Food safety for ECE services (Food Act requirements)

Food Act requirements for early learning services

All early childhood education (ECE) services and kōhanga reo must make sure the food they serve children is safe and suitable to eat. Some services will have additional obligations under the Food Act 2014 (the Food Act) and the Food Regulations 2015 (the Food Regulations).

The Food Act applies to anyone who provides food as part of their business. It requires people to provide food that is safe and suitable to eat.

What it means for early learning services

Most education and care centres and kōhanga reo that provide meals and food to children will need to operate under National Programme 2.

Working with a national programme is the way that lower-risk food businesses operate under the Food Act. There are 3 levels of national programmes, which are based on the food safety risk of the activities a business does. All national programmes require:

  • record keeping to show that you’re selling safe food
  • registration of business details with your local council
  • one or more visits from a verifier recognised by MPI.

To find out if the type of food provision at your ECE centre or kōhanga reo is subject to National Programme 2, you can use the MPI Where do I fit tool.

Exempt services, i.e. those that are not required to operate under a national programme, include:

  • Home-based ECE services
  • Centre-based ECE services and kōhanga reo who undertake minimal food handling only, for example provide cut fruit, crackers and spreads, and packet biscuits
  • Where food preparation as part of the curriculum, i.e. baking and cooking done with children
  • Where food is donated or brought by families to share
  • Where children bring a lunch box

The Ministry for Primary Industries (MPI) has produced a Factsheet with examples of how the Food Act applies to education providers.

What you need to do if you are on National Programme 2

  • Make food safe. Meet food safety requirements by, for example, keeping hands and kitchen surfaces clean, keeping cooked and raw food separate, and cooking and storing food at the right temperature.
  • Select a ‘verifier’ (e.g. a council environmental health officer). A list of verifiers is available on the MPI website.
  • Register with either MPI or your local Council. Steps to follow are outlined on the MPI website. If you run several ECE centres, then you can complete a multi-site registration with MPI. If you intend to do this, contact MPI at info@mpi.govt.nz to discuss your circumstances.
  • Get checked by your chosen verifier. This may be as little as once every three years if you are managing food safety well.

MPI have developed guidance for the early learning sector so you are prepared for your verification visit.

ECE centres and kōhanga reo subject to National Programme 2 need to have a number of procedures around food preparation, cleaning procedures, storage of cleaning materials and solid waste disposal. These procedures do not need to be written down. ECE centres and kōhanga reo also need to keep a variety of records, for example staff training, managing illnesses, cooking poultry, chilling cooked food and pest control. MPI have developed guidance sheets and templates to use.

What you need to do if you are exempt

  • Make food safe. Meet food safety requirements by, for example, keeping hands and kitchen surfaces clean, keeping cooked and raw food separate, and cooking and storing food at the right temperature.
  • You don’t need to register or be verified.

When you need to do it

From 1 March 2016:
New ECE centres and kōhanga reo on National Programme 2 opening on or after this date must be registered and meeting the requirements.

By 31 March 2017:
Existing ECE centres and kōhanga reo on National Programme 2 must have applied for registration.

By 30 June 2017:
Existing ECE centres and kōhanga reo on National Programme 2 must be registered. ECE centres and Kōhanga reo then have a year from the time they register to have their first verification. 

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