Changing a Custom Food Control Plan: Does Your New Product or Process Need Evaluation?

Custom food control plan changes deserve attention before a new product reaches customers. A different ingredient, process or intended consumer can affect the assumptions behind the existing plan, even when the business name and premises stay the same.

This guide answers a specific question: does a new product or process need evaluation, and what information should you prepare to find out? It is for New Zealand businesses already operating under a custom Food Control Plan (FCP), including My Food Plan. It does not replace the separate rules for template FCPs, national programmes or risk management programmes.

When should you review custom food control plan changes?

Start a review when the proposal may go beyond what the plan describes or relies on. MPI’s guidance on changing a custom FCP covers different amendment and notification routes. Use that guidance with the details of your own operation, rather than choosing a route from the product name alone.

Before the discussion, describe what will stay the same as well as what will change. “Another sauce” is less useful than a comparison showing the ingredients, processing steps, packaging, storage conditions and intended use of the current and proposed products.

• Product: What is different about the recipe, ingredients, packaging or proposed shelf life?
• Process: Will you add, remove or alter a step, change equipment or use a different operating limit?
• Consumer and use: Who will eat the food, and is further preparation expected?
• Supply: Will storage, transport, distribution or the customer type change?
• Scope: Which existing plan section appears to cover the activity, and which parts are unclear?

These are suggested review questions, not a legal classification checklist. A change can affect several areas at once. If the proposal also involves a new site, a new operator or another regulatory pathway, include that in the discussion instead of assessing the recipe in isolation.

Does every change need evaluation?

MPI separates significant amendments requiring evaluation, significant amendments that may not require evaluation, minor amendments and changes requiring notification. The category depends on the effect of the change. A marketing description such as “minor recipe improvement” does not establish its regulatory category.

Use MPI’s examples as a starting point and check the complete proposal with the relevant adviser or MPI where the classification is unclear. Keep that classification decision with the change documents. The category summary above is not an approval to manufacture or sell under amended arrangements.

For plans within its scope, section 46 of the Food Act 2014 distinguishes written notification of a non-significant amendment from an application to register a significantly amended plan. This is why “no evaluation” does not mean “no formal action”.

Prepare a clear change brief

A clear brief lets the people reviewing the change see the same facts. Organise it around the difference between the current approved operation and the proposal. The following is an AFVA preparation suggestion; it is not a substitute for the application form or the evidence requested for your change.

1. Identify the current baseline

Gather the current registered plan, scope of operations, relevant conditions and the latest controlled versions of affected procedures. Identify any previous evaluation information that the proposal relies on. If several documents appear current, resolve that before sending the brief so the reviewer knows which version describes the operation.

2. Describe the proposal precisely

Write a short before-and-after comparison. Include the proposed product, ingredients, process sequence, equipment, packaging, storage, distribution and intended consumers where they are relevant. Mark affected steps on a process flow diagram. Distinguish confirmed decisions from ideas that are still being considered.

3. Review hazards and controls

MPI’s custom FCP development guidance explains how ingredients, process steps, hazards and controls fit together. For a proposed change, identify which existing controls still apply, which need revision and what has not yet been demonstrated. Specify who will carry out each check, how it will be recorded and what happens if the result is unacceptable.

4. Identify the evidence gap

A proposed control needs an appropriate basis. MPI’s explanation of evaluation, validation and verification describes validation as evidence that a plan or process can consistently produce safe and suitable food. The evidence needed depends on the process; a familiar-looking product does not establish that its previous safety assumptions still hold.

Keep existing supporting information separate from evidence still to be obtained. Where trials, scientific references or specialist input are proposed, describe their purpose and who will assess the result. Avoid presenting an unfinished study, a supplier assurance or a single result as proof of a broader claim it does not establish.

5. Prepare the document changes

List the plan sections, procedures, forms, specifications, staff instructions and product information that may need revision. Show proposed amendments clearly. Keep a short document register identifying the existing version, proposed version, responsible person and intended release point. This helps prevent a revised recipe being used with an old production instruction.

An example: adding a new packaged product

Illustrative example: A manufacturer has a registered custom FCP and wants to add a new packaged product. This is a planning example, not an AFVA client case study or a classification of a particular business.

The owner’s initial question is, “Can we add it to the existing range?” A useful review breaks that into smaller questions: which ingredients are different, whether the process changes, whether the existing controls cover those differences, and what the proposed storage and use instructions depend on.

