If you are starting or changing a food business in New Zealand, one of the first questions you must answer is: Do I need a Food Control Plan or a National Programme?
The correct pathway depends on every food activity carried out by the business, including how food is made, handled, stored, packaged, transported and sold. It is not determined only by your main product, the size of the business or whether you operate from home.
This guide compares Food Control Plans, My Food Plan, National Programme 1, National Programme 2 and National Programme 3, and explains how to identify the pathway that is likely to apply to your business.
Quick answer: Food Control Plans generally apply to businesses carrying out higher-risk food-service, retail or manufacturing activities. National Programmes apply to food sectors assigned to NP1, NP2 or NP3 according to risk. However, the final answer must be based on your complete food activities. Use MPI’s My Food Rules tool before applying.
Food Control Plan vs National Programme: Quick Comparison
| Requirement | Food Control Plan | National Programme |
|---|---|---|
| General risk category | Generally used for higher-risk food activities requiring a documented plan. | Used for food sectors assigned to NP1, NP2 or NP3, with NP3 the highest-risk National Programme level. |
| System used | A registered written Food Control Plan describing applicable food-safety procedures and controls. | The business follows the legal requirements and applicable National Programme guidance without developing a full individual Food Control Plan. |
| Available pathways | Template FCP, Custom FCP or My Food Plan, depending on the operation. | National Programme 1, 2 or 3. |
| Independent evaluation | A business-specific Custom FCP generally requires independent evaluation before registration. Pre-evaluated content does not normally require the same business-specific evaluation. | A separate business-specific plan evaluation is not normally required. |
| Registration authority | The local council or MPI, depending on the type of plan, sites and business structure. | The local council or MPI, depending on the sites and business structure. |
| Registration renewal | Generally every year. | Generally every two years. |
| Records | Records required by the registered plan and actual food activities. | Relevant records required by the programme and actual food activities. |
| Verification | Required. The verification frequency can change according to the applicable rules and compliance performance. | Required. The frequency depends on the programme, applicable rules and compliance performance. |
The comparison is general guidance. The Food Act assigns requirements according to food sectors and activities, so two businesses selling apparently similar products may have different registration pathways.
What Is a Food Control Plan?
A Food Control Plan, commonly called an FCP, explains how a food business will produce safe and suitable food. It identifies the procedures, controls, monitoring, records and corrective actions that apply to the operation.
Food Control Plans commonly apply to food-service and retail businesses that prepare meals, as well as certain food manufacturers and other businesses carrying out higher-risk activities. MPI provides detailed information about Food Control Plans.
Template Food Control Plan
A Template Food Control Plan contains pre-evaluated food-safety procedures. A business selects and follows the parts that apply to its products and activities rather than writing a completely new plan.
The Simply Safe & Suitable Template Food Control Plan is commonly used by restaurants, cafés, takeaways, caterers and other food-service or retail businesses whose activities are covered by the template.
A template is not automatically suitable merely because a business serves food. The operator must check that every preparation, processing, packaging, wholesale and storage activity is covered.
Custom Food Control Plan
A Custom Food Control Plan may be required when a business’s products, processes or control measures are not adequately covered by an available template or other pre-evaluated content.
A business-specific Custom FCP generally needs to:
- Describe the business, products and intended consumers
- Document the process flow and food activities
- Identify relevant food-safety hazards
- Define control measures and critical limits where applicable
- Specify monitoring and verification activities
- Define corrective actions
- Identify the records that must be maintained
- Be independently evaluated before registration
Learn more about our Custom Food Control Plan evaluation service.
Independence and conflict-of-interest requirements can affect who may develop, evaluate and verify a Custom FCP. Confirm these arrangements before appointing consultants, evaluators and verifiers.
My Food Plan
My Food Plan allows an eligible business to build a tailored plan using relevant pre-evaluated MPI content. It can suit operations that need a broader combination of procedures than one standard template provides but can still be covered by available pre-evaluated material.
Eligibility depends on the actual activities selected in MPI’s system. Read MPI’s steps for getting My Food Plan or review our My Food Plan verification service.
What Is a National Programme?
