New Zealand raised a number of questions with New Zealand Food Safety. They provided a very full response as per below. In particular, it is noted,

“MPI also does daily monitoring of overseas notifications about food recalls, including recalls due to undeclared allergens, and then follows up to find out whether that food is available here. This has resulted in a number of recalls of imported food.” (under Q6).

  1. Are importers of manufactured food meant to comply with New Zealand’s Food Safety regulations, including that of allergen labelling of pre-packed food and allergen information available on request from consumers (who may also be retailers or food services) for non-prepacked items?

Yes, importers of manufactured food must comply with New Zealand’s food safety regulations to keep consumers safe. The introduction of the Food Act 2014, in March 2016, brought about an increased awareness of the importance of allergen management for manufacturers, retailers and verifiers.

Food businesses should manage all allergens, and can do this in many ways. Detailed supplier product specifications, or certificates of analysis, are both common ways we see food businesses effectively manage allergens.

To import food—whether it’s to sell it or to use as an ingredient—a business must be registered with MPI as a food importer, or use an agent who is registered. Find out more at:

Under the Food Act, it is the responsibility of all businesses – not just importers – to know what is in their food, so that it will meet New Zealand’s labelling rules when it makes it to the consumer.

The composition of imported products, and associated labelling, must meet the rules in the Australia New Zealand Food Standards Code, if sold in New Zealand or Australia. These rules have been in place since 2002, and include the requirement for labelling information to be in English.

Labelling and composition information in English, helps consumers to make an informed decision about what to buy, whether it meets their dietary needs, and whether it contains certain ingredients – such as allergens – that they should avoid.

The majority of food sold in New Zealand shops must be labelled. Where food is not required to be labelled (for example, bakery products made/baked onsite at where these are sold), allergen information needs to be available for staff to provide to customers when allergen information is requested.

Incorrect labelling is a major cause of food recalls – which can be expensive and damage a food business’ reputation. To help, New Zealand Food Safety has produced labelling guides, including for hemp seed products, alcoholic drinks and honey – available at

It is now possible for Ministry for Primary Industries (MPI), and local council food safety officers, to issue infringements for some labelling non-compliances which will assist with improving compliance overall.

  1. Do all the countries from which we import food have the same regulations as ours including a) labelling (and list) of allergens; and b) food control plans for management of food allergens?

No, the rules in other countries vary. This is why in New Zealand the Food Act is clear it is the importer who is responsible for knowing the composition of the food. As the individual(s) responsible for the food coming here, it is they who need to ensure all important information about their food is provided to their client or customer.

  1. How are importers and distributors of imported food (pre-packed or not) monitored for compliance with our allergen regulations?

Under the Food Act, all registered food businesses, including distributors, are monitored for compliance through routine verification checks. How the food business manages allergens is part of these checks. Most importers also sell food, so would be subject to verification. However, if a business is only involved in importing food for supply to other manufacturers or retailers, they won’t necessarily require verification.

  1. Does monitoring apply to every imported product or just to the importer?

It’s the people who own and operate food businesses who are legally accountable for their food being safe. The system of registration, verification and enforcement establishes each business’ specific rules, based on what they do, and provides assurances about their performance. Monitoring can play a valuable part, but the New Zealand system aims higher, working to encourage strong food safety cultures and practices that suit each and every business.

  1. Do stores selling imported products have to comply with regulations specifically relating to allergens? Is there any information they are obliged to give consumers e.g. ‘if you have a reaction to an undeclared allergen…(information that actually should be available in all supermarkets…)

Yes. All supermarkets are food retailers, and have the same responsibilities.

  1. Does MPI do spot checks (e.g. visiting supermarkets and arranging tests on random products on the shelves) or rely on consumers reporting reactions to undeclared allergens, or manufacturers themselves, to identify, investigate and instruct a recall of a product?

As noted above in question 3, all registered food businesses are verified.

MPI receives information about undeclared allergens from a variety of sources, including food businesses, verifiers and consumers. Verifiers and food businesses are legally required to report all critical non-compliances, such as undeclared allergens on labels, to the registration authority (the local council or MPI).

