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On this page:
- Requirements for all manufacturers and millers
- Products covered by both Acts
- Additional requirements for pet food manufacturers under the APA
- If you render animal products
- Your pet food product could be a veterinary medicine
- Who to contact
Requirements for all manufacturers and millers
All animal feeds – including pet food, nutritional supplements, and milled feeds – are subject to regulation under the Agricultural Compounds and Veterinary Medicines (ACVM) Act 1997 as oral nutritional compounds.
If you make any of these kinds of products, they are:
- likely to be exempt from registration under the ACVM Act, but
- must meet the requirements for oral nutritional compounds set out in ACVM Regulations.
ACVMs exempt from registration
The ACVM regulations require you to:
- make sure your product is fit for purpose (regulation 7)
- have a documented system for manufacturing, and you follow the system and keep adequate records (regulations 9 and 14)
- provide specified information on the product label (regulation 12)
- meet the specific requirements for oral nutritional compounds listed in Schedule 2, Part B, entry 22
- not make misleading statements about your product – particularly therapeutic claims (regulation 13).
Products covered by 2 acts
If the oral nutritional compound you manufacture contains animal material, you will need to meet the requirements of both the ACVM Act and the Animal Products Act (APA) 1999.
Our guide can help you identify what legislation applies to you.
Guidance: making food for animals [PDF, 267 KB]
If you already have a risk management programme (RMP) under the APA you can use this for the documented system for manufacturing required by regulation 9, as long as it also covers the oral nutritional compound requirements under the ACVM Act.
Additional requirements for pet food manufacturers under the APA
The requirements you have to meet as a pet food manufacturer depend on what kind of processor you are.
- Primary pet food processors slaughter and dress animals.
- Secondary pet food processors process animals after slaughter and dressing.
Primary pet food processors
If you slaughter and dress animals, and also make pet food, you must comply with the APA – including operating under an RMP.
Find out about risk management programmes
You must also meet the requirements in the:
- animal products regulations, and
- Animal Product Notice: Production, Supply and Processing
Animal Products Regulations 2021
Animal Product Notice: Production, Supply and Processing [PDF, 2.6 MB]
Find help in the operational code
The operational code for pet food processing is designed to help pet food processors and manufacturers meet the requirements of the APA.
Operational code: Pet food processing [PDF, 1.6 MB]
Make sure slaughtered animals are suitable for pet food
Slaughtered animals must have a post-mortem examination to make sure they're suitable to be used in pet food. Our post-mortem tables show how to do this. Refer to Schedule 1 of the Animal Product Notice: Production, Supply and Processing [PDF, 2.6 MB]
Secondary pet food processors
If you're a pet food manufacturer who doesn't slaughter or dress animals, your legal requirements depend on whether you are:
- a manufacturer of pet food that requires official assurances for export – you're required to operate under an RMP
- a "further" pet food processor required to list with the Ministry for Primary Industries (MPI) – you use animal product that has resulted from the death of the source animal, such as meat, or
- a secondary pet food processor who doesn't need to list with MPI – the only animal products you use are not obtained through the death of the source animal (such as eggs and dairy).
If you make pet food for export
There are additional steps you need to follow if you make pet food for export.
Find out more about exporting pet food
Note: There are no ACVM legal requirements for export-only oral nutritional compounds, but you must keep them separate from products that will be sold in New Zealand.
If you're a further pet food processor
In addition to the ACVM Act requirements, under the APA further pet food processors must:
- have a documented tracking system to show you meet requirements
- only get animal material from regulated sources
- comply with the relevant parts of the animal consumption specifications (unless you're exempt), and
- be listed with MPI.
Part 7, Subpart 3 – Further petfood processing of the Animal Product Regulations 2021
Tracking system template and guidance
To help you with your tracking system, we've developed a template and guidance document. (The template is available in PDF and Word formats).
Tracking system template for further pet food processors [PDF, 352 KB]
Tracking system template for further pet food processors [DOC, 318 KB]
Guidance document: Tracking system template for further pet food processors [PDF, 234 KB]
Listing your operation with MPI
You're required to provide MPI with the details of your processing operations so we can add you to our list of further processors.
Complete and return form AP61 to apply to be listed.
Application form AP61 – Further (pet food) processors listing [PDF, 295 KB]
If you're a secondary pet food processor not required to list with MPI
If you make pet food and you only use animal products that are not obtained through the death of the source animal (for example, eggs or dairy products), then you don't have to register or list under the APA.
You do still need to meet the relevant ACVM Act requirements for oral nutritional compounds.
If you render animal products
If you render animal products for consumption by animals, different requirements will apply.
Find out about rendering business requirements
Your pet food product could require registration
A pet food could no longer be just an oral nutritional compound if you:
- make claims about your product that aren't just nutritional claims (for example, "this product can help manage arthritis")
- include levels of nutrients above those necessary for the maintenance of health
- include substances that aren't nutrients, feed additives (such as flavours and preservatives) or substances described in one of the other ACVM regulations Schedule 2 entries.
If any of these apply your product might need to be registered under the ACVM Act.
Find out more about veterinary medicines and the ACVM Act 1997
Who to contact
If you have questions about pet food, animal feed, and nutritional supplements, email info@mpi.govt.nz
