 
 
 
Risk Management Proposal  
 
Specified Animal Products   
SPECPROD.ALL  
 
 
 
 
29 November 2019   
 
 
Disclaimer  
This risk management proposal does not constitute, and should not be regarded as, legal advice. While every 
effort has been made to ensure the information in this document is accurate, the Ministry for Primary Industries 
does not accept any responsibility or liability whatsoever for any error of fact, omission , interpretation or opinion 
that may be present, however it may have occurred.  
© Crown Copyright - Ministry for Primary Industries  
 
 
 
 
 
 
 
 
 
 
 
 
 
Contact for further information : 
Ministry for Primary Industries (MPI)  
Agriculture & Investment Services  
Animal Trade ( Imports ) 
PO Box 2526  
Wellington 6140  
Email: animal.imports@mpi.govt.nz  
Telephone:  04 890 0134  
 Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 1 Contents  
1 Purpose  3 
2 Background  3 
3 Objective  4 
4 General considerations  4 
5 Recommendations for Goods Containing Animal Products for Human Consumption  4 
5.1 Canned or retorted animal products  4 
5.2 Collagen (edible)  5 
5.3 Composite foods  6 
5.4 Gelatine (edible)  7 
5.5 Insect and arachnid based products  8 
5.6 Meat and meat products  9 
5.7 Enzymes, microorganisms and other products used in food  10 
6 Recommendations for Non -Food Goods Containing Animal Products  12 
6.1 Bile and bile derivatives (bovine and ovine)  12 
6.2 Emu oil from Australia  13 
6.3 Gelatine (inedible)  13 
6.4 Highly processed inedible collagen/protein products  14 
6.5 Other non -food animal products  14 
6.6 Specified Porcine Enzymes  14 
7 Recommendations for other animal products  16 
7.1 Dietary Supplements, Supplemented Foods and Therapeutic Products for Human Use  16 
Schedule 1 – F03 Time and Temperature  17 
 
 Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 3 1 Purpose  
The purpose of this document is to:  
(1) Show the risk management decisions for the Import Health Standard (IHS) for Specified Animal Products . 
2 Background  
(1) The following IHSs have  some long -standing  import requirements : 
a) IHS: Emu Oil from Australia , EMUOILIC.AUS.AUS , 17 June 2004  
b) IHS: Pre -cooked Heat -and-Eat Meals Containing Animal Products for Human Consumption from 
Australia , HEAMEAIC.AUS , 1 November 2001  
c) IHS: Pre-cooked Heat -and-Eat Meals Containing Animal Products for Human Consumption from 
Canada and  the United States of America , HAEMEAIC.SPE , 10 April 2014  
d) IHS: Specified Animal Products and Biologicals , INEPROIC.ALL , 8 June 2011  
e) IHS: Specified Foods for Human Consumption Containing Animal Products , EDIPRO IC.ALL , 15 
January 2019  
f) IHS: Specified Porcine Enzymes from Canada and the United States of America , PORENZIC. NAM, 
16 January 1998  
(2) These animal products share at least one  of the  following characteristics:  
a) Being shelf -stable;  
b) Have undergone intensive industrial processes;  
c) Having specific commodity description s that restrict  their end use s and the country from whic h they 
originate . 
(3) The risk decisions supporting the above  IHSs will be reviewed in this RMP, and where they are in line with 
MPI risk advice  the commodities will be included in t he IHS for Specified Animal Products  
(SPECPROD.ALL) , which  has been drafted  as one single IHS to manag e risk  associated with the 
importation of these animal products .  
(4) MPI proposes shifting provisions, contained in the following specific clauses and IHSs, to the IHS 
SPECPROD.ALL , without making any changes to import requirements.  As a minor amendment, they will 
not be publically consulted.  
a) Clauses 6.4, 6.8, 6.16, 6.23  in the IHS: Spec ified Animal Products and Biologicals , INEPROIC.ALL, 
08 June 2011  
b) Clauses 2.4, 2.14, 2.16, 2.17, 2.18, 2.20,  2.23 in the IHS: Specified Foods for Human Consumption 
Containing Animal Products , EDIPROIC.ALL , 20 September 2019  
c) IHS: Emu Oil from Australia , EMUOILIC.AUS.AUS , 17 June 2004  
(5) MPI proposes  revok ing provisions, contained in the following specific clauses and IHSs, for commodities 
that have not been imported for a prolonged time (e.g. 10 years) . 
a) Clauses 6.6, 6.7, 6.9, 6.10, 6.11, 6.12, 6.13, 6.14, 6.15, 6.17,  6.18, 6.19, 6.20, 6.21, 6.22, 6.26, 6.27, 
6.28 in the IHS: Specified Animal Products and Biologicals , INEPROIC.ALL, 08 June 2011  
b) IHS: Heinz Watties Frozen or Chilled Meat Extracts from Japan , MEASHWIC.JPN , 9 October 2001  
c) IHS: Processed Animal Products for use by Airlines and the Military for Fli ghts Leaving New 
Zealand , AIRPROIC.ALL , 19 November 1999  
d) IHS: Specified Meat Products from Australia for use on Flights Leaving New Zealand , 
AIRMEAIC.AUS , 25 February 2000  
e) IHS: Specified Meat Products from France for Use on Flights Leaving New Zealand , 
AIRMEAIC.FRA , 25 February 2000  
f) IHS: Specified Protein Digested An imal Products from France , PRODIGIC.FRA , 8 May 2001  
g) IHS: Tacos containing Cooked Beef from Mexico , MEATACIC.MEX , 12 March 2001 e Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 4 3 Objective  
(1) The objective  of the IHS SPECPROD is to effectively manage biosecurity risks associated with the import 
of specified  animal products , consistent with New Zealand’s domestic legislation and international 
obligations.  
4 General considerations  
(1) Cons idering the characteristics mentioned in clause 2 (2), MPI’s assessment of the exporting countries’ 
export and certification systems , and bilateral country -to-country negotiation,  will not be required.  
(2) Risk will be effectively managed by at least one  of the following  general measures : 
a) An import permit assessment process ; 
b) Documentation (e.g. official certification, government -endorsed manufacturer’s declaration or 
manufacturer’s declaration) attesting to specific treatments  or processes ; 
c) Demonstration of di sease freedom as officially recognised by the OIE;  
d) Evidence (e.g. commercial documents , product labelling ) demonstrating the nature of the animal 
product and thus correct determination of the commodity  (e.g. products containing less than 5% 
each of aquatic  animal, dairy or egg products ). 
5 Recommendations for Goods Containing Animal Products 
for Human Consumption  
5.1 Canned or retorted animal products  
(1) Clause 2.1 (2) of the IHS EDIPROIC.ALL has the requirements for commercial consignments of canned or 
retorted animal products , which may be imported from any country provided all of the following 
requirements are met:  
a) The product is shelf -stable.  
b) The consignment is accompanied by:  
i) A manufacturer’s declaration stating that the product has been subjected to a retort  process of 
Fo3 or greater (refer to Schedule  1 of this RMP  for time s and temperatures to achieve Fo3);  or 
ii) A government -endorsed manufacturer’s declaration stating that the product (may or may  not 
be retorted) has been subjected to a heating process equiva lent to Fo3 or greater.  
(2) The IHS EDIPROIC.ALL has the following definition for shelf -stable:  
a) The product has been commercially manufactured.  
b) The product has been packaged by the manufacturer.  
c) The product is in that package.  
d) The package has not been opened or broken.  
e) The product:  
i) Is able to be stored in the package at room or ambient temperature.  
ii) Does not require refrigeration or freezing before the package is opened.  
(3) The definition has not been apparent for some importers a nd MPI biosecurity inspectors . It will be 
amended in the IHS SPECPROD.ALL  to add clarity . 
(4) Canned or retorted products that are h ermetic ally sealed are air tight, completely sealed and impermeable 
to gas. It is  a distinctive product feature  that indicates t he retort process has been  effectively carried out . 
‘Hermetically sealed’  will thus be set as a requirement.  
(5) The IHS EDIPROIC.ALL requires products to be accompanied by documentation, that is, a manufacture r’s 
