Need Custom Food Control Plan evaluation or support?
Access Food Verification & Auditing Limited provides Custom Food Control Plan evaluation and food-safety support across New Zealand. Contact AFVA for free initial guidance about your activities, plan readiness, evaluation pathway and next steps.
A standard Food Control Plan works well for many cafés, restaurants, retailers and food-service businesses. But when a food business uses specialised processes, manufactures products outside an available template, or needs controls designed around its own operation, a Custom Food Control Plan in New Zealand may be required.
A Custom Food Control Plan—often shortened to Custom FCP—must accurately describe the business, products, processes, hazards, controls, monitoring, corrective actions and records. It must follow the appropriate evaluation and registration pathway before it can be used as the business’s registered food-safety plan.
Quick answer: when do you need a Custom Food Control Plan?
You may need a Custom FCP when your food activities, products, processes or risk controls are not adequately covered by an available template Food Control Plan or National Programme. Confirm the correct pathway using MPI’s My Food Rules tool and, where needed, discuss the result with MPI, your registration authority or a recognised evaluator before investing in plan development.
In this guide
What Is a Custom Food Control Plan in New Zealand?
A Food Control Plan is a comprehensive system for managing food safety and suitability. A Custom Food Control Plan is tailored to the actual activities and risks of a particular food business rather than relying entirely on a pre-evaluated standard template.
The plan should explain not only what the business intends to do, but how it will consistently control relevant hazards in practice. It normally connects the product description and process flow to hazard identification, preventive controls, critical or operational limits, monitoring, corrective action, verification, record keeping and review.
MPI’s Custom Food Control Plan guidance explains that businesses using this pathway need to develop or obtain the relevant plan, complete the required evaluation process, register it, arrange verification and follow the registered plan when producing food.
Custom does not mean informal
A custom plan gives a business flexibility, but that flexibility must be supported by technical reasoning and evidence. A procedure copied from another company may not control the risks in your product. The plan must match your recipes, equipment, process conditions, packaging, storage, distribution, intended consumers and operating environment.
When Might Your Business Need a Custom FCP?
The correct food-safety measure is determined by the activities your business carries out—not by the business name alone. Two manufacturers selling similar products may have different requirements because their processes, scale, distribution or controls are different.
A Custom Food Control Plan may be appropriate when one or more of the following applies:
| Possible indicator | Why it matters | Evidence to consider |
|---|---|---|
| No available template covers the activities | The business needs a plan designed around its own food-safety risks and operating controls. | My Food Rules result, activity scope and product/process descriptions. |
| Specialised or novel processing | Special controls may be needed for lethality, preservation, cooling, fermentation, drying, reduced oxygen packaging or another technical process. | Process validation, scientific references, trials, equipment data and expert input. |
| Multiple sectors or complex operations | One business may combine several manufacturing, food-service, packing, storage or distribution activities that are not neatly covered by one template. | Site map, scopes, product families, process flows and responsibility structure. |
| Business-specific controls are essential | Safety may depend on controls, limits or monitoring arrangements developed specifically for the product and process. | Hazard analysis, control justification, monitoring method, corrective action and records. |
| Significant change to an existing custom plan | A new product, process, technology, site or control may change the hazard profile and require plan amendment and further evaluation. | Change assessment, revised flow, updated hazard analysis, validation and implementation plan. |
Do not choose a Custom FCP based only on preference
A Custom FCP can require substantial development, validation, evaluation, registration and ongoing verification work. First confirm whether an existing template, National Programme, My Food Plan pathway or another regulatory measure already covers the activities.
Template Food Control Plan vs Custom Food Control Plan
A template FCP is pre-evaluated for the activities it covers. The operator selects and follows the relevant sections. A fully customised plan is developed for a particular operation and normally requires independent evaluation before registration. MPI also provides the My Food Plan pathway for eligible businesses using the My Food Rules tool; its exact evaluation and registration steps should be confirmed for the activities selected.
