Part 1: Introduction

Monitoring importers of specified high-risk foods

New Zealanders expect the food they buy to be safe. The market for imported food is complex and often changing. Changes in what we like to eat and how we eat it affect what is imported and where it is imported from.

As at 2020, New Zealand imports food from 218 countries. The volumes of food imported into New Zealand have not changed much in recent years. However, the value of imported food has increased. In 2022, imported food was valued at $8.5 billion (see Figure 1). In early 2024, there were more than 3700 registered food importers in the country.

Figure 1
The value of food imports, from 2019 to 2022

Line graph showing the value of food imports from 2019 to 2022. In 2019, food import was valued at 7.4 billion. In 2022, the value of food import increased to 8.5 billion.

Source: Based on data from the Ministry for Primary Industries.

When new types of food are imported, and from new places of origin, there can be new risks to public health that will need to be managed.

Some imported foods have been associated with food recalls and outbreaks of foodborne illness. Between June 2022 and July 2023, 39 people contracted Hepatitis A in cases that were attributed to consuming imported frozen berries. Half of these people were hospitalised.

The latest figures from the Ministry for Primary Industries (the Ministry) showed that of the 60 consumer-level recalls that occurred in 2022, 27 were for imported food. This was an increase on previous years.

The Food Act 2014 (the Food Act) regulates the importing of food into New Zealand1 and makes importers responsible for the safety and suitability of the food they import. The Ministry is responsible for monitoring importers' compliance with the Food Act.

Why we did this audit

We carried out an audit to understand how well the Ministry monitors food importers' compliance with the requirements for importing foods that present a greater risk to consumers and public health (specified high-risk foods).

New Zealand's food import system relies on a level of trust that importers are assessing the safety and suitability of food that will be sold to the public. As with any system involving trust, checks are needed to ensure that importers are meeting their responsibilities.

Data supplied by the Ministry showed that, in 2022, specified high-risk foods made up 7.4% of imported food by value and 3.3% of imported food by weight.

How we carried out this audit

We looked at:

  • the Ministry's approach to checking whether importers are meeting all requirements for importing specified high-risk foods; and
  • how the Ministry assesses the effectiveness of food importing requirements.

We expected that:

  • the Ministry's approach to monitoring importers would be informed by the risks posed by the specified high-risk foods;
  • requirements for importing specified high-risk foods would be clear, and that importers would understand their responsibilities;
  • the Ministry would have a good understanding of importers' compliance with all requirements; and
  • the Ministry would collect the right information to support regular reviews of importing requirements for specified high-risk food to ensure that requirements are working effectively.

Monitoring importers and having effective food importing requirements are parts of a broader food safety system, which includes domestically produced food. We did not look at the broader food safety system for this audit.

This is the first of two rapid performance audits announced in our 2023/24 annual plan. Our rapid audits are intended to provide insight and analysis into matters of public interest in a short time frame. This audit was completed in 12 weeks.


The Controller and Auditor-General and the Deputy Controller and Auditor-General are independent Officers of Parliament. Their independence, and the independence of those who work on their behalf, is critically important to the good standing of the Office's work. To help maintain Parliament's and the public's trust and confidence, the Office of the Auditor-General has a Code of Ethics. The Code includes the independence requirements that the Auditor-General and those who carry out work on their behalf need to meet.

The Deputy Auditor-General, Andrew McConnell, recently held Deputy Director-General positions in the Ministry for Primary Industries. He was appointed to the role of Deputy Auditor-General in May 2023 and has not been involved with any aspect of this performance audit.

1: The Animal Products Act 1999 and the Wine Act 2003 are also components of the food safety system.