declaration or government -endorsed manufacturer’s declaration. To enhance the veracity of Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 5 documentation presented to MPI, official certification issued by the exporting country will be required to 
attest to the retort process, and if applicable, the BSE  risk status of the exporting country, zone or 
compartment (see below).     
(6) To manage the risk of BSE  (applicable to products derived from Bos t aurus and B. indicus ), MPI will adopt 
the OIE Terrestrial Animal Health Code  (the Code ) recommendations for the importation of bovine meat 
and meat products from:  
a) a country, zone or compartment posing a negligible BSE risk ; or 
b) a country, zone or compartment posing a controlled BSE risk . 
 Recommendation  
(7) The RMP proposes that canned or retorted animal products may be  imported from any country provided 
the following requirements are met:  
a) The product does not require refrigeration before the package is opened . 
b) The product is commercially manufactured and packaged.  
c) The package has not been opened or broken.  
d) The product is accompanied by an official certificate stating that the product has been heat-treated in 
a hermet ically sealed container to an F0 value of 3 or more (see Schedule 3 of the IHS for equivalent 
time/temperatures combinations to achieve an F0 value of 3 ). 
e) In addition to the above requirements, product s contain ing bovine products  is accompanied by an 
official certificate that meets the specified  Code recommendations for:  
i) a country, zone or compartment posing a negligible BSE ris k; or 
ii) a country, zone or compa rtment posing a controlled BSE risk . 
5.2 Collagen (edible)  
(1) Clause 2.8  of the IHS EDIPROIC.ALL  has the requirement  for commercial consignments of edible 
collagen products such as manufactured sausage casings and hydrolysed collagen used as a dietary 
supplement,  which may be imported from any country provided the product is shelf -stable.   
(2) Currently, BSE is  managed by the MPI  Food Notice:  Importing Food , under which, bovine products can 
only be imported into New Zealand from countries that have been assessed as posing minimal BSE risk 
and that have a pre -clearance agreement with New Zealand. On the other hand, t he Code  contains 
recommended  BSE control me asure  for the importation of collagen . MPI proposes to align collagen import 
requirements with the OIE’s Code  recommendations, specifically, that  prepar ed from bones intended for 
food, and that prepared from hides and skins for food.  
(3) Collagen may be produc ed from a range of different animal tissues, including bovine tendons, calves 
skins, sheepskins, pigskins, sheep gut and bovine bones.   
(4) The followings does not pose a BSE risk:  
a) Collagen produced from species other than Bos taurus and B. indicus ; and  
b) Collag en prepared ex clusively from hides and skins, in accordance with the OIE Code . 
(5) Although the OIE Code has no recommendation relating to BSE for collagen produced from species other 
than B. taurus and B. indicus , and does not recommend official certification  for collagen prepared 
exclusively from hides and skins, requiring an official certificate to respectively state the species and that 
the collagen is prepared exclusively from hides and skins provides assurance to MPI.  
(6) Commercial manufacturing in collagen production further ensures  that non -BSE risk is minimised.   
 Recommendation  
(7) The RMP proposes that edible collagen derived from B. taurus  and B. indicus  and prepared from hides 
and skins may be imported  from any country provided that the product is accompanied by an official 
certificate stating that the collagen has been prepared exclusively from hides and skins . Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 6 (8) The RMP proposes adopting the Code  recommendations for collag en that is derived from Bos taurus and 
B. indicus , and prepared from bones. Ac cordingly, the product must be accompanied by an official 
certificate stating that:  
a) The product originates from a country, zone or compartment having a negligible BSE risk ; or 
b) The product originates from a country, zone or compartment having a controlled BSE risk  and is 
derived from cattle which have passed ante - and post -mortem inspections; and that  
i) Vertebral columns from cattle over 30 months of age at the time of slaughter and skulls have 
been excluded; and  
ii) The bones have been subjected to a process whi ch includes all of the following steps:  
1. degreasing;  
2. acid demineralisation;  
3. acid or alkaline treatment;  
4. filtration;  
5. sterilisation at >138 degrees Celsius  for a minimum of 4 seconds.  
(9) The RMP proposes that  edible collagen derived from species other than Bos t aurus  and B. indicus  may be 
imported from any country provided the product is accompanied by an official certificate that states the 
animal species, showing that the animal species is not B. taurus nor B. indicus . 
(10) In addition to the above requirements, t he RMP proposes that all edible collagen, regardless of species 
and w hich animal part  the collagen is derived from, is commercially manufactured.  
5.3 Composite foods  
5.3.1 Pre-cooked heat -and-eat meal  
(1) The IHS HEAMEAIC.AUS and IHS HEAMEAIC.SPE have long -standing import  requirements for pre -
cooked heat -and-eat meals containing animal products for human consumption from Australia, and 
Canada and the USA, respectively.  The requirements are as follows.  
(2) Pre-cooked heat -and-eat meals containing animal products for human consu mption may be imported from 
Australia  provided all the following requirements are met:  
a) The product is commercially packaged and sealed in foil or plastic ; 
b) The product does not contain poultry meat.  
(3) Pre-cooked heat -and-eat meals containing animal products for human consumption may be imported from 
Canada and the USA provided all the following requirements are met:  
a) The product is commercially packaged and sealed in foil or plastic ; 
b) The product does not contain poultry meat.  
c) The product is accompanied by a go vernment -endorsed manufacturer’s declaration that certify : 
 