| Point | Template FCP | Custom FCP |
|---|---|---|
| Design | Pre-evaluated for specified food activities and adapted by selecting the applicable content. | Tailored to the business’s products, processes, hazards and controls. |
| Suitable for | Activities fully covered by the template, often including common food-service and retail operations. | Activities or controls not adequately covered by an available template or programme. |
| Technical evidence | Business implements the prescribed controls and keeps required evidence. | Business must justify and validate its product- and process-specific controls. |
| Evaluation | The template itself has already been evaluated; individual operators generally do not commission a full evaluation of the unchanged template. | The applicable custom-plan evaluation pathway must be completed before registration. |
| Ongoing responsibility | Follow the template, keep records, update selections and pass verification. | Follow the registered plan, maintain evidence, control changes, review effectiveness and pass verification. |
For a broader comparison of registration pathways, read Food Control Plan vs National Programme: Which Does Your Business Need?
What Should a Custom Food Control Plan Contain?
There is no useful one-page shortcut for a complex operation. The plan must be detailed enough for staff to implement, management to review, an evaluator to assess and a verifier to check against actual practice. The content should be proportionate to the scope and risk.
| Plan area | What should be clear |
|---|---|
| Business scope | Legal operator, sites, activities, products, intended consumers, distribution, responsibilities and boundaries of the plan. |
| Products and processes | Product descriptions, ingredients, safety characteristics, packaging, shelf life, storage, intended use and verified process-flow diagrams. |
| Hazard analysis | Relevant biological, chemical, physical and allergen hazards at each process stage, with reasons for inclusion or exclusion. |
| Controls and validation | How hazards are controlled, the limits or criteria applied, and credible evidence showing the control can achieve the required outcome. |
| Monitoring and corrective action | What is checked, how, where, when and by whom; acceptance criteria; response to loss of control; product disposition and escalation. |
| Supporting systems | Supplier approval, allergen control, cleaning, maintenance, calibration, pest control, staff competency, traceability, recall and complaint handling. |
| Operator verification and review | How the business will confirm the system works, review records and trends, investigate failures, conduct internal checks and manage plan changes. |
Validation is not the same as evaluation
Validation is the technical evidence that a selected control can achieve its intended result—for example, evidence supporting a cooking process, pH limit, water-activity target, cooling method or shelf life. Evaluation is the independent assessment of whether the complete plan meets applicable requirements and is likely to produce safe and suitable food when properly implemented.
An evaluator does not create missing scientific proof simply by reviewing the plan. If your controls are not validated, the evaluation may need to pause while trials, testing, calculations or other evidence are completed.
How Does Custom Food Control Plan Evaluation Work?
Custom FCP evaluation is a structured, evidence-based assessment completed before registration. Its purpose is to determine whether the plan is appropriate for the stated operation and is likely to result in safe and suitable food when followed. MPI provides a current overview of how evaluation and verification work for a new Custom FCP.
| Step | Stage | What happens |
|---|---|---|
| 1 | Confirm the pathway and scope | Define the operator, sites, activities, product families and processes. Confirm that a Custom FCP is the correct measure and identify the applicable evaluation route. |
| 2 | Develop and test the plan | Prepare the plan, verify process flows, complete the hazard analysis, set controls, validate important limits, prepare forms and test whether the system is workable. |
| 3 | Engage the correct evaluator | Select an MPI-recognised evaluator whose recognition scope covers the products, processes and evaluation functions required. |
| 4 | Desktop document review | The evaluator assesses the plan, supporting evidence and legal alignment. Questions, gaps and requests for clarification are recorded. |
| 5 | Responses and revisions | The business updates documents and provides missing evidence. Several review rounds may be needed if the initial submission is incomplete or technically complex. |
| 6 | On-site assessment where required | An on-site component may be needed to assess premises, equipment, process capability, trial implementation or matters that cannot be adequately evaluated from documents alone. |
| 7 | Evaluation outcome and report | When the evaluation is complete, the evaluator documents the outcome. The required report forms part of the registration evidence where applicable. |
| 8 | Registration and verification arrangements | Submit the required plan and evidence to MPI, provide verifier arrangements where required, receive registration, implement the plan and complete verification within the applicable timeframe. |
What does the evaluator actually check?
The evaluator considers whether the plan meets relevant legal requirements, accurately covers the proposed operation, identifies relevant hazards, contains effective and validated controls, defines workable monitoring and corrective action, includes appropriate records, and is likely to produce safe and suitable food when followed.
