National Programme 3 NZ: Requirements, Records and Verification

National Programme 3 (NP3) sets food safety requirements for specified medium-risk activities under New Zealand’s Food Act 2014. An NP3 business needs the correct registration, suitable day-to-day controls, required records and independent verification.

NP3 is the highest of the three National Programme levels. That does not make it the correct pathway for every manufacturer, drink producer or retailer. Assess the complete products, processes, locations and sales model before deciding which measure applies.

What is National Programme 3?

The National Programmes are risk-based requirements for specified food activities. NP1, NP2 and NP3 have different scopes and verification arrangements. The level follows the activities; a business cannot choose a lower level simply because its paperwork looks easier.

For activities fully covered by NP3, the operator follows the National Programme requirements rather than writing a custom Food Control Plan for evaluation. The business still needs workable procedures, competent people and evidence of compliance. Other activities can require a different measure.

MPI updated its NP3 guidance in December 2025. Using that particular booklet is optional; following the applicable legal requirements is compulsory. If you use the booklet, make the relevant instructions available to staff and explain changes. Start with MPI’s current NP3 steps and guidance.

For the wider comparison, see our National Programme verification guide covering NP1, NP2 and NP3.

Which activities may need NP3?

MPI’s examples include the following activities, subject to the complete operation and any exclusions or additional requirements:

• Processing grain, herbs or spices.
• Retail handling without preparation or manufacture, such as reheating manufactured pies or scooping ice cream.
• Manufacturing oils or fats for human consumption.
• Manufacturing food additives, processing aids, vitamins, minerals or other nutrients intended for addition to food.
• Manufacturing dry mix powders.
• Manufacturing alcoholic or non-alcoholic drinks.

These are starting points, not a complete classification tool. Extra preparation, animal-product processing, importing, exporting or mixed activities may change the answer. A home kitchen, warehouse or shop address alone does not determine the programme.

Confirm the whole operation

1. List each product group, ingredient type, process and packaging step.
2. Describe storage conditions, shelf life, customers and whether sales are wholesale, retail, online or mobile.
3. Identify every site and any separately regulated importing, exporting or animal-product activity.
4. Use MPI’s My Food Rules tool with the actual scope. Resolve an unclear result with MPI or the registration authority.

Keep the classification outcome and review it when activities change. Our Food Control Plan versus National Programme guide explains the main distinctions.

Main National Programme 3 NZ requirements

Controls must suit the actual operation. The following areas explain what to organise; they do not replace the complete requirements applying to the business.

Sourcing and receiving food

Take reasonable steps to assess incoming food as safe and suitable. Keep supplier and received-product information, relevant temperature checks and action taken when food is unsuitable or received at the wrong required temperature. A business’s assessed-supplier list does not mean every supplier has government approval.

Premises, equipment, hygiene and water

Provide suitable space, equipment and capacity for hygienic operation. Maintain surfaces and equipment, control pests and waste, and separate chemicals from food. Staff need appropriate personal hygiene and illness arrangements. Water used where it can affect food safety must meet the applicable supply, protection and assessment requirements; self-supply needs particular attention.

Processes and monitoring

Identify the controls applicable to the product and process, including relevant time, temperature, storage, formulation or other specified criteria. The Food Notice for Food Control Plans and National Programmes contains water and National Programme process requirements. A different process or alternative control can require a different regulatory pathway or specific approval; an operator’s own validation does not automatically authorise an alternative NP method.

People and competence

Identify and record the skills needed by the day-to-day manager and people doing tasks that affect food safety. Keep appropriate evidence that those skills are achieved and maintained. Task instruction, demonstration and checks should show that staff can carry out the controls and respond to a failure. A course attendance record alone does not demonstrate practical competence.

MPI’s NP3 guidance explains that a sole operator does not need to keep training records; the verifier checks that they can meet the rules. This concerns training records, while the operator still needs to understand and demonstrate the applicable food safety controls.

