Food Supplier Audits NZ: When Is a Document Review Not Enough?

A food supplier audit in New Zealand should address a defined question about the supplier and what it provides. Sometimes a current specification and a focused technical reply resolve the uncertainty. Sometimes the remaining question concerns how a control operates at a particular factory, warehouse or process.

Start with the evidence gap before commissioning a site visit. A folder of certificates is not the same as a reasoned approval decision, and an on-site audit is not a universal requirement for every supplier. Check your actual programme, product, customer and regulatory requirements.

Food supplier audits: start with the unanswered question

Write down what you are buying, from which manufacturing or handling site, and how your business will use it. An ingredient used without a further hazard-control step may raise different questions from one receiving an effective control in your operation. Do not decide the assessment method from price or supplier size alone.

Then identify the requirement or decision that needs evidence. For example: “Does the current specification describe the formulation we receive?” is different from “Are the agreed segregation controls implemented during this process?” The first may need corrected documentation; the second may need records, discussion and observation.

• Does each document identify the supplier, actual site, material and relevant activity?
• Are versions, dates and product codes consistent with what you purchase?
• What does any certificate or audit report actually cover, and what does it leave outside its scope?
• What information remains uncertain, and how could that uncertainty affect the intended use?

Where an animal-product supplier’s registration is relevant, the RMP register checking guide explains how to examine the public scope and location. A register search addresses that specific question; it does not answer every question about the material or the supplier’s current practices.

Separate requirements from possible assurance methods

The Codex General Principles of Food Hygiene, section 13.2.8 recommends procuring incoming ingredients against specifications and checking their suitability where necessary. It identifies supplier audits as potentially appropriate for some ingredients, alongside relevant inspection and testing. This is food-hygiene guidance, not a blanket New Zealand rule requiring every supplier to receive an on-site audit.

Check the specific requirements applying to your operation and material. A scheme, customer contract, product-specific import condition or your own programme may set particular evidence or assessment conditions. A general risk-based discussion does not override those conditions.

The existing packaged-food importing guide provides a product-file and label example for food from India. The decision here is narrower: what additional review, if any, is needed to resolve the supplier evidence gap?

Compare document review, remote assessment and on-site work

These methods can be combined. A document review can form part of an audit, but collecting attachments alone does not establish that an audit or assessment has been completed. The cards below are practical planning suggestions, not prescribed assessment categories.

For each option, ask what evidence it can provide and whether that evidence satisfies the applicable criteria. If it cannot, adjust the scope or obtain another appropriate form of evidence. Do not treat a cheaper method as equivalent without checking the unanswered question.

Recognise reasons to review the evidence again

The following are suggested review triggers. They do not automatically require an on-site audit; first identify what has changed and what evidence is needed.

• Product or process changes: a new ingredient, manufacturer, production site, processing arrangement or packaging may make an old assessment irrelevant.
• Conflicting records: the certificate, specification, delivery information and actual manufacturing location do not match.
• Recurring problems: repeat complaints, non-conforming deliveries or ineffective corrective actions raise questions that another generic assurance letter may not resolve.
• Unclear control ownership: a broker or distributor supplies documents, but it remains unclear who manufactures the product and maintains the relevant controls.
• New use or customer conditions: your intended use changes, or the customer now needs evidence that the existing approval did not address.

Example only: a supplier changes the manufacturing site but sends a certificate naming the previous factory. Start by clarifying the actual site, relevant scope and current evidence. If questions about implementation remain, define the controls and activities that further assessment should examine. The mismatch alone does not establish that the new factory is unsafe.

Turn the evidence into a purchasing decision

Keep a short decision record linking the question, criteria, evidence reviewed, gaps and conclusion. State who authorised the decision, which materials and sites it covers, any restrictions and what will trigger another review. This is a recommended working format, not a universal statutory approval certificate.

1. Identify which requirement or question the evidence addresses.
2. Distinguish evidence examined from information merely promised or unavailable.
3. Record unresolved items and the actions or purchasing restrictions needed under your actual programme.
4. Name the person responsible for obtaining and reviewing further evidence.
5. Check corrective-action implementation and effectiveness where relevant; keep incomplete actions visible.

An audit report, questionnaire or certificate can inform the decision without transferring the buyer’s or importer’s responsibilities to the auditor. Retain a clear route for product, process and site changes to reach the person who maintains approval.

Scope supplier audit support around the decision

AFVA’s published service includes supplier documentation review, supplier audit support, supplier approval systems, findings and recommendations, and corrective-action follow-up. Agree which work is needed rather than assuming every enquiry requires a full audit.

Send the material and supplier/site details, relevant requirements, current evidence, problem or change, and the decision you need to make. For proposed audit work, agree criteria, boundaries, suitable competence, access, report content, exclusions and follow-up. Confirm whether preparation, travel and further review are included in the quote; no standard fee or duration is stated here.

Avoid common supplier-review mistakes

• Approving by attachment count: ask what each document demonstrates about the actual supply.
• Assuming certification answers every question: check relevant scope, current status and remaining conditions.
• Booking a visit without criteria: agree what the auditor will examine and report.
• Ignoring method limitations: record what a remote session or site visit could not assess.
• Closing a gap on a promise: obtain and evaluate the missing evidence before treating it as resolved.

Frequently asked questions about food supplier audits

General information only: The evidence and assessment method depend on the actual material, supplier, site, intended use and applicable requirements. This guide is not a complete audit checklist, regulatory approval or certification decision. Information checked on 20 October 2026.