Once a report is received, an investigation is carried out to determine what action is required, including product recall and/or re-labelling. MPI works with food businesses in carrying out food recalls. More information on the recall process is available here:

MPI also does daily monitoring of overseas notifications about food recalls, including recalls due to undeclared allergens, and then follows up to find out whether that food is available here. This has resulted in a number of recalls of imported food.

From time to time, MPI carries out targeted surveys. MPI carried out surveys in 2014 and 2015 on the use of sulphites in fresh meat and a number of retailers were prosecuted as a result.

  1. What was the total of all food recalls in last 12 months in New Zealand? How many of these were due to undeclared allergens?

Information on consumer level recalls is available at: The total number of consumer level recalls undertaken in 2019 was 84. Note that four of these recalls were not published on the MPI website, and 40 of these related to allergens.

  1. Of the food recalls for undeclared allergens in last 12 months, how many were due to:
  1. Consumer report of reaction due to undeclared allergen – 4. However, if additional investigation in other businesses occurred (as the original recall suggested further action across the sector is required) and resulted in recalls, these are captured in point d.
  2. Consumer report of (suspected) undeclared allergen on the label – 0
  3. Manufacturer or retailer report of (suspected) undeclared allergen on the label – 3
  4. Undeclared allergen identified through regulatory process – 28. This category includes recalls noted in point a above, that were triggered by notifications received from the verifier or issues of non-compliant labelling noticed during verification, notification received from MPI business groups who may be involved with the food business (such as Border Clearance), or issues noted during another recall or food investigation:
  5. Other e.g. products identified through processes in other countries. 5 recalls were triggered by information received from overseas competent authorities
  1. How does our food recall data compare to Australia?

Although we share the same rules under the Food Standards Australia New Zealand Code, a number of factors can contribute to differing food recall rates in the two countries, which means a direct comparison can be misleading.

Of 87 recalls undertaken in Australia last year, 32 related to allergens (37%). New Zealand had a total of 84 recalls undertaken in 2019, with 40 related to allergens (48%). This difference is likely to be caused by the recalls associated with undeclared milk in chocolate last year, which did not affect Australia. Food recall information from Australia is available at:

  1. On the basis of the high rate of food allergen-related recalls, the perception of New Zealand food-allergic consumers is that food allergen labelling in general, and particularly on imported products, is as per Delwyn’s email – no monitoring and a big risk, and labels can’t be trusted. This is also the perspective in Australia following the publication of the study. However, it could also be that the high level of food recalls in New Zealand, for undeclared allergens, are due to improved regulations – and implementation of these - here. If the latter is true, what is the evidence for this?

Consumers rightly expect they can trust their food to be safe. MPI believes this is critically important, too. Consumers are more strongly scrutinising food businesses and demanding they step up. Food safety professionals across New Zealand are also working hard to educate businesses and manage non-compliance wherever it occurs. The pressure is growing for food businesses – and the people responsible in those businesses – to lift their performance and protect those who buy their food. Targeting stores only importing products is not appropriate, as the challenge is wider and MPI wants all businesses to properly manage allergens, so every consumer can trust they are protected and safe.

  1. Given food-triggered severe reactions (anaphylaxis) are not reportable in New Zealand through the health system, how does MPI and New Zealand Food Safety measure the effectiveness of its regulatory regime in respect to food allergens?

Although food-triggered severe reactions are not required to be notified through the health system, MPI does receive a number of reports from consumers, or members of their family, about these reactions and takes appropriate action in response. All such notifications are treated as high priority and action is taken to investigate the report and prevent further harm as outlined above.

The rapid response to notifications and effective management of allergen-related recalls, and prosecutions, demonstrate the effectiveness of the food regulatory system.

There’s always room for improvement under any framework and we welcome feedback to strengthen it.

However, we also encourage consumers who have allergies to read labels on food products—if in doubt, don’t buy it. Ask the retailer or manufacturer for a list of ingredients. If you become ill from a suspected, undeclared allergen in a food or food product, immediately report it, and if at all possible, save the uneaten portion for testing at your local council or MPI.

Allergy New Zealand thanks MPI for their very comprehensive response.

Remember, to report a complaint regarding food allergen labelling, go to:

MPI Food Safety on 0800 00 83 33, or by email: