Food Packaging Suitability NZ: Check the Food-Contact Evidence

Food packaging suitability in NZ depends on the actual food, material and conditions of use. A tub, liner, pouch or closure described as “food grade” still needs to suit your filling process, storage, distribution and intended consumer use.

This guide is for manufacturers, food brands and quality teams assessing supplier evidence before buying or changing food-contact materials. It focuses on whether the evidence matches the application, rather than choosing a packaging atmosphere or designing printed labels.

Food packaging suitability in NZ: define the duty

MPI’s food packaging rules and guidance says packaging must be fit for purpose, clean, intact and suitable for the food, conditions of use and shelf life. It must protect food and avoid becoming a source of contamination. The page expressly identifies Food Act, Animal Products Act and Wine Act pathways; check the requirements applying to your operation.

For Food Act operators, regulation 25 of the Food Regulations 2015 applies within the food control plan provisions, while regulation 70 for National Programme operators contains the corresponding packaging duty. Both require food-related accessories to maintain food safety and suitability to the extent of their intended use, and not create or contribute to hazards.

The document checks below are practical recommendations for demonstrating that the proposed use has been considered. They are not a prescribed universal certificate, mandatory test panel or approval by a regulator. MPI also identifies Standard 3.2.2 as Australia-only; it should not be presented as New Zealand packaging law.

Describe the exact food and intended use

Give the supplier a written intended-use profile. “For food” is too broad to establish whether the proposed material and your process match. Include the conditions before filling, while the food is in contact with the material, through distribution, and during the use you intend to describe on the product.

• Food: the product and recipe version, relevant acidity, fat content and other characteristics that may affect the food–material interaction. Give measured or specified values where available; identify estimates.
• Pack: the supplier, product code, material specification and version, size, food-contact surfaces, liner or coating, closure and any other component included in the proposal.
• Process: filling conditions, any heating or cooling while packed, freezing, sealing and other treatment the complete pack will experience. State the temperature and duration being proposed, rather than assuming that “hot fill” is sufficiently precise.
• Contact and storage: intended contact time, proposed shelf life and the storage and transport conditions the evidence needs to cover.
• Use: whether consumers will heat, microwave, reclose or reuse the pack, and the instructions you intend to give.

MPI recommends following the manufacturer’s instructions for use and storage. It says single-use packaging should not be reused; packaging intended for reuse needs to be designed for that purpose and capable of proper cleaning and sanitising. Being physically robust does not establish that a container is suitable for repeated food contact.

If the project also changes vacuum or modified atmosphere packaging, use the separate vacuum packaging and MAP change-review guide for that process decision. Material suitability remains one part of the complete product assessment.

Check what the supplier evidence actually covers

Ask the supplier for documentation or assurance that can be connected to your exact proposed purchase. A useful response identifies the material covered, the intended food-contact uses, conditions and restrictions, and the technical basis for the assurance. Ask for clarification where a distributor’s description cannot be linked to the manufacturer’s specification.

Match identity, conditions and conclusion

Read the scope before the conclusion. Does a report concern the same film structure, coating, colour, closure or finished article? If it concerns a related material or a family of products, ask the supplier to explain why it covers the version offered to you. Keep that explanation with the document.

Next compare the stated contact conditions with your intended-use profile. Evidence for cold storage does not itself answer a hot-filling question. A statement for one food type, contact duration or use cannot simply be assumed to cover another. Where a report uses test conditions rather than your actual food, ask a competent reviewer to explain their relevance and limitations.

Overseas standards or certificates may form part of the evidence supplied. Record the exact reference and scope, then assess what it demonstrates for your New Zealand application. A familiar acronym or a certificate heading does not explain whether your particular material and conditions are covered.

Keep chemical suitability and pack performance separate

Food-contact chemical evidence and physical pack performance answer different questions. Relevant supplier information may address the transfer of substances into food; other information may concern seals, strength, barrier properties or handling. An acceptable-looking pack does not establish chemical suitability, and chemical evidence alone does not establish that a seal or closure will protect the product through its intended life.