1. Write the proposal: record the current product and the proposed product, with the differences highlighted.
2. Check the plan: identify relevant scope and process sections rather than assuming that a similar product name means coverage.
3. List unresolved questions: separate the amendment route from technical matters such as the evidence for a control or proposed shelf life.
4. Assign actions: name who will obtain missing information, review the plan and confirm the applicable formal steps.
5. Set a release decision: identify the evidence and any approvals needed before the changed commercial activity begins.

This approach also helps when the proposal changes during development. If the team later chooses different packaging or alters the process, update the brief and reassess the affected decisions. The review should follow the final proposal, not an earlier version that nobody intends to manufacture.

What if you use My Food Plan?

My Food Plan is a type of custom FCP. It uses standard content tailored through MPI’s process. Standard cards do not make every future activity automatically part of your registered scope. MPI’s steps for My Food Plan distinguish the standard content from the completed business-specific plan and its evaluation.

MPI currently requires a desktop evaluation of the completed business-specific My Food Plan before initial registration. A later amendment may need further evaluation. The standard content is therefore not a blanket exemption from assessment.

For a scope-related change, use My Food Rules to obtain the updated information and follow the resulting instructions alongside MPI’s amendment guidance. Keep the current and proposed card sets identifiable so it is clear which activities each describes.

Keep advice, evaluation and approval separate

A consultant can help analyse the proposal and prepare useful documents. A recognised evaluator assesses the relevant plan or amendment where evaluation is required. MPI handles the amendment approval process. A verifier checks implementation against the applicable requirements. One step is not evidence that all the others are complete.

MPI’s guidance on using a food consultant says that a consultant cannot evaluate or verify a plan or programme they wrote. For custom FCPs, MPI also requires the verifier to differ from the evaluator. Confirm recognition, scope and independence for the actual work before assigning the roles.

1. Confirm the proposed activity and the applicable amendment route.
2. Agree the advice, technical work and independent services needed.
3. Update the plan and gather the supporting evidence.
4. Obtain evaluation where required, and complete the applicable MPI submission or notification process.
5. Confirm any approval conditions and follow-up requirements before introducing the changed activity.

Use the current change form linked from MPI’s amendment page and follow its instructions for the documents and submission method. Do not rely on a form saved for an older project. The steps above organise the work; the actual form, official requirements and MPI’s decision determine what is needed in your case.

Put the change into practice

Treat implementation as a separate part of the project. Once the required formal steps have been completed, the revised documents need to reach the people doing the work. Discuss how to prevent old instructions and records from remaining in use at the same time as the revised process.

A practical handover can identify the released document versions, affected staff, training or briefing completed, the first production activity to be checked and the person responsible for following up any issues. Keep supporting records truthful and contemporaneous; do not fill gaps by creating evidence of checks that did not happen.

Plan how the business will check that the change works as intended. For example, ask staff to explain the revised step and review the relevant records once the activity is operating. These are suggested implementation checks. They do not replace an evaluation, a required verification or a condition imposed by MPI.

Mistakes that make change reviews harder

• Calling a change minor before reviewing its effect. Describe the facts first, then determine the category.
• Reviewing only the recipe. Include related processing, equipment, packaging, storage and customer changes.
• Sending inconsistent versions. Make sure the brief, process diagram and proposed plan describe the same operation.
• Confusing evaluation with approval. Track the evaluator’s work and MPI’s decision separately.
• Assuming existing evidence covers the new arrangement. Check what conditions the evidence actually supports.
• Leaving the handover until launch day. Plan document release, staff briefing and follow-up as part of the change.

How a food consultant can help

Access Food Verification & Auditing Limited (AFVA) can help review food safety procedures and records, identify gaps and organise practical improvements. For a product or process change, a clearly scoped consulting engagement can help turn the proposal into a structured brief, document review and action list.

Our HACCP consulting and food safety plan support may be relevant where the proposal affects the hazard analysis or controls. For a broader explanation of advisory support, see what a food consultant does in New Zealand.

Consulting does not guarantee acceptance of an amendment or a verification outcome. Any formal evaluation or verification service is subject to recognition, scope, conflict-of-interest and independence requirements. Agree what AFVA will do, what the business must implement and which decisions remain with the relevant authority or independent assessor.

Frequently asked questions

Review the change before committing to launch

Start with a clear comparison of the current operation and the proposal. Identify what the plan covers, what remains uncertain and which formal decisions are needed. That gives the review a defined purpose and helps your team prepare the right information.

General information only: Requirements depend on the complete food activities, products, processes, locations and sales model. Use current official guidance and confirm the requirements applying to the specific business before relying on a classification, timeframe or record list.