National Programmes apply to food sectors and activities identified under the Food Act framework. They provide a risk-based set of requirements without requiring each operator to write a complete individual Food Control Plan.
A business operating under a National Programme must still:
- Register the food business and keep the registration current
- Ensure its registered scope covers all products, activities and sites
- Follow applicable food-safety requirements and programme guidance
- Maintain suitable premises, facilities and equipment
- Keep the records relevant to its activities
- Manage allergens, contamination, temperatures and other applicable risks
- Maintain traceability and recall arrangements
- Complete verification when required
- Correct non-conformances within the required timeframe
- Notify the registration authority about significant changes
MPI provides the current requirements and guidance for National Programmes.
National Programme 1
National Programme 1 (NP1) is the lowest-risk National Programme level. Depending on the exact scope, NP1 can apply to some transport, distribution, horticultural production, packing, storage or retail activities involving manufacturer-packaged foods.
NP1 is not simply a permanent one-off food licence. Registration generally renews every two years, the business must remain compliant, and verification requirements continue to apply according to the applicable rules.
National Programme 2
National Programme 2 (NP2) applies to specified low-to-medium-risk activities. Depending on the products and processes, examples can include certain early childhood food services, retail of chilled or frozen foods, bread manufacturing, confectionery and some shelf-stable snack-food manufacturing.
A shelf-stable product is not automatically NP2. Ingredients, processing, packaging, shelf-life controls, wholesaling and any additional activities must all be assessed.
National Programme 3
National Programme 3 (NP3) is the highest-risk National Programme level. It applies to specified activities requiring more extensive food-safety controls than NP1 or NP2. Depending on the operation, some beverage, dry-food, food-additive, storage, wholesale or manufacturing activities may fall within NP3.
The correct National Programme level must be confirmed from the complete scope. A business cannot choose NP1 or NP2 simply because the documentation or verification may appear easier.
Template FCP, Custom FCP, My Food Plan, NP1, NP2 and NP3
| Pathway | Generally used when | Important feature |
|---|---|---|
| Template FCP | All activities are covered by an available pre-evaluated template, such as Simply Safe & Suitable. | Follow the selected template procedures and keep the required records. |
| Custom FCP | The operation is specialised or complex and is not adequately covered by available pre-evaluated content. | A business-specific plan generally requires independent evaluation before registration. |
| My Food Plan | The business is eligible to combine applicable pre-evaluated MPI content into a tailored plan. | The plan is built according to the activities selected through MPI’s process. |
| National Programme 1 | The food sector and activities are assigned to the lowest-risk National Programme level. | The business follows applicable NP1 requirements and guidance. |
| National Programme 2 | The food sector and activities are assigned to the low-to-medium-risk National Programme level. | More controls may apply than under NP1. |
| National Programme 3 | The food sector and activities are assigned to the highest-risk National Programme level. | More extensive controls and evidence may be expected than under NP1 or NP2. |
Examples of Possible Registration Pathways
The following examples are indicative only. A small difference in ingredients, processing, packaging, storage or customer type can change the result.
| Example business activity | Possible pathway |
|---|---|
| Café or restaurant preparing and serving meals | Commonly a Template Food Control Plan |
| Takeaway, food truck or catering business preparing meals | Commonly a Template Food Control Plan |
| Early childhood centre preparing or serving food | Often NP2, depending on the complete activities |
| Retailer selling only sealed, manufacturer-packaged shelf-stable foods | May be NP1 |
| Retailer handling chilled or frozen foods | May be NP2, depending on handling and other activities |
| Manufacturer of bread, confectionery or some shelf-stable snack foods | May be NP2 |
| Manufacturer of certain beverages, dry foods or food additives | May be NP3 |
| Manufacturer using specialised or higher-risk processes not covered by available pre-evaluated content | A Custom Food Control Plan may be required |
| Importer, warehouse or distributor | NP1, NP2 or NP3 may apply according to the food, storage, handling and distribution activities |
Do not use this examples table as the final classification. Complete MPI’s My Food Rules tool using accurate information about your business.
What Determines Whether You Need an FCP or National Programme?
