Do I Need a Food Control Plan? Quick Check for NZ Food Businesses

One of the most common questions we get from food business owners is: “Do I actually need a Food Control Plan?” The answer depends on what your business does. This guide helps you figure out which food safety requirements apply to you under the Food Act 2014.

The Three Categories

Every food business in New Zealand falls into one of three categories:

1. Food Control Plan (FCP): for higher-risk food activities
2. National Programme: for lower-risk food activities
3. Exempt: for very low-risk activities that don’t require registration

The key factor is risk. The more you do to food before selling it (cooking, processing, manufacturing), the higher the risk, and the more rigorous the food safety requirements.

You Almost Certainly Need a Food Control Plan If You…

• Run a restaurant, cafe, or bar that prepares and serves food
• Operate a takeaway or fish and chip shop
• Run a bakery that bakes on-site
• Operate a catering business
• Run a food truck or mobile food business that cooks on-site
• Operate a sushi bar or prepare ready-to-eat food
• Run a butcher shop that processes meat
• Operate an aged care kitchen or hospital kitchen (note: some operations serving vulnerable populations may need a custom FCP rather than the standard template, so check with your council)
• Run a school canteen that prepares hot food
• Manufacture food for wholesale or retail

If you’re cooking, baking, preparing, or processing food for sale, you need an FCP. There are very few exceptions for businesses that handle food at this level.

You Might Need a National Programme Instead If You…

• Only sell pre-packaged food that you didn’t make (e.g., a dairy selling chips and drinks)
• Transport food but don’t prepare or process it
• Store food in a warehouse
• Sell whole fruit and vegetables without processing them

Not sure which applies? We’ve written a full comparison of Food Control Plans vs National Programmes that breaks down the differences in detail. Your local council can also advise.

You’re Probably Exempt If You…

• Sell food at a fundraiser or one-off community event (specific conditions apply)
• Grow and sell unprocessed horticultural products directly from your property
• Make food only for personal or family consumption

Exemptions are narrow. If you’re selling food to the public on any regular basis, you almost certainly need to be registered under either an FCP or a National Programme.

Common Scenarios

”I run a food truck”

You need a Food Control Plan. Food trucks that cook and serve food are treated the same as restaurants. The fact that you’re mobile doesn’t change the food safety requirements.

”I sell baking at the local market”

If you’re baking at home and selling at a market, you likely need an FCP. Home-based food businesses that prepare higher-risk food for sale are covered by the Food Act 2014. Talk to your local council about registration.

”I make and sell sauces/jams/preserves”

Manufacturing food products for sale requires an FCP. If you’re bottling, canning, or packaging food for retail, you need a plan that covers your production process. Depending on the complexity, you might need a custom FCP rather than the standard template.

”I’m a personal chef or meal prep service”

If you’re preparing food for others and selling it, you need an FCP. Meal prep services where you cook food and deliver it to customers are treated as food businesses.

”I only sell coffee”

If you only sell espresso-based drinks and don’t prepare food, you may fall under a National Programme rather than a full FCP. But if you sell cabinet food, baked goods, or anything that requires temperature control, you’ll likely need an FCP. Check with your council.

”I run a dairy/convenience store”

If you only sell pre-packaged food and drinks, a National Programme may be sufficient. If you have a hot food cabinet, make sandwiches, or do any food preparation, you’ll need an FCP.

”I’m a food manufacturer or processor”

You need a Food Control Plan. If your operation is complex (multiple product lines, specialist processes, export), you’ll likely need a custom FCP rather than the standard template. Custom FCPs must be evaluated by an MPI-recognised evaluator before registration.

”I run a catering business from home”

Same as any other catering business. You need an FCP. Operating from home doesn’t exempt you. You’ll also need to check with your local council about any resource consent or zoning requirements for running a food business from a residential property.

Template FCP vs Custom FCP

If you do need a Food Control Plan, the next question is which type:

Template FCP (Simply Safe and Suitable): Suitable for most businesses that prepare food for direct sale to consumers, including restaurants, cafes, takeaways, bakeries, caterers, and food trucks. MPI provides the template, and you customise it to your operation. Read our guide to template FCPs for more detail.

Custom FCP: Required for more complex operations that don’t fit the template, such as food manufacturers, processors, businesses with specialist processes (e.g., sous vide, smoking, curing), and exporters. These are written specifically for your operation. We provide custom FCP systems for businesses that need them.

How to Get Started

1. Figure out what you need. Use this guide or MPI’s online tool to determine whether you need an FCP or National Programme.
2. Register with your local council. Your council is your registration authority. Contact them to start the process.
3. Set up your plan. If you need a template FCP, our setup guide walks you through it step by step.
4. Start recording. From day one, your records need to be consistent and complete. This is what your verifier will check.

Going Digital

If you’re setting up a new Food Control Plan, it’s worth considering whether to go paper or digital from the start. Paper works, but it creates problems down the line: lost forms, illegible handwriting, and the scramble to organise records before a verification visit.

Template FCP App is the digital FCP platform we built for New Zealand food businesses. It gives your team guided daily checks on their phones, automatic timestamps on every record, and audit-ready PDF exports. If you’re starting fresh, starting digital means you never have to deal with paper records at all.

30-day free trial. No payment required.