Evaluation is not a guarantee that daily operations will always comply. The business remains responsible for implementation. That is why verification happens after registration—to check what the operator is actually doing and whether the registered plan is effective in practice.
What Documents Should You Prepare for Custom FCP Evaluation?
A well-organised submission makes evaluation faster and more predictable. The exact evidence depends on the operation, but the evaluator may request:
- a complete draft Custom Food Control Plan with document control;
- legal operator, site, scope and responsibility details;
- product descriptions, specifications, intended use and consumer groups;
- confirmed process-flow diagrams for each product or process family;
- hazard analysis and the rationale for control decisions;
- validation for critical limits and important food-safety controls;
- monitoring procedures, corrective actions and blank record forms;
- supplier approval, allergen, cleaning, calibration, maintenance and pest-control procedures;
- traceability, recall, complaint and non-conforming-product systems;
- label, packaging, storage and shelf-life evidence;
- training and competency requirements;
- trial-production, implementation or historical records where available;
- any relevant scientific literature, laboratory results, calculations, expert reports and equipment specifications.
The documents should tell one consistent story. If the process flow says the product is air-dried, the hazard analysis must assess that step, the procedure must describe the control, and the records must show how the control will be monitored. Contradictions between documents are a common source of questions.
What Happens After the Evaluation?
1. Arrange a recognised verifier
Before registration, you may need evidence that an appropriate verifier has agreed to provide verification services. The verifier’s recognition scope must cover the registered activities. Evaluation and verification are different functions, and independence or conflict-of-interest requirements must be managed when selecting providers.
2. Apply to register the plan
Custom Food Control Plans are registered with MPI. The application may need the completed plan, evaluation report, verifier confirmation and other information specified for the applicable pathway. See MPI’s guidance on creating and registering a Custom Food Control Plan.
3. Implement the registered plan
Registration is not the end of the process. Train staff, issue controlled copies, use the approved records, monitor the specified controls, deal with deviations, complete operator-verification activities and keep evidence. Your actual practices must match the registered plan.
4. Complete external verification
The recognised verifier checks whether the business is following the plan, keeping the required records and effectively controlling food-safety risks. The first verification takes place after registration within the timeframe applicable to the business. Ongoing frequency can change depending on the measure, risk, performance and verification outcome.
AFVA also provides Food Control Plan verification services within recognised scope. Where AFVA has completed the evaluation, verification-provider arrangements must respect applicable independence and conflict-of-interest requirements.
5. Renew registration and control changes
MPI states that Custom FCP registrations must be renewed annually. A business should also assess proposed changes before implementation. New products, processes, equipment, premises, packaging, shelf life or control limits may require document updates, validation, notification, evaluation or registration action. MPI provides guidance on changing a Custom Food Control Plan.
How Long Does Evaluation Take and What Does It Cost?
There is no single evaluation price or timeframe for every Custom FCP. Independent evaluators set their own fees. MPI registration charges and external verification charges are separate. Current government charges should be checked on MPI’s Food Act fees and charges page.
The work required is affected by:
- the number of sites, activities, product families and process flows;
- the technical complexity and food-safety risk;
- whether controls and limits are already validated;
- the quality, consistency and completeness of the submitted documents;
- the number of clarification and revision rounds;
- whether an on-site component or specialist technical input is required;
- laboratory, trial, shelf-life or process-validation work still outstanding;
- evaluator availability and the business’s response time.
For an accurate quotation, provide the evaluator with the proposed scope, product list, process summary, current plan status, key validation evidence, number of sites and desired timeframe. A low initial estimate based on incomplete information may change once the true scope is known.
