Environment

These sections outline New Zealand's approach to sustainable use of its vast marine environment.

Supply Chain

These sections outline New Zealand's approach to ensuring supply chain integrity within the seafood industry.

People

These sections outline New Zealand's approach to the welfare of workers and indigenous communities involved in seafood production.

Traceability.

New Zealand's traceability requirements allow for the identification and tracking of product as it moves along the supply chain.
While the primary purpose of traceability in New Zealand is to ensure that an effective recall can be undertaken quickly and effectively, it also provides seafood businesses with a level of transparency and integrity.
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ALL SEAFOOD OPERATORS ARE REQUIRED BY LAW TO IDENTIFY AND TRACK PRODUCTS ON AT LEAST A 'ONE STEP FORWARD, ONE STEP BACK' BASIS.
The New Zealand Government recently revised its food safety and traceability requirements through the passing of the Food Act 2014. The Food Act came into force on 1 March 2016. It applies to all new food businesses from that date but existing food businesses will transition between 2016 and 2019.
The New Zealand Seafood Standards Council and the Ministry for Primary Industries have jointly developed a Code of Practice for the Processing of Seafood Products. The code includes guidance to assist seafood businesses to implement effective traceability systems in line with the regulatory requirements.
This section provides an overview of New Zealand's legal requirements for seafood traceability. More information on industry codes of practice and associated food safety legislation can be found by clicking on the Related Sections, Deeper Reading or downloable PDF features.

For seafood, traceability requirements apply from the point of harvest or catch through to retail sale (if consumed in New Zealand) or to the point of export. This means traceability of seafood in New Zealand can extend from sea to plate.

As part of food safety requirements, businesses are required to have systems that allow product to be identified and tracked on a one step backwards and one step forward basis. There are also specific regulatory requirements for inventory control and recalls. For seafood processing activities, this extends to being able to identify the source of all food inputs such as raw materials, additives, other ingredients and packaging.

Traceability data is most often recorded as Key Data Elements (KDEs) associated with Critical Tracking Events (CTEs). CTEs are described as those events that must be recorded in order to allow for effective traceability of products in the supply chain (e.g. where product is moved between premises or is transformed). KDEs are the pieces of information or data that are captured as part of the CTE.

KDEs for seafood will include information such as:

– Identity of the vessel that caught the product
– Dates of catch
– Lot numbers allocated to incoming product
– Identity of the premise that received, processed or stored the product
– Amounts of product processed or shipped

The traceability systems used in New Zealand are not prescribed. In practice, traceability relies on a combination of human readable data (i.e. labelling), electronically encoded data, and standardised electronic exchange of information being provided across the supply chain.

Traceability of seafood in New Zealand is regulated under food safety legislation.

The Animal Products Regulations, Food Regulations and Food Standards Code all contain traceability requirements for seafood. The majority of seafood produced in New Zealand is from land-based premises or factory vessels operating under a food safety Risk Management Programme regulated under the Animal Products Act.

A Risk Management Programme is a documented system that ensures products are fit for their intended purpose, and if intended for human consumption, also meet the requirements of the Food Standards Code. As part of this documented system, businesses must document their procedures for ensuring product traceability. Due to the uniqueness of business practices and products, the legislation places the onus of responsibility onto the business to demonstrate their system (supported by KDEs and appropriately identified CTEs) complies with legislation.

Conformance is backed-up by internal and external verifications and trace-back exercises. The frequency of external verification for traceability is determined by the Performance Based Verification system. This legislated system allows the frequency of external verification to vary based on previous performance. For seafood businesses that export, the frequency is capped at six monthly audits.

Several New Zealand seafood businesses have obtained Marine Stewardship Council Chain of Custody certification, which verifies the integrity of traceability systems for MSC certified products.
New Zealand legislation requires all labelling to be truthful and not misleading. This includes any claims of provenance.
Traceability Factsheet
Download a short summary of the key points from this section. The professionally designed format makes it easy to share soft copies and print hard copies.
Traceability Section Detail Report
To learn more about New Zealand's traceability requirements, download the full OpenSeas report here. All references and links (where available) are included.
Simplified traceability model for New Zealand seafood
Download a map of the generalised Critical Tracking Events and Key Data Elements for traceability of seafood in New Zealand.
Traceability is a critical element in New Zealand's food safety system and is therefore inseparable from the legal requirements around product safety and suitability. More details about the food safety aspects can be found under "Food Safety".
Non-compliance with traceability requirements can result in a series of enforcement actions depending on the severity of the breakdown in traceability. As a minimum, seafood businesses are required to identify and correct any non-compliance. For more severe offences against the Act, individuals or body corporates can face fines and/or imprisonment.
There is currently no global, secure, interoperable system for seafood traceability. Both the New Zealand seafood industry and the New Zealand Government maintain an active watching brief on global developments to enhance traceability.
Information verification procedures
All content generated on this page is referenced from the OpenSeas Section Detail Report (downloadable above).

The OpenSeas report was prepared by a technical expert, with demonstrable knowledge and experience in the topic at hand. An internal fit-for-purpose review was conducted by the OpenSeas Programme Director, which may have included external scientific or operational expertise. An external scope and accuracy review was conducted by the relevant regulatory agency(ies) (i.e. New Zealand Government departments).

The report author was responsible for revising the report in line with recommendations from reviews and retains final responsibility for the report content.
Section Detail Report Author:
Cathy Webb
Seafood Standards Manager, Seafood Standards Council
Page last updated: 3 August 2017
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