Allergens and consumer information

Keep supplier information, ingredients, recipes and consumer information aligned. Labelling and allergen duties depend on the product and how it is sold. Food exempt from carrying a complete label can still need allergen information. Check FSANZ’s current allergen-labelling guidance for the applicable declarations; a voluntary “may contain” statement does not replace required declarations or contamination controls.

Operator checks and corrective action

Regularly check the operation rather than waiting for the verifier’s visit. If control is lost, identify the affected food and extent of the problem, prevent unsafe or unsuitable food being sold, restore control and address the cause. Record decisions, product disposition and action to prevent recurrence. Keep any required incident or recall notifications separate from routine corrective-action notes.

What records does an NP3 business need?

Keep records required under the Food Act for at least four years from creation. They must be legible, accurate, complete and readily accessible to the relevant people. Identify the date or version as applicable; activity records need the date, time where appropriate, results and who carried out the activity. See regulations 81–82 of the Food Regulations 2015.

The examples below combine required information with practical ways of organising it. They are not seven prescribed forms or a requirement to collect every retail customer’s identity. Use records appropriate to the activities, and keep any additional evidence needed by the applicable rules.

Electronic records or suitable customised templates can work. Check access, backups, version control and retrieval. Do not fill a missed check with an invented result; investigate the gap and document what can actually be established.

How to register and keep the scope current

1. Confirm NP3 and its complete scope. Describe the products, processes, places and sales activities accurately.
2. Choose a suitable recognised verifier before applying. Check that the verifier covers the actual NP3 activities, availability and independence requirements. Obtain their confirmation letter and include it with the registration application.
3. Choose the correct authority. A business based in one council district, or a mobile or online business, registers with the council where it is based. For fixed sites in more than one council area, the options include separate local registrations or collective registration with MPI.
4. Use the authority’s current application process. Supply the scope, operator and site information, verifier letter and any other required documents and fee. MPI forms are for MPI applications; obtain the relevant council form for a council application.
5. Check and maintain the registration. Confirm names, activities, sites and programme level, and track the two-year renewal date separately from verification dates.

Use MPI’s NP3 registration steps and the appropriate authority’s current forms and fees. Our food-business registration process provides a practical overview.

Keep the authority informed when the operator, activities, sites or verification agency change. Check the MPI guidance on managing National Programme changes and notify significant changes as required, rather than waiting for renewal. Reassess the pathway before assuming a new process is covered by the existing NP3 registration.

When is NP3 verification due?

Verification checks whether the registered business follows its requirements and produces safe and suitable food. The verifier compares practices, staff explanations, records and the actual scope. Registration, verification and registration renewal are separate actions.

Under regulations 91 and 94, an acceptable initial NP3 verification places the business at step 6, a two-year routine interval. An unacceptable outcome increases frequency after the relevant criteria are considered; later acceptable outcomes can reduce it within the framework. Do not assume a fixed annual visit or that renewal automatically sets the next verification date. The NP3 verification rules in the Food Regulations govern these intervals.

A new business seeking an extension must apply in writing to the registration authority no later than two weeks before verification is due and give reasons. Approval depends on the circumstances; the maximum extension is six weeks beyond the original due date. Continue working to the original deadline until the authority confirms an extension. MPI’s NP3 verification steps explain the application process.

Prepare for discussion of scope changes, people, premises, receiving, process controls, consumer information, traceability and previous corrective actions. AFVA’s food-business verification process explains the visit and follow-up.

Traceability, recall and mock-recall requirements

Traceability needs to connect incoming food with its movement within the business and the next supply-chain recipient. The requirement to identify the recipient excludes the final consumer; it does not require a name for every walk-in retail purchaser. Information requested by the Chief Executive or a food safety officer must be supplied in an accessible format within 24 hours, or within a reasonable shorter period they specify, under regulation 71.

MPI’s NP3 guidance also calls for testing the tracing system at least once a year. Where a simulated recall applies, the same exercise can test both tracing and recall.

Where recall procedures apply, test them with a simulated recall at least every 12 months. An effective genuine recall can meet that interval when it demonstrated that the traceability and recall procedures worked. It does not automatically count merely because an incident occurred.