For mammalian meat:  
i) The product contains only meat derived from animals slaughtered in Canada or the United 
States of America.  
ii) The product contains meat that is free of bone.  
iii) During manufacture of  the product, the meat products have been heated to the following 
minimum core temperatures/times, prior to freeze -drying, dehydrating or any other process:  
1) 70ºC for at least 25 minutes; or  
2) 80ºC for at least 3 minutes.  
For egg products:  
i) The egg products ha ve been heated to the following minimum core temperatures/times, prior 
to freeze -drying, dehydrating or any other process:  
1) 60ºC for at least 30 minutes;   
2) 100ºC for at least 1 minute.  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 7 For dairy products:  
i) The milk used to manufacture the dairy ingredients u sed during manufacture of the product 
has been heat treated:  
1) a sterilisation process applying a minimum temperature of 132°C for at least one 
second (ultra -high temperature [UHT]); or  
2) if the milk has a pH less than 7.0, a sterilisation process applying a m inimum 
temperature of 72°C for at least 15 seconds (high temperature - short time 
pasteurisation [HTST]); or  
3) if the milk has a pH of 7.0 or over, the HTST process applied twice.  
 
(4) These are historic import health agreements with Australia, Canada and the US A, and are consistent with 
the risk assessment that supports  other IHSs for unprocessed animal products.  
 Recommendation  
(5) The RMP proposes the requirements remain unchanged in the IHS SPECPROD.ALL . 
5.3.2 Products  containing less than 5% each of aquatic animal , dairy or egg products  
(1) Clause 2.22 of the IHS EDIPROIC.ALL  has the requirements for products  containing less than 5% fish, 
dairy or egg ingredients , which may be imported from any country provided all of the following 
requirements are met:  
a) The product is commercially prepared and packaged.  
b) The product is in its original sealed packaging on arrival.  
c) The product must be:  
i) Accompanied by a manufacturer’s declaration which certifies that the product contains no 
meat ingredients and less than 5% each of fish, da iry, or egg ingredients; or  
ii) In commercial packaging that states the product contains no meat ingredients and less than 
5% each of fish, dairy, or egg ingredients.  
(2) This is a long -standing provision. Products imported under this provision are commercially pr epared and 
packaged for human consumption. This reduces the possibility of waste production, and the amount of 
waste if it does occur. The low percentage (i.e. 5%) requirement further reduces the amount of fish, dairy 
or egg ingredients being exposed to an imal populations if waste is produced.  Considering t he above , MPI 
determines that the commodity poses a negligible biosecurity risk to New Zealand . 
(3) Following the reasoning in clause 5.3.2 (2) of this RMP, MPI also considers that products containing less 
than 5% aquatic animal products ( e.g. finfish, crustaceans, mollusca) pose  negligible risk to New Zealand.   
(4) Manufacture r’s declaration attesting to the absence of meat ingre dient and the percentage of aquatic 
animal , dairy or egg products , or labelling to de monstrate the same,  is considered sufficient in providing 
MPI the confidence required to ascertain  the composition  of the product.  
 Recommendation  
(5) The RMP proposes  the requirements remain unchanged in the IHS SPECPROD.ALL , except the wording 
‘fish’ is repl aced by ‘aquatic animal ’. 
5.4 Gelatine  (edible)  
(1) Clause 2.20 of the IHS EDIPROIC.ALL has the requirement for edible gelatine and gelatine products, 
which may be imported from any country provided they are shelf -stable.  
(2) Gelatine may be prepared from hides and skins, or bones. The OIE recommends that gelatine prepared 
from hides and skins is a safe commodity as it does not carry BSE infectivity; whereas gelatine prepared Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 8 from bones  should be accompanied by an official cert ificate  with specific attestations as recommended by 
the OIE.  
(3) Considering the following scientific evidence, MPI will not adopt the OIE’s recommendation for gelatine 
prepared from bones.  
(4) Appendix 4: Does gelatine pose a BSE risk to consumers  of the  MPI document Officials’ Review of New 
Zealand’s BSE Country -Categorisation Measure  states that BSE infectivity has not been found in skin, 
even in advanced clinical cases. This supports the OIE’s recommendation for gelatine prepared from 
hides and skins.  
(5) The pape r described the following chemical processes used in the manufacture of gelatine:  
a) Bone degreasing. This has the ability to remove 98 -99% of nervous tissue proteins.  
b) Acid treatment. This drops the pH value to less than 1.5 for a period of at least 2 days an d brings 
about changes to the internal structure of the BSE prion protein.  
c) Alkaline treatment. This increases the pH value to greater than 12.5 for a period of between 20 and 
50 days. This again  brings about changes to the internal structure of the BSE pri on protein.  
d) Extraction of gelatine. This involves filtration and sterilisation processes that further remove 
suspended particles and remove remaining, if any, BSE infectivity.  
(6) The paper concluded that the series of chemical processes used in the manufacture of gelatine , 
regardless of whether it is derived from hides and skins, or bones,  is sufficient to inactivate any BSE 
infectivity which might have been present in the raw material from which the gelatine is made.  
 Recommendation  
(7) The RMP proposes  that commercially manufactured edible  gelatine, regardless of whether it is prepared 
from hides and skins, or bones, may be imported from any country .  
(8) Intermediate gelatine products (e.g. gel bone) produced during the manufacture of gelat ine have not 
undergone all the industrial  processes described in clause 5.4 (5 ). The pr oposed requirement s therefore 
do not apply to  intermediate products.  Imports of intermediate products would need to meet other IHSs.  
5.5 Insect and arachnid based products  
(1) Insect and arachn id based food products, such as insect -containing  hard candy and cricket flour, are 
becoming a more common ly trade d commodity.  
(2) MPI risk analysts completed  Technical Advice (TA): the Biosecurity Risk of Insect -based Products 
Intended for Consumption by H umans and Animals , September 2015.   
(3) According to the TA, insect products intended for human or animal consumption pose a very low 
biosecurity risk to New Zealand if:  
a) The commodity contains insects that were reared in a commercial environment using a formul ated 
insect diet and standard hygienic insect rearing techniques; and  
b) The commodity is not produced fr om insects that are wild caught.  
