Food Control Plan vs National Programme: Which One Does Your NZ Business Need?
The difference between a Food Control Plan and a National Programme under Food Act 2014. How to figure out which applies to your food business in New Zealand.
Food Control Plan or National Programme? Under the Food Act 2014, every food business in New Zealand falls into one of these two categories (or is exempt entirely). They have different documentation, different verification schedules, and different costs, but figuring out which one applies to you is simpler than it looks.
The Quick Answer
- Food Control Plan: For businesses that prepare, cook, manufacture, or process food. Higher risk = more documentation and more frequent verification.
- National Programme: For businesses that handle food in simpler, lower-risk ways. Less documentation, less frequent checks.
If you’re cooking food and selling it to people, you almost certainly need a Food Control Plan.
Food Control Plan (FCP)
A Food Control Plan is a detailed written document that describes how your business keeps food safe. It covers your procedures for receiving, storing, preparing, cooking, and serving food, plus what you do when something goes wrong.
Who Needs an FCP
- Restaurants, cafes, and bars that serve food
- Takeaway shops and fish and chip shops
- Bakeries that bake on-site
- Caterers and event food providers
- Food trucks and mobile food businesses
- Sushi bars and ready-to-eat food preparers
- Butcher shops that process meat
- Food manufacturers and processors
- Aged care kitchens, hospital kitchens, school canteens (where food is cooked)
What’s Involved
- Detailed written plan based on HACCP principles (usually using MPI’s Simply Safe and Suitable template)
- Daily records: Temperature logs, cleaning records, corrective actions
- Regular verification visits by an MPI-recognised verifier
- Staff training records documenting food safety training
- Supplier records and traceability documentation
- Annual mock recall to demonstrate traceability
Cost
You pay for registration with your local council plus verification visits. Verification frequency depends on your risk profile and compliance history. An unacceptable outcome increases your frequency (and costs).
National Programme
A National Programme is a simpler food safety framework for lower-risk food businesses. Instead of a detailed written plan with daily records, businesses follow a set of minimum requirements based on their risk level.
Who Uses a National Programme
- Dairies and convenience stores that only sell pre-packaged food
- Transport companies that move food without processing it
- Food warehouses and storage facilities
- Fruit and vegetable retailers selling whole, unprocessed produce
- Businesses selling shelf-stable pre-packaged products
National Programme Levels
National Programmes have three levels based on risk:
Level 1 (Lowest Risk)
- Selling pre-packaged, shelf-stable food only
- Minimal food handling
- Example: A shop selling only packaged snacks and drinks
Level 2 (Moderate Risk)
- Some food handling involved but no cooking
- Example: A deli slicing pre-cooked meats, a bakery selling pre-made goods
Level 3 (Higher Risk)
- More food handling, but still within defined boundaries
- Example: Businesses doing limited food preparation
What’s Involved
- Following the food safety requirements specified for your level
- Keeping basic records
- Less frequent verification than FCP businesses
- Lower compliance costs overall
Side-by-Side Comparison
| Food Control Plan | National Programme | |
|---|---|---|
| Risk level | Higher | Lower |
| Who | Restaurants, cafes, caterers, manufacturers, anyone cooking/processing food | Pre-packaged sellers, transport, storage, simple retail |
| Documentation | Detailed written plan with daily records | Follow minimum requirements for your level |
| Daily recording | Yes: temperatures, cleaning, corrective actions | Basic record-keeping |
| Verification frequency | More frequent (annually or more) | Less frequent |
| Cost | Higher (more verification, more documentation) | Lower |
| Template available | Yes, Simply Safe and Suitable (SSS) | Requirements set by MPI for each level |
| Corrective actions | Formal recording required | Less formal |
| Staff training records | Yes, documented | Less detailed requirements |
| Mock recall | Required annually | May not be required depending on level |
”What If I Do Both?”
Some businesses straddle the line. For example, a convenience store that mostly sells pre-packaged food but also makes fresh sandwiches and heated pies. In these cases, the higher-risk activity determines your requirement. If you’re preparing food, you need an FCP.
The rule of thumb: the highest-risk activity in your operation determines which plan you need. If any part of your business involves cooking, preparing, or manufacturing food, you need a Food Control Plan for the whole operation.
How to Find Out Which One You Need
- Check MPI’s online tool: MPI has a Food Safety Rules tool that walks you through a series of questions about your business and tells you which plan applies.
- Contact your local council: Your council is your registration authority. They deal with this question every day and can advise you directly.
- Ask yourself: Am I cooking, preparing, or processing food? If yes, you need an FCP.
Already Know You Need an FCP?
If you’ve determined you need a Food Control Plan, here’s where to go next:
- Setting up a template FCP: Read our step-by-step setup guide
- Understanding the SSS template: See our template FCP guide
- Getting record blanks: See our 2026 record blanks guide
- Auckland businesses: See our Auckland FCP registration guide
- Need a custom FCP: If your operation doesn’t fit the template (manufacturing, specialist processes, export), we provide custom FCP systems
If you’ve confirmed you need an FCP and want to skip paper from day one, Template FCP App handles the daily recording side digitally. Have a look. It’s free to try.