Under the Food Act 2014, schools may now be required to register as a national programme or to register a food control plan if they sell food. Schools were given until 30 June 2018 to meet the requirements – but if you've missed the deadline, there's no need to eat humble pie. We're sure you've had a lot on your plate! If you don't know beans about what you need to do, just read our explanation below. It'll give you food for thought.
First things first, all food provided by schools, whether it's sold or not, must meet food safety guidelines. Food must be safe to eat and have been prepared in a hygienic environment.
If schools sell food, they may also be required to register as a national programme or to register a food control plan. Note that food for sale includes food provided as part of the service of paid breakfast, after-school, and holiday programmes. However, if the food is provided to students by an external agency, it's their responsibility to register under the Act.
Food is divided into three types:
§ If you sell pre-packaged shelf-stable food bought from another company, you don't need to register but you must ensure that the food is safe and suitable.
§ If you sell reheated, chilled, frozen, or repackaged food, you need to register as a national programme.
§ If you sell your own prepared or cooked food you need to register a food control plan.
Selling food as part of a fundraising activity is different, as the requirement to register depends not only on the type of food, but how many times you've tried to sell food:
§ Pre-packaged shelf-stable food does not require registration, e.g. confectionery sales.
§ Reheated, chilled, frozen, and repackaged food, or food prepared or cooked at home or at the school (e.g. for bake sales or sausage sizzles) can be sold up to twenty times per year without registration.
To be clear, the calculation of 'twenty times per year' relates to the organising body of the activity. If some fundraising activities are organised centrally by the school and others are organised by individuals or groups, then each organising body can fundraise without registration up to twenty times. If an organising body sells food as part of a fundraising activity more than twenty times a year, they need to register under a food control plan or a national programme, depending on the type of food sold.
For more information see Education NZ's helpful links and guidelines, and for details about what to do if you need to register as a national programme or register a food control plan, see the Ministry for Primary Industries' Food Act page, which will link you to guidance tools and templates. Schools that need further help with the registration process are advised to contact their local council for support or email the Ministry for Primary Industries at firstname.lastname@example.org.