(4) The TA states  that most commercial i nsect food manufacturers  are registered with the US Food and Drug 
Administration  (FDA ), apply  the processing  principles set o ut in the Codex Alimentarius, including  Hazard 
Analysis Critical Control Point (HACCP), or follow Good Manufacturing Practices (GMP) . Some 
manufacturers may comply with all or  a combination of the above systems. Out of the above systems, 
HACCP is an internationally recognised system commonly applied by food industries.  
(5) Commercial manufacturing of insect -based food products commonly involves c ooking , freeze -drying or  
dehydration , which leads to insects to become non-viable.  The TA also states that transmission of plant 
pathogens can only occur when the insect is alive.  
(6) While the scope of the risk advice includes only insect based food products, it would also apply to 
arachnid based food products that follow the sa me harvesting and processing .  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 9  Recommendation  
(7) The RMP proposes that insect  and arachnid based  products may be imported from any country provided 
the product is accompanied by a  government -endorsed  manufacturer’s declaration stating that: 
a) The insect or ara chnid is raised in farms specifically for human consumption; and  
b) The product is processed in facilities operating a current Hazard Analysis and Critical Control Point 
(HACCP) programme; and  
c) The product does not contain viable insects or arachnids.  
5.6 Meat and  meat products  
5.6.1 Processed foods containing less than 5% meat  
(1) Clause 2.21 of the IHS EDIPROIC.ALL  has the requirements for products containing less than 5% meat 
ingredients, which may be imported from any country provided all of the following requirements are met:  
a) The product is shelf -stable.  
b) The product must be:  
i) Accompanied by a manufacturer’s declar ation,  which certifies that the product contains less 
than 5% meat ingredients; or  
ii) In commercial packaging that states the product contains less than 5% meat ingredients.  
(2) This is a long -standing import provision , and is intended to mitigate risk from produ cts that contain 
discernible meat or meat pieces. The wording ‘ingredient’ should therefore be removed from the 
commodity title to add clarity.  For products containing meat based ingredients (including broth, 
concentrate, meat extract, fat, flavours, floss, stock or tallow) , the provision for ‘processed foods 
containing meat -based ingredients’ applies (see clause 5.6.2 of this RMP).  
(3) Products imported under this provision are commercially prepared and packaged for human consumption. 
This reduces the pos sibility of waste production, and the amount of waste if it does occur. The low 
percentage (i.e. 5%) requirement further reduces the amount of meat being exposed to animal populations 
if waste is produced.  Considering the above, MPI determines that product s containing less than 5% of 
meat  poses a negligible biosecurity risk to New Zealand.  
(4) Based on the rationale in clause 5.6.3 (3), whether the product requires refrigeration before the package is 
opened is not considered to be a risk mitigation measure. Als o refer to clause 5.1 (2) and (3) of the RMP 
on the discussion about the shelf -stable requirement.  
(5) The IHS EDIPROIC.ALL requires a manufacturer’s declaration to state that the prod uct contains less than 
5% meat. It is important that this  statement is authe ntic. Government -endorsed  manufacturer’s declaration 
should  provide New Zealand an acceptable level of confidence. The labelling provision will thus be 
removed.  
 Recommendation  
(6) The RMP proposes that processed foods  containing less than 5% meat  may be impo rted from any country 
provided all of the following requirements are met:  
a) The product is commercially prepared and packaged.  
b) The package has not been opened or broken.  
c) The product must be a ccompanied by a government -endorsed manufacturer’s declaration whic h 
certifies that the product contains less than 5% meat.  
5.6.2 Processed f oods containing meat -based ingredients  
(1) Clause 2.2 of the IHS EDIPROIC.ALL has the requirements for commercial imports of animal product -
based floss, flavouring or stock, which may be impor ted from any country provided all of the following 
requirements are met:  
a) The product is shelf -stable.  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 10 b) The product does not require further cooking before consumption, but may require rehydration or  
reheating prior to consumption.  
(2) See clau se 5.1 (2) and (3) of the RMP for a discussion on  the shelf -stable requirement.  
(3) The commodity title in the IHS EDIPROIC.ALL  ‘animal product -based flavouring or stock’ does not clearly 
convey the intent of the provision, nor does it  sufficiently define s the commodity . This provision is intended 
for processed foods that are ready for direct human consumption or for direct use as an ingredient in the 
preparation of  food for human consumption , limiting the risk of any product waste getting exposed to 
animals . This  has only be en implied in the clause ‘not requiring further cooking bef ore consumption’ . By 
requiring products to be in shelf -ready  packaging  (see definition in Schedule 2 of the IHS ) that is rea dy for 
direct human consumption,  or for direct use as an ingredient in th e preparation of  food for human 
consumption , the intent of the provision  should be clarified . 
(4) Flavouring and stock are derived from meat, and meat is defined as all edible parts of an animal  according 
to the OIE Code . The wording ‘animal -based ingredients’  is thus replaced with ‘meat -based ingredients’ to 
add clarity. Flavouring  and stock are not specific nor informative . They  should  therefore be replaced by 
specific examples: broth, concentrate, extract, fat, flavours,  floss, stock  or tallow . 
(5) Considering the clarifications described  in 5.6.2  (3), the provision therefore will not  apply to commercial, 
bulk (e.g. in drums) imports of meat -based ingredients .  
 Recommendation  
(6) The RMP proposes that processed foods containing  meat -based ingredients (ingredients i nclude  broth, 
concentrate, extract, flavours , floss , stock  or tallow), may be imported f rom any country provided the 
following requirements are met:  
a) The product does not require refrigeration before the package is opened.  
b) The product is commercially manufa ctured and is in shelf -ready packaging . 
c) The package has not been opened or broken.  
d) The product is in  a form ready for:  
i) direct human consumption; or  
ii) the preparation of  food for human consumption.  
5.6.3 Pork crackling  
(1) Clause 2.4 of the IHS EDIPROIC.ALL has the requirement for commercial consignments of pork crackling, 