Common Problems That Delay Custom FCP Evaluation
| Common gap | Why it causes delay | Better preparation |
|---|---|---|
| Scope is vague or inconsistent | The evaluator cannot confirm what products, sites and activities the plan covers. | Prepare one controlled scope statement and align it across all documents. |
| Process flows omit real steps | Hazards may not have been assessed at receiving, holding, cooling, drying, rework, packing or dispatch. | Walk through the actual process and confirm each flow onsite before submission. |
| Critical limits are copied without evidence | A limit from another product may not control the hazard in this formulation or process. | Link every important limit to suitable legislation, guidance, trials, science or expert validation. |
| Monitoring is not operational | The plan says “monitor regularly” but does not define what, how, when, where and who. | Use precise instructions, responsibilities, frequencies, acceptance criteria and records. |
| Corrective actions do not control affected product | Correcting equipment or a process does not decide what happens to food produced while control was lost. | Include containment, investigation, product assessment, disposition, documentation and recurrence prevention. |
| Plan and records do not match | The forms cannot demonstrate that the written monitoring and review requirements will be met. | Cross-check every required monitoring and verification activity against a usable record. |
How AFVA Can Help With a Custom Food Control Plan
Access Food Verification & Auditing Limited supports New Zealand food businesses with Custom FCP evaluation and related food-safety services within recognised scope. Depending on the project and independence requirements, support may include:
- initial review of activities and likely pathway;
- confirmation of proposed evaluation scope;
- Custom Food Control Plan evaluation;
- clear evaluation questions and document-gap comments;
- review of hazards, controls, monitoring, corrective actions and records;
- guidance on evaluation evidence and registration steps;
- food-safety consulting, validation planning and audit preparation where appropriately separated from formal evaluation;
- coordination guidance for external verification after registration.
For service details, visit AFVA’s Custom Food Control Plan Evaluation page. For a quote, provide your business location, products, processes, number of sites, existing documents and intended launch or registration date.
Custom Food Control Plan NZ: Frequently Asked Questions
What is a Custom Food Control Plan?
A Custom Food Control Plan is a food-safety plan tailored to a business’s specific activities, products, processes and risks. It defines how the operator will produce safe and suitable food and must complete the applicable evaluation and registration pathway.
How do I know whether I need a Custom FCP in New Zealand?
Use MPI’s My Food Rules tool and accurately enter every food activity. A Custom FCP may be needed where available templates or National Programmes do not adequately cover the operation. Ask MPI, the registration authority or a recognised evaluator if the result or scope is unclear.
Does every food manufacturer need a Custom Food Control Plan?
No. The correct measure depends on the actual food activities and risks. Some manufacturers may fit a National Programme, an available template, My Food Plan or another regulatory regime. Classification should be confirmed before developing a custom plan.
Who can evaluate a Custom Food Control Plan?
Use an MPI-recognised evaluator whose recognition scope covers the required evaluation function and the business’s products and processes. Recognition should be checked before work begins.
What is the difference between Custom FCP evaluation and verification?
Evaluation assesses the written plan and supporting evidence before registration. Verification happens after registration and checks whether the business is implementing the plan, keeping records and managing food-safety risks in practice.
Can a Custom FCP evaluation be completed remotely?
Document review is commonly completed as a desktop activity. An on-site component may still be required depending on the plan, process, evidence and matters that cannot be adequately assessed remotely. Confirm the evaluation approach with the evaluator.
How long does Custom FCP evaluation take?
Timing depends on complexity, document quality, missing validation, the number of review rounds, any on-site work and how quickly the business responds. A complete, consistent and well-supported submission is usually more efficient to evaluate.
How much does Custom Food Control Plan evaluation cost?
Independent evaluators set their own fees. Cost depends on scope, technical risk, completeness and the work required. MPI registration and ongoing verification charges are separate, so request a written scope and quotation.
Can I start selling food before my Custom FCP is registered?
A business required to operate under a registered Custom FCP should not begin the covered commercial food activities until the applicable plan has completed its required evaluation and registration steps. Confirm the exact commencement requirements with MPI before launch.
Do changes to an existing Custom FCP need another evaluation?
Some significant changes may require further validation, evaluation, notification or registration action. Assess changes before implementation and check MPI’s current change process for the type of Custom FCP involved.
Need Help With a Custom Food Control Plan?
AFVA provides professional Custom FCP evaluation and practical food-safety support for eligible food businesses across New Zealand. Contact us early—before planned production or registration deadlines—to confirm the scope and documents required.
View Custom FCP Evaluation Services Contact AFVAGeneral information only: The correct Food Act measure, evaluation route, registration process and technical evidence depend on the specific business activities, products, processes and current legal requirements. This guide does not replace business-specific regulatory, technical or legal advice.
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.