MPI’s simulated food-recall guidance explains the immediate-consumption-only foodservice qualification. These businesses still need to act on recalled ingredients. A mixed operation that also supplies wholesale or packaged food needs recall procedures and simulated recalls; do not assume the whole business is exempt because one activity is food service.

• Choose a realistic scenario and identify the affected products and lots.
• Trace suppliers, internal movements, stock and relevant recipients.
• Account for quantities and record how long the exercise took.
• Prepare draft communications clearly marked as a simulation; MPI does not require them to be sent to customers or the public.
• Review gaps, assign corrective action and retain the evidence.

For an actual problem, first control the affected food and assess the situation. A decision to recall triggers notification to MPI as soon as practicable and no later than 24 hours after that decision. An NP breach that results in food that is, or may be, unsafe or unsuitable and could adversely or injuriously affect human life or public health must also be reported to the verifier or verification agency as soon as practicable. These are different triggers under regulations 72 and 80; do not treat the 24-hour outer limit as a reason to wait.

How to prepare for NP3 verification

1. Confirm that the certificate, sites and current activities agree.
2. Check applicable requirements against the operation, including the current MPI guidance where used.
3. Gather required records across a representative period and explain any gaps.
4. Trace a recent product or batch from receipt through handling and supply.
5. Review the latest recall exercise or effective genuine recall, where applicable, and close gaps.
6. Check current ingredients, allergen information and product labels or other consumer information.
7. Check measuring equipment, maintenance, cleaning, water and pest-control evidence as applicable.
8. Ask staff to explain their tasks, checks and actions when control is lost.
9. Bring previous findings and evidence of effective correction.
10. Confirm the visit date and keep both verification and renewal reminders.

Common NP3 mistakes to check before verification

• Scope drift: new products, sites or processes have not been assessed against the registration.
• Unreliable records: forms contain unexplained gaps, results entered retrospectively or no identification of who checked.
• Disconnected information: ingredients, recipe changes, lots and consumer information cannot be connected.
• Incomplete correction: a failed check is recorded without a product decision or effective follow-up.
• Unclear recall evidence: an exercise fails to reconcile stock and supply, or its gaps remain open.
• Weak task understanding: staff can find a procedure but cannot demonstrate the required control.

Use these prompts to check evidence before the visit and assign any follow-up to a named person.

Request NP3 verification or preparation support

Start with the decision you need to make: obtaining verifier confirmation for registration, arranging a due verification, or getting help with a specific preparation gap. AFVA's National Programme verification service includes NP3 verification and preparation support, subject to the appropriate recognised scope and independence arrangements.

Before applying for NP3 registration

Describe the actual products, processes, premises and sales activities. Ask whether AFVA can verify that scope and provide the confirmation needed for your registration application. Confirm availability and the engagement before relying on a proposed opening date. The registration authority handles registration; a verifier's letter does not register the business.

When verification is approaching

Provide the current registration, latest verification report, open findings and next due date. Identify changes since the previous visit and the staff member who can explain the operation. Ask for a written quote explaining the work included, reporting, travel, GST and any follow-up charges. These enquiry details are AFVA's practical preparation recommendations, not an additional prescribed NP3 form.

When you need preparation or corrective-action support

Identify the particular record, process or finding you need help understanding and send the relevant evidence. Ask for that advisory work to be scoped separately from independent verification. Disclose previous plan-development or consulting work so the appropriate role and any independence limits can be checked. Advice or a complete record folder does not guarantee a verification outcome.

Keep the NP3 scope, practices and evidence aligned

Start with the correct pathway and build records around the work actually done. Keep required checks, staff knowledge, traceability, corrective action and due dates aligned with the registered operation. Review changes before relying on the previous scope.

Reviewed 20 October 2026 against current official guidance and applicable legislation. General information only: Requirements depend on the complete food activities, products, processes, locations and sales model. Confirm the requirements and dates applying to the specific business before relying on a classification, timeframe or record list.