Preparing for an NP2 visit? Explore AFVA’s National Programme verification service or contact AFVA about your business and verification needs. A useful starting point is to identify the records that apply to the food you actually make, handle or sell.
Quick answer
National Programme 2 requires evidence of important food safety activities, including relevant staff training and sourcing, receiving and tracing food. Other records depend on your processes, water supply and business type, or arise when something goes wrong. Keep required records for at least four years after creation, and make them accurate, complete and accessible. A large folder is less useful than a clear record that shows what happened and how you managed it.
If you are preparing for verification, the practical question is: can someone follow your records back to the activity, ingredient, product or decision they describe? This guide focuses on that preparation task for New Zealand businesses already operating under NP2. It does not decide which programme your business belongs under.
For the broader registration and verification process, read our National Programme verification guide.
What records does National Programme 2 require?
MPI’s steps for National Programme 2 explain that operators need to demonstrate how they make safe food and keep written evidence of important food safety issues. MPI updated its NP2 guidance in December 2025, including information about suitable water, allergen labelling and simulated recalls.
The December 2025 National Programme 2 guidance separates what you need to understand, what you must do and what you must demonstrate. Read the applicable sections and their sector symbols. A requirement for a manufacturer using a particular preservation process may not apply to a retailer selling sealed products.
Using MPI’s particular guidance document is not compulsory, but meeting the underlying applicable rules is. NP2 also does not automatically require a documented Food Control Plan. Optional schedules and checklists can help your team work consistently; they should not be presented as universal legal requirements.
Routine records and problem records
Use this table as a starting point, then check the relevant MPI section for your operation. It distinguishes records made as part of an activity from records triggered by a problem. It is not an exhaustive list of every sector requirement.
On a phone, swipe sideways within the table to see every column.
| Record category | When it applies | Evidence to organise |
|---|---|---|
| Staff training and competence | For relevant staff and visitors; MPI provides a sole-operator exception for training records. | Tasks, people trained, training completed and evidence they understand the task. |
| Sourcing, receiving and tracing | Relevant food and ingredient receipts, inputs and supplies to other businesses. | Supplier details, food type, quantity and receipt date; chilled receipt temperatures and links between ingredients and finished food where applicable. |
| Self-supply water | Where you use your own roof, surface or ground water supply for relevant food-business uses. | Required water test results and evidence that the supply and treatment are suitable for their use. |
| Preservation process records | Where drying, concentration, fermentation or acidification is used to keep food safe. | The method and relevant water-activity or pH evidence required by the applicable process section. |
| Sector-specific operational records | Where the guidance calls for them for your business type and activities. | Applicable maintenance, sickness, cooking or transport records. Check sector exceptions instead of copying another business’s list. |
| Problems and corrective actions | When issues affect food safety or suitability, including relevant storage, pest, packaging or foreign-matter problems. | What happened, affected food, immediate action, the decision about the food and steps to prevent recurrence. |
| Recall and simulated recall | Actual recall actions; periodic simulated recalls where required for the business’s scope. | The scenario or incident, tracing results, actions, review and improvements. Immediate-consumption-only businesses have different expectations. |
| Routine cleaning schedules | MPI’s general NP2 cleaning section treats cleaning records as optional; cleaning and sanitising duties still apply. | A practical schedule or completed record if it helps your operation. Keep evidence of problems and actions when needed. |
A problem record does not replace the activity itself. For example, you still need to control storage conditions even when the guidance only requires a written storage record when something goes wrong. Likewise, a signed training sheet cannot show competence if the person cannot explain or perform the task.
Build evidence that matches your operation
1. Start with a simple record map
AFVA recommends making a short index with the applicable topic, the person responsible and the location of its evidence. This is an organisational aid. It helps you identify missing links without creating forms for activities you do not perform.
For each topic, ask three questions: what food safety decision do we make, how do we know the control worked, and where can another person find that evidence? Put infrequent evidence, such as a service report or water result, on the index as well as daily records.
2. Connect suppliers, ingredients and finished food
Collecting invoices is a useful start, but ask whether they connect to the food you made. For a manufactured product, a practical evidence trail may run from a delivery reference to an ingredient lot, then to a production batch and the businesses that received it. Add references where your existing records need a link.