which may be imported from any country provided they are accompanied by a manufacturer’s declaration 
stating that the product has been subj ected to a heating process of F0 3 or greater ( see Schedule 3 of the 
IHS for equivalent time/temperatures combinations to achieve an F0 value of 3 ). 
 Recommendation  
(2) The RMP proposes the requirements remain unchanged in the IHS SPECPROD.ALL.  
5.7 Enzymes, m icroorganisms and other  products  used in food  
(1) The IHS IN EPROIC.ALL has the following requirements:  
a) Clause 6.4: c ommercially manufactured food cultures, enzymes or starters derived from or 
consisting of micro -organisms (e.g. yoghurt, cheese and sausage starters, enzymes  or cultures) 
from any country may be given  clearance.  
b) Clause 6.5 of the IHS INEPROIC.ALL  has the requirements for commercially manufactured rennet, 
which may be imported from Australia.  
c) Clause 6.8: b rewer ’s yeast, baker ’s yeast or any other yeast products used in the food industry from 
any country  may be given clearance.   
d) Clause 6.16: commercially packaged isinglass air bladder of fish (clarifying agent for alcoholic 
beverages) from any country.  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 11 (2) These are long -standing requirements that represent a very low risk to New Zealand and thus are eligible 
for biosecurity clearance.  
(3) Rennet is a complex of enzymes used in food, and is eligible for importation from any country under the 
provision ‘ commercially manufactured food cultures, enzymes or starters d erived from or consisting of 
micro -organisms (e.g. yoghurt, cheese and sausage starters, enzymes  or cultures)’.  
(4) Products  containing p robiotic microorganisms  are commodities  commonly traded . A probiotic 
microorganism is eligible for importation when it is:  
a) Deemed by t he New Zealand Environmental Protection Authority (EPA) as present in New Zealand 
under the Hazardous Substances and New Organisms (HSNO) Act 1996 .  
b) Not an unwanted organism under the Biosecurity Act 1993.  
c) Not contaminated by any other organisms  that may not meet 5.7(4) a) and b).  
d) Not for use in or on animals or plants.  
Recommendation  
(5) The RMP proposes that the provision in clause 6.5  of the IHS INEPROIC.ALL  be revoked; and clause 6.4, 
6.8 and clause 6.16 remain unchanged.  
(6) The RMP proposes that pr oducts containing probiotic microorganisms may be imported from any country 
provided the following requirements are met:  
a) The product is accompanied by a manufacturer’s declaration stating:  
i) The scientific name (genus and species) of the microorganisms; and  
ii) The product is for human consumption; and  
iii) The probiotic microorganism, or each respective microorganism  if the product contains more 
than one , is in the form of a pure culture that consists of a single species and that has no 
contaminating organisms.  
b) The p roduct is accompanied by a confirmation from the New Zealand Environmental Protection 
Authority (EPA) stating that the microorganisms are deemed to be present in New Zealand under the 
Hazardous Substances and New Organisms (HSNO) Act 1996.  
c) The microorganis ms are not unwanted organism under the Biosecurity Act 1993.  
  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 12 6 Recommendations for Non -Food Goods Containing Animal 
Products  
6.1 Bile and bile derivatives (bovine and ovine)  
(1) Clause 6.3 of the IHS INEPROIC.ALL  has requirements for  concentrated ox gall/ox bile and derivatives 
from any country , which may be imported when  the following requirements are met : 
a) The product shall be commercially packaged  
b) The packaging shall be clean and free from visible signs of contamination  
c) The product shall be shelf -stable (i.e. does not require refrigeration.).  
(2) MPI has revised import requirements of bovine and ovine bile and their derivatives , and t he MPI Technical 
Advice  on Processed Bovine and Ovine Bile  (TA dated 2 Oct 2019 ) identified the following  hazards  for 
which further assessment was undertaken around the ef ficacy of industrial processes  in inactivating each 
identified hazard:  
a) Viruses  
i) Bluetongue virus  
ii) Bovine herpes virus - 1  
iii) Bovine viral diarrhoea virus  
iv) Foot and mouth disease virus  
v) Lumpy sk in disease virus  
vi) Peste des petitis ruminants virus  
vii) Rift valley fever virus  
viii) Sheep pox virus  
b) Bacteria  
i) Mycoplasma mycoides subsp. mycoides SC  
c) Prions  
i) Bovine spongiform encephalopathy (BSE)  
ii) Scrapie  
(3) The industrial processes considered in the TA  were:  
a) Heat treatment at a minimum of 100  degrees Celsius  for a minimum of 8 hours;  and 
b) Hydrolysis  with sodium hydroxide . 
(4) The TA  concluded that in order to mitigate all the identified hazards, bile must be treated with the industrial 
processes described in 6.1( 3) of this RMP.  
(5) The TA also states that the collection of bile from animals that passed ante - and post - mortem inspections 
at premises with competent authority oversight  ensures bile is collected only from healthy animals.  
(6) Processed  bile and bile derivatives may be contaminated with unprocessed bile. Precautions to prevent 
contamination prior to dispatch from the processing premises in the exporting country is able to mitigate 
risk of post -processing contamination.  
(7) Considering the New Zealand industry may import bile that has been subjected to  heat treatment as 
desc ribed in 6.1 (3) a) of this RMP , bile may be directed to an MPI -approved transitional facility for further 
processing to meet 6.1 (3) b).  
Recommendation  
(8) The RMP proposes that bovine and ovine bile, and their derivatives, may be imported from any country 
provided it is accompanied by an official certificate that states the bile, or the bile that produces the bile 
derivatives:  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 13 a) Has been collected from animals that have passed ante - and post -mortem inspectio n at premises 
with competent authority oversight . 
b) Has unde rgone a heat treatment of 100 degrees Celsius  for a minimum of 8 hours.  
c) Has been treated with sodium hydroxide.  
d) Has been subjected to precautions to prevent contamination prior to dispatch from the processing 
premises.  
e) Is in packaging that is clean and free from visible signs of contamination.  
(9) The RMP proposes that bovine and ovine bile that has not undergone the treatment as described in 6.1 
(3) b) of this RMP  may be imported from any country provid ed it is accompanied by:  
a) An official certificate that states the bile :  
i) Has been collected from animals that have passed ante - and post -mortem inspection at 
premises with competent authority oversight . 
ii) Has unde rgone a heat treatment of 100 degrees Celsius  for a minimum of 8 hours  
