Preparing for a Food Label Review in NZ: What to Send Before Printing

A useful food label review starts with the information behind the artwork. A reviewer needs to understand the exact product, ingredients, proposed claims and package being assessed. A polished label PDF alone cannot show whether those facts are current.

This guide helps New Zealand food brands, manufacturers and importers assemble one controlled information pack before printing. It focuses on the handover to the reviewer and printer. For the wider rules, use our complete food labelling requirements guide.

Confirm the product and review scope first

Start with a one-page brief stating the product name, variant, pack size, intended consumers, where it is made and where it will be sold. Explain whether it is a new product, reformulation, imported product, packaging change or correction to an existing label. Identify the manufacturer, brand owner and the person who will authorise printing.

Sales format matters. MPI’s retail food labelling guidance identifies situations where a retail food does not need a label, while information duties can still apply. Do not assume that retail packs, food supplied to caterers and ingredients supplied to another manufacturer all use the same information route. Tell the reviewer which sales channels are in scope.

Include the proposed shelf life, storage conditions, preparation directions and the supporting information you already have. State whether overseas markets are included. An assessment for New Zealand sale should not be treated as clearance for every export destination. Agree which questions the review will answer and which need separate specialist input.

Build the food label review information pack

Use a short index that identifies each file, its date and version, and the product variant it covers. The six groups below are a practical starting point. A reviewer may request more information for a particular product; not every document applies to every food.

Why the formulation and specifications need to agree

Where an ingredients list is required, ingredients are generally ordered by ingoing weight. FSANZ’s ingredients and percentage-labelling guidance also explains compound ingredients and characterising ingredients. A recipe using “seasoning” without the matching specification leaves the reviewer unable to follow the ingredient information through to the label.

Provide the full supplier evidence even when the proposed on-pack list is shorter. Deciding what must be declared is part of the assessment; a shortened label list is not a substitute for the underlying information. For the declaration names and presentation, refer to our Plain English allergen labelling guide rather than relying on a generic allergen list.

Keep nutrition and claims evidence linked to the product

Not every food requires a nutrition information panel (NIP). FSANZ’s NIP guidance explains exemptions and that some claims require nutrition information. Where a panel is needed, send its basis as well as the finished numbers. Identify whether values come from calculation, analysis or a combination, and explain the recipe and serving information used.

For a calculation, retain the saved file and ingredient-data sources so changes can be traced. Our guide to reviewing saved Nutrition Panel Calculator recipes covers that separate task. A reviewer can then identify whether the supplied values and artwork concern the same version, rather than reconstructing their history from emails.

FSANZ’s nutrition and health claims guidance explains that nutrition content claims have criteria and health claims need scientific support. Send the exact proposed statement and its evidence before treating it as final artwork. A claim copied from another pack does not establish that it is suitable for your product.

Make missing information visible

Do not hide an unresolved input inside a file described as final. Add a short open-items list with the question, affected product or panel, person responsible, requested response date and current status. Distinguish information not yet received from a review comment that has already been resolved.

If only part of a review can proceed, ask the reviewer to identify its limits clearly. Preliminary comments on wording are not the same as a completed assessment of the finished product and label. Resolve the missing input and check its effect on the whole pack before releasing the affected artwork.

Control the handover through to printing

1. Choose one current set. Give the recipe, supplier evidence, calculations and artwork clear versions. Keep superseded files separately so there is one obvious working set.
2. Send an indexed pack. Include the brief, file list and open items together. Agree a suitable channel for commercially sensitive formulation information with the reviewer.
3. Record each review comment. Note the affected artwork panel, the requested change, the action taken and any question that remains. Keep technical wording and design changes connected.
4. Check the revised proof. Compare the complete revised artwork with the comments, formulation and evidence. Check that a change on one panel has not left conflicting wording elsewhere.
5. Authorise a named printing file. Record the exact file version, date and responsible business decision-maker. Check the printer’s proof at actual size and confirm that coding or over-labelling will preserve the reviewed information.
6. Retain the release record. Keep the reviewed file, comments, evidence and print authorisation together. Reopen the affected assessment when a formulation, supplier, claim, pack or process changes.

For the finished proof, review readability as well as wording. FSANZ’s guidance on truth and legibility explains that required labelling must be legible, prominent and in English, and that food representations must not mislead. A text document cannot demonstrate what happens when that text is reduced, moved or placed on a curved pack.

Avoid common handover mistakes

• One file for several variants: show which recipe, specification set and artwork belong to each flavour and size; identify shared evidence rather than assuming it applies to every variant.
• Old supplier evidence: a familiar ingredient name does not confirm that the formulation or supplied code is unchanged. Check the current document against purchasing and production information.
• Unexplained nutrition numbers: preserve the calculation inputs or report and the finished-product basis. Do not send only a screenshot with no identifiable source.
• Late marketing edits: a new claim, ingredient image or product name can change the review question. Send the amended complete proof back for the affected checks.
• Ambiguous release emails: “looks good” does not identify the file, scope or outstanding questions. Use a clear record of the version being released and any conditions still to be resolved.

How AFVA can help with the label handover

Access Food Verification & Auditing Limited provides food labelling review, compliance-gap comments and practical recommendations. The service covers matters including ingredients, allergens, nutrition information, date and storage information, claims and imported labels. Explain the product, intended market, current artwork stage and printing deadline when enquiring.

This is consulting support. AFVA does not provide official label approval, and final responsibility for label compliance remains with the food business. An organised pack helps define what has been assessed and what still needs evidence; it does not turn incomplete information into a compliance guarantee.

Prepare one current pack before the next proof

Start with the actual product and the files already available. Match them by variant and version, list the gaps, and agree the review scope before the printing deadline. This makes the next question clear: what evidence or change is still needed for this exact label?

General information only: Labelling requirements depend on the food, ingredients, claims, package, intended consumers, markets and sales format. The information pack and release process above are practical recommendations, not a complete legal checklist or a prescribed MPI approval process. Confirm the requirements applying to the specific product.