MPI’s guidance requires receiving and sourcing information and records of who food is supplied to, except direct supply to the final consumer. Detailed batch information supports targeted tracing. It does not mean you need to collect the name of every person who buys a retail snack.
3. Keep process evidence with the product it supports
Where your food relies on a preservation process, organise the applicable method and results so they can be matched to the product and relevant production. A test report with no clear product reference is difficult to use. A recipe alone may also leave unanswered questions about whether the food met the required control.
Do not choose a temperature, pH or water-activity limit from a generic internet checklist. Use the applicable MPI section and a method suitable for your food. Different products and processes need different evidence; ask for clarification if your process does not fit the guidance.
4. Close the loop when something goes wrong
An effective corrective-action record follows the issue through to its outcome. Record what food may have been affected, how it was controlled, the decision made and why, who acted, and whether the follow-up change worked. “Fixed” on its own leaves the important food safety decisions unexplained.
Do not assume that repairing a fridge answers whether the food inside was safe. These are separate questions. Follow the applicable troubleshooting and recall rules, including notification requirements where relevant, and record the actions you actually took.
5. Make the recall test useful where it applies
MPI’s simulated food recall guidance explains the requirement to test at least every 12 months after a simulated recall, or an effective genuine recall. It also distinguishes businesses selling only food for immediate consumption from mixed-scope businesses that include wholesale or packaged food.
For an applicable mock recall, retain the scenario, tracing evidence, time taken, quantities accounted for and follow-up improvements. Our practical mock food recall guide explains how to reconcile the affected batch. A rehearsal should be clearly identified so nobody mistakes it for an actual recall.
Sole operators, ECE centres and retailers
A sole operator still needs to demonstrate competence
The NP2 training section says a sole operator does not need to keep training records. The verifier still checks whether that operator can meet the rules. This exception does not remove receiving, process or other records that apply to the operation.
Early childhood centres and kΕhanga reo need their own checklist
MPI publishes specific food safety record guidance for ECE centres and kΕhanga reo. Its list includes sickness, pest problems, allergy information, cooking poultry, chilling cooked food, received or transported food temperatures, and what happened when things went wrong.
Use that sector guidance with the applicable NP2 requirements. Do not use a manufacturing checklist unchanged for a centre, or assume every centre has the same activities. If sector guidance and a general example appear to differ, confirm the requirement for your operation with your verifier or registration authority.
Retailers of manufacturer-packaged chilled or frozen food
A retailer selling sealed food does not carry out the same production controls as a manufacturer. MPI’s NP2 guide contains sector exceptions, including for some maintenance, hygiene and transport records. Match the checklist to the operation, while retaining relevant receiving, supplier, problem and other applicable evidence.
If you begin repacking, making food, wholesaling or adding another activity, check the effect on your scope before relying on your previous record list. This guide does not classify a new or changed activity as NP2.
What a useful record should contain
Under regulation 82 of the Food Regulations 2015, required records must be readable, accurate and complete, dated or versioned, and accessible to relevant people. An activity record needs the date, the time where appropriate, its results and the people who performed it.
On a phone, swipe sideways within the table to see every column.
| Field | What to write | Why it helps |
|---|---|---|
| Date and time | When the activity or issue occurred; include time where relevant. | Connects the evidence to production, a delivery or an incident. |
| Person | Identify the person who performed the activity. | Makes responsibilities and follow-up clear. |
| Food, batch or equipment | Use a reference relevant to the activity. | Shows which product, delivery or item the result concerns. |
| Result or observation | Record the actual result, including relevant units or a clear description. | Shows what was found rather than only that a box was ticked. |
| Action and food decision | For an issue, record immediate controls and what happened to affected food. | Explains the response and the basis for the decision. |
| Follow-up | Note the responsible person, completion and effectiveness of any improvement. | Helps the team establish whether the problem has been addressed. |
The extra references and follow-up fields in this table are practical recommendations; the exact information depends on the record. Keep entries factual. If a check was missed, document the gap and your response. Do not backdate a check or invent a result to fill an empty space.
Paper, digital records and four-year retention
For National Programme records required under the Act, regulation 81 requires retention for at least four years after the record is created. Keep longer if another applicable obligation requires it.