The decision must consider the complete operation, including:
- The types of food and ingredients handled
- Whether food is ready-to-eat
- Cooking, cooling, reheating or hot-holding
- Fermentation, acidification, drying or other preservation processes
- Whether products require chilled, frozen or ambient storage
- Packaging methods, including vacuum or modified-atmosphere packaging
- Intended shelf life and shelf-life controls
- Whether products are repacked or relabelled
- Direct-to-consumer and wholesale supply
- Importing, storage, transport and distribution
- Mobile trading, market stalls and online sales
- Whether consumers include vulnerable groups
- The number and location of production, storage and sales sites
Assess every current and proposed activity. Leaving wholesale, importing, repacking or an additional storage location out of the application can result in an incomplete registration scope.
How to Identify the Correct Plan or Programme
Step 1: List Every Product and Food Activity
Prepare a complete list of products, ingredients, process steps, packaging, storage conditions, shelf life, customers, sales methods and locations. Include seasonal products and activities carried out only occasionally.
Step 2: Use MPI’s My Food Rules Tool
Complete MPI’s My Food Rules tool. Answer according to what the business will actually do, not what you think will produce the simplest result.
Save the outcome because it can help with your registration application, Scope of Operations and discussion with the registration authority or verifier.
Step 3: Review the Applicable Guidance
Check that the proposed template, My Food Plan content or National Programme guidance covers the whole operation. MPI publishes the relevant Food Act plans, programme guidance, forms and documents.
Step 4: Confirm the Registration Authority
Where you register depends on the plan or programme, the number of sites and the council districts in which the business operates.
| Business structure | Usual registration pathway |
|---|---|
| Single-site business in one council district using a Template FCP or National Programme | Normally the local council |
| Online or mobile business based in one council district | Normally the council where the business is based |
| Fixed sites in more than one council district | Register sites with the relevant councils or, where eligible, register the sites as a group with MPI |
| Custom Food Control Plan or My Food Plan | MPI |
These are general pathways. Confirm the correct authority using MPI’s food-business registration guidance.
Step 5: Contact a Recognised Verifier
Many registration applications require the business to nominate a recognised verification agency. Written verifier confirmation may also be requested when an independent verification agency will complete the verification.
The verifier’s recognised scope must cover the relevant Food Control Plan or National Programme and the food activities being registered. Review our food-business registration process for the usual application steps.
Registration and Verification Are Different
Registration is the legal approval for the business to operate under the specified plan or programme. Verification is the independent assessment of whether the business is following the applicable requirements and producing safe and suitable food.
Receiving a registration certificate does not mean that the first verification has already been completed.
| New-business registration type | Normal initial verification timeframe |
|---|---|
| Template Food Control Plan | The verifier must generally visit within six weeks after registration |
| National Programme 1, 2 or 3 | The verifier must generally visit within six weeks after registration |
| Custom Food Control Plan | The verifier must generally visit within three months after registration |
| My Food Plan | The verifier must generally visit within three months after registration, or earlier if required by MPI |
Extensions may be available through the applicable process in limited circumstances. Confirm the current requirements with your registration authority and verifier, and do not wait until the end of the allowed period to arrange the visit. MPI explains the general process for getting a food business verified.
After the initial visit, the verification frequency can increase or decrease within the applicable rules based on factors such as the programme, compliance performance and food-safety history.
During verification, the verifier may review:
- Whether actual activities match the registered scope
- Food handling and processing practices
- Cooking, cooling, reheating and temperature controls
- Cleaning and sanitising
- Allergen and cross-contamination controls
- Supplier approval and receiving checks
- Traceability and recall readiness
- Pest management and maintenance
- Staff knowledge, training and personal hygiene
- Monitoring records and corrective actions
- Implementation of the applicable plan or programme
Our food-business verification process guide explains what happens before, during and after the assessment.
Do Home-Based, Online and Mobile Businesses Need Registration?