Worked example: a packaging evidence decision

The following is an illustrative purchasing record, not a real AFVA client case or an approved process. A business proposes changing the tub for an acidic sauce, with warm filling and chilled storage. Its supplier has provided a statement describing cold-food use, without explaining the proposed filling exposure. The appropriate result is an explicit question and hold on the purchasing decision, rather than silently expanding the statement’s scope.

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Make the record usable by purchasing and production staff. It should make clear which item can be ordered or used, which conditions apply, and which proposal is still awaiting evidence. An unresolved question should not disappear when a trial sample arrives.

Resolve gaps before ordering tests

First identify the missing conclusion. Is the problem that the material is unidentified, the supplier’s use conditions are unclear, an existing report needs interpretation, or there is no evidence for a particular proposed use? Those are different gaps and may require different responses.

Ask for the missing supplier information before commissioning a broad test package. If further testing is appropriate, agree the question, relevant material and food-contact conditions, suitable methods and interpretation with a competent packaging specialist and an appropriate laboratory. There is no single migration panel or routine food test that answers every packaging-suitability question.

The broader food testing guide explains why the purpose, sample identity and decision should be defined before analysis. Where laboratory analysis is needed, it is performed by an appropriate external laboratory; do not assume AFVA is the laboratory or that a test report gives regulatory approval.

Keep technical conclusions bounded by the conditions actually assessed. An absence of visible damage or an acceptable taste and appearance during a short trial should not be treated as evidence for every chemical, safety or shelf-life question.

Control the approved material and later changes

After the evidence supports a decision, retain the exact specification and its permitted use with the supplier correspondence, reports and review record. We recommend naming an owner for approval, purchasing controls and later reassessment. Ask how the supplier will communicate changes that could affect the evidence.

MPI advises regular review of packaging requirements. It also explains that a change of material may affect shelf life and may require checking that the stated use-by date remains supported by testing or other technical information. A more sustainable material still needs the food-safety and suitability assessment; neither an unchanged recipe nor an environmental claim establishes equivalence.

Consider the complete change, including the closure, storage instructions, packing equipment and handling. Follow the amendment requirements of the business’s applicable plan or programme where relevant. This article does not determine whether a particular proposal is a significant amendment.

Protect packaging after receipt. MPI recommends appropriate storage away from pests, dust and chemicals, and using clean, undamaged packaging. Supplier assurance does not replace those day-to-day controls.

Before-purchase checklist

1. Describe the exact food, pack components and all proposed contact conditions.
2. Obtain identifiable supplier assurance, specifications and relevant supporting information.
3. Compare document scope, versions, food types and conditions with the intended use.
4. Record restrictions, missing information and the person responsible for resolving each gap.
5. Agree any necessary specialist assessment, trial or testing before committing to a conclusion.
6. Review shelf-life, instructions and applicable plan-change implications.
7. Record the final decision, approved version and conditions; make them available to purchasing and production.

Common mistakes

• Filing “food grade” without its scope: ask what material, food and conditions the description covers.
• Reviewing only the tub: include the lid, liner, coating and other relevant components of the proposed pack.
• Treating a successful trial as complete evidence: distinguish appearance, seal performance, chemical suitability and shelf-life questions.
• Changing the item after review: compare the actual purchase specification with the approved version and assess substitutions.
• Using an overseas reference as the whole answer: establish its relevance to the actual material, use and applicable New Zealand requirements.

Prepare a focused AFVA enquiry

AFVA’s product-development support includes packaging and storage review. Its food safety and quality consulting service also covers specifications, supplier controls, procedures and records. These services can help organise the information and practical next steps for an evidence-gap review; the engagement scope should be agreed for the actual project.

Send the exact material specification, food description, process flow and intended contact conditions, proposed storage and shelf life, supplier documents and the decision still open. Identify which figures are proposed and which are supported by existing evidence.

Consulting support does not replace registration, recognised evaluation or verification. Any regulated engagement is subject to the applicable recognition, scope and independence requirements.

General information only: Requirements depend on the complete food activities, products, processes, packaging, locations and sales model. Use current official guidance and obtain product-specific technical advice before relying on packaging evidence, changing a process or releasing food. This article is not a material approval, process specification or shelf-life validation.