MPI permits different record formats, including electronic records and photos. Choose a system your staff can use and your verifier can follow. A photo can be useful evidence, but it needs enough context to show what it records and when. A whiteboard entry that is erased without being retained will not provide a four-year record.
- Give files clear names or references that match the activity, date and product where relevant.
- Keep current working records easy to reach, with a clear route to older records.
- Use a backup process and check that you can retrieve a saved record.
- Provide appropriate access for staff responsible for the activity; avoid relying on one person’s personal phone.
- Protect sickness and allergy information from unnecessary access while making relevant food safety information available to authorised people.
Your preparation checklist
Before the visit, work through a representative sample of your own evidence. This is AFVA’s preparation recommendation, not an additional legal audit or a guarantee of a particular verification outcome.
- Confirm your registered scope, products, activities and sites are current.
- Use the latest applicable MPI guidance and identify the sections relevant to your operation.
- Make a record index and identify who can retrieve each item.
- Follow one recent delivery through the receiving record and, where relevant, into a finished batch and customer supply.
- Check relevant training evidence and ask staff to explain the work they perform.
- Retrieve conditional evidence such as self-supply water results or preservation-process records.
- Review a problem record, including the affected-food decision and completed follow-up.
- Check applicable mock-recall evidence and identify outstanding improvements.
- Test access to both recent and older records, including a backup.
- List genuine gaps and the actions you are taking. Ask your verifier about unclear scope-specific requirements.
Common mistakes that make records difficult to verify
- Using someone else’s checklist without checking scope. It may miss your process or demand evidence you do not need.
- Calling every optional form mandatory. Separate food safety duties from helpful ways of documenting them.
- Recording only “OK”. Include the information needed to understand the activity and its result.
- Leaving a report disconnected from the product. Link relevant test, supplier and production references.
- Filing an issue without its food decision. A repair or retraining record may not explain what happened to affected food.
- Creating records only before the visit. Keep reliable evidence as work is done and deal honestly with gaps.
Frequently asked questions
Do all NP2 businesses need the same records?
No. Staff, water supply, processes, business type and incidents affect the evidence required. Use the applicable sections of MPI’s NP2 and sector guidance, including their exceptions.
Do I need a daily cleaning log under National Programme 2?
MPI’s general NP2 cleaning and sanitising section says cleaning records are not required, although schedules and records can be helpful. Cleaning and sanitising requirements still apply. Check any other requirements that apply to your operation.
Can I keep NP2 records in a spreadsheet or app?
Yes, electronic records can be used. They must remain accurate, complete, readable and accessible, with required records retained for at least four years. Make sure the system preserves entries and allows relevant evidence to be retrieved.
What should I do if a record is missing?
Identify what is missing, assess the implications for food safety and document your response. Use genuine existing evidence where available and explain its limitations. Do not recreate an unperformed check or present a later estimate as an original result.
Does a complete record folder guarantee a successful verification?
No. Verification considers what happens in the business as well as relevant evidence. Staff understanding, actual controls, facilities and responses to problems matter. Records should accurately support the work you do.
AFVA verification and preparation support
AFVA provides National Programme verification within its recognised scope and food safety audit preparation support. The appropriate service depends on your activities and needs; verification and consulting must respect professional independence.
When you contact AFVA, describe your registered programme, food activities, sites and the records you need help understanding. This helps clarify the appropriate scope of work and any independence considerations before an engagement.
Keep the next step practical
Choose one recent product or delivery and retrieve the evidence behind it. Any missing connection gives you a specific improvement to make before verification.
Official sources and review date
Sources checked on 10 October 2026. Requirements and guidance can change; use the current official material for your activities.
- MPI: steps for National Programme 2 — programme duties and the December 2025 guidance update.
- MPI: National Programme 2 Guidance, December 2025 Version 2 — applicable records, sector exceptions, training, process evidence and record formats.
- MPI: early childhood educators and kΕhanga reo — sector-specific record guidance.
- MPI: how to do a simulated food recall — frequency and immediate-consumption guidance.
- Food Regulations 2015, regulations 81 and 82 — retention, quality, content and availability.
General information only. This article does not replace the Food Act, regulations, applicable notices or MPI guidance, and does not determine your business’s programme or verification outcome. Confirm requirements for your actual activities with your verifier, registration authority or MPI where needed.
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