The business model or premises type does not decide the plan or programme by itself.
| Business model | What determines the requirement |
|---|---|
| Home-based | The products and processes determine whether an FCP or National Programme applies. The home kitchen must also be suitable, and separate council planning or residential-business requirements may apply. |
| Online | Selling through a website or social-media page does not remove registration requirements. Manufacturing, repacking, importing, storage and distribution must all be assessed. |
| Food truck or mobile vendor | The foods prepared and sold determine the plan or programme. The base kitchen, water, wastewater, storage and mobile-trading approvals also need consideration. |
| Market stall | Regular commercial food sales commonly require registration. Event-organiser approval does not replace the operator’s own Food Act requirements. |
Common Mistakes When Choosing an FCP or National Programme
- Selecting a programme because another business sells a similar product.
- Choosing NP1 because it appears easier or less expensive.
- Considering only the main product and leaving out other activities.
- Omitting wholesale, importing, repacking, storage or distribution.
- Assuming all shelf-stable products are NP1 or NP2.
- Assuming a home-based or online business is exempt.
- Using a Template FCP without confirming that all processes are covered.
- Failing to arrange Custom FCP evaluation before registration.
- Applying before confirming the correct registration authority.
- Not obtaining verifier confirmation when it is required.
- Confusing registration with verification.
- Changing products, processes, ownership, location or sites without notifying the registration authority.
Confirming the correct pathway early can prevent registration delays, unexpected costs and non-conformances during initial verification.
Frequently Asked Questions
Is a National Programme easier than a Food Control Plan?
A National Programme generally involves less business-specific documentation than a Food Control Plan. However, the operator must still meet all applicable food-safety requirements, maintain relevant evidence and complete verification. A business cannot choose a National Programme merely because it appears easier.
Can I choose NP1 because it has fewer requirements?
No. Your food sector and actual activities determine whether NP1, NP2, NP3 or a Food Control Plan applies. Selecting a lower programme without legal grounds can result in an incorrect registration scope.
Is National Programme 1 a one-off registration?
No. National Programme registration generally needs to be renewed every two years. The business must remain compliant, complete verification as required and notify significant changes.
Does a Food Control Plan registration last longer than a National Programme registration?
No. Food Control Plan registration generally renews annually, while National Programme registration generally renews every two years. Verification is separate from registration renewal.
Does a home bakery need an FCP or National Programme?
It depends on the products and processes. A bakery making only certain shelf-stable products may follow a different pathway from one making chilled cream products, cooked meals or foods using specialised processes. Operating from home does not decide the programme.
Do I need a verifier before registering?
Many applications require the business to nominate a recognised verifier. Written verifier confirmation may be required when an independent verification agency will conduct the verification. Confirm the requirement with the relevant council or MPI before applying.
Does every Custom Food Control Plan require evaluation?
A new business-specific Custom FCP generally must be independently evaluated before registration. The treatment of pre-evaluated content, including My Food Plan, differs, so confirm the correct process for your plan.
What if I add a new product or process?
A new product, processing method, packaging system, wholesale activity or site can change the registered scope or the applicable plan. Contact the registration authority and verifier before introducing a significant change.
How can I check whether a food business is registered?
MPI provides public food-safety registers and lists, including registered Food Control Plan and National Programme businesses.
Need Help Choosing the Correct Food-Safety Programme?
Access Food Verification & Auditing Limited supports New Zealand food businesses with:
- Food Control Plan verification
- National Programme verification
- My Food Plan verification
- Custom Food Control Plan evaluation
- Registration-pathway guidance
- Scope of Operations review
- Verifier confirmation where applicable and within recognised scope
- Initial-verification preparation
- Food-safety procedures and records
- Corrective-action support
Not sure whether you need an FCP, NP1, NP2 or NP3?
We can review your proposed products, processes, packaging, storage and sales activities and explain the likely next steps. Contact us for free initial guidance.
This article provides general information only. Food-business classification, registration and verification requirements can change and must be confirmed for your specific products and activities with the appropriate council, MPI, verifier or evaluator.
Need Practical Food Safety Support for Your Business?
Contact us for free initial guidance. We provide practical, plain-English food safety support for New Zealand food businesses across all service areas.
This article provides general information only and is not a substitute for professional advice specific to your situation. Contact us for guidance based on your actual food activities and requirements.