iii) Has been subjected to precautions to prevent contamination prior to dispatch from the 
processing premises.   
iv) Is in packaging that is clean and free from visible signs of contamination.  
b) An import permit that nominates an MPI -approved  transitional facility where the bile will be treated 
with sodium hydroxide.  
6.2 Emu oil from Australia  
(1) The IHS EMUOILIC.AUS has the requirements for emu oil from Australia, which may be imported when it 
is presented with  
a) a manufacturer’s declaration stating that the emu oil has been heat treated to a core temperature of 
the product to a minimum of 100 degree C for at least 1 minute during manufacturing; and  
b) a veterinary certificate to state that records of the manufacturer has been examined and the signing 
government veterinary official has no reason to doubt the veracity of the manufacturer's declaration.  
Recommendation  
(2) The RMP proposes that the requirements remain unchanged.  
6.3 Gelatine (inedible)  
(1) Clause 6.23 of the IHS INEPROIC.ALL has the requirements for inedible gelatine and products containing 
gelatine, which may be imported from any country provided the product is commercially packaged.  
(2) The scientific article in Appendix 4: Does gelatine pose a BSE risk to consumers  of the document Officials’ 
Review of New Zealand’s BSE Country -Categorisation Measure  presented and discussed in clause 5.4 of 
the RMP can be applied to both edible and inedible gelatine. Recommendation for inedible gelatine will 
therefore be the same as that for edible gelatine.  
 Recommenda tion 
(3) The RMP proposes that commercially manufactured inedible gelatine, regardless of whether it is prepared 
from hides and skins, or bones, may be imported from any country .  
(4) Intermediate products (e.g. gel bone) during the manufacture of gelatine have no t undergone all the 
chemical processes described in clause 5.4 (5).  The proposed requirement therefore do not apply to these 
intermediate products. Imports of intermediate products would need to meet other IHSs.  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 14 6.4 Highly processed inedible collagen/protein products  
(1) Clause 6.25 of the IHS INEPROIC.ALL has the requirement for highly processed inedible collagen/protein 
products, which may be imported from any country provided the products are commercially packaged. 
Examples of such products are keratin setting retarder (product used for making plaster), hydrolysed 
collagen, other products containing animal proteins for use in the buildin g trade (e.g. Durafoam protein).  
(2) These products should be prohibited for use as animal feed to minimise the risk exposure of th e products 
to animals.  
(3) When commercially manufactured, these products do not represent a biosecurity risk to New Zealand. 
Commercial packaging should therefore not be required.   
Recommendation  
(4) The RMP proposes that highly processed inedible collagen/protei n products may be imported from any 
country provided the following requirements are met:  
a) The product is not for use as animal feed; and  
b) The product is commercially manufactured.  
6.5 Other non -food animal products  
(1) The IHS INEPROIC.ALL  contains the following pro vision : 
a) Clause 6.24: commercially packaged animal skin/hide glue or size from any country.  
(2) This is a  long-standing  requirement that present a very low risk to New Zealand and thus is eligible for 
biosecurity clearance.  
(3) Animal skin/hide glue or size, when commercially manufactured, do not represent a biosecurity risk to New 
Zealand. Commercial packaging should therefore not be required.  
Recommendation  
(4) The RMP proposes that the requirements remain unchanged, except that the  requirement ‘commercially 
packaged’ for and animal skin/hide glue or size, is replaced with ‘commercially manufactured’.  
6.6 Specified Porcine Enzymes  
(1) Cause 6.14 of the IHS INEPROIC.ALL has the requirements for the  porcine  enzymes pancreatin and 
pepsin from Australia, Canada, and the USA, which may be given clearance provided the product is 
commercially packaged.  
(2) The IHS PORENZIC.NAM also has requirements for four specified porcine enzymes: lipase, pancreatin, 
pepsin and trypsin from Canada and the  USA. The IHS requires the product is commercially packaged 
and hermetically sealed, and a manufacturer’s declaration which states : 
a) The product  was derived from pigs born, raised and slaughtered in with Canada or the USA ; and  
b) that the pigs have passed vete rinary ante -mortem and post -mortem inspection ; and  
c) that the pigs were processed in meat packing premises inspected by and registered with the 
government veterinary authority of the country of  origin of the pigs . 
(3) For the purpose of preventing post -processi ng contamination, tamperproof sealing is deemed as 
equivalent as hermetic sealing.  
(4) The IHS PORENZIC.NAM  also requires  veterinary certification stating that African swine fever, foot and 
mouth disease, hog cholera (classical swine fever), rinderpest, and swine vesicular disease has not 
occurred in the country of origin of the pigs during the twelve months prior to the date of  departure of the Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 15 product for New Zealand . Note that rinderpest had been globally eradicated in 2011 so certification of this 
disease  is not required.  
(5) Requirements for t he porcine  enzymes pancreatin and p epsin from Canada, and the USA have been 
duplicated in the IHS INEPROIC.ALL and PORENZIC.NAM. The requirements in the IHS 
PORENZIC.NAM should preva il as it provides New Zealand a highe r level of protection.  
Recommendation  
(6) The RMP proposes that the requirements for the porcine enzymes pancreatin and pepsin from Australia 
remain  unchanged.  
(7) The RMP proposes that specified porcine enzymes may be imported from Canada and the United States 
of America provide they meet the following requirements:  
a) The porcine enzymes is lipase, pancreatin, pepsin or trypsin.  
b) The p roduct is commercially packaged with tamperproof seals applied to bags . 
c) The product is accompanied by  a manufacturer’s declaration sta ting: 
i) The product was derived from pigs born, raised and slaughtered in Canada, or the United 
States of America. ; and  
ii) that the pigs have passed veterinary ante -mortem and post -mortem inspection; and  
iii) that the pigs were processed in meat packing premises in spected by and registered with the 
government veterinary authority of the country of origin of the pigs.  
d) The product is accompanied by a veterinary certificate stating that African swine fever, foot and 
mouth disease, hog c holera (classical swine fever) , and swine vesicular disease has not occurred in 
the country of origin of the pigs during the twelve months prior to the date of  departure of the product 
for New Zealand . 
 
  Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 16 7 Recommendations for other animal products  
7.1 Dietary Supplements, Supplemented Foods and Therapeutic 
Products for Human Use  
(1) Cordyceps are non -viable caterpillars that have been parasitized by a fungus . The fungus has several 
scientific names that are synonymous to each other: Cordyceps sinensis, Metacordyceps chlamydosporia, 
Ophiocordyceps  sinensis, and Verticillium chlamydosporium . The fungus has been deemed by the New 
Zealand Environmental Protection Agency (EPA) as being present in New Zealand. So as long as 
cordyceps are non -viable and free from visible contamination, they are eligible for importation.  
(2) Clause 6.1 of the IHS INEPROIC.ALL has the requirements for health supplements/Chinese and Oriental 
medicines containing animal products, which may be imported from any country provided all the following 
requirements are  met: 
a) The product s hall be commercially manufactured and compounded into pills,  tablets, capsules, 
liquids, syrups, oils or medicated plasters.  
b) The product shall be shelf -stable (i.e. not require refrigeration)  
c) The packaging or appearance of the packaging shall not indicate that the product  is intended for 
animal use . 
d) If the product is a liquid, it shall be con tained within sealed packaging.  
(3) Sub-clause d) does not add to risk mitigation.  
(4) The commodity title ‘ health supplements/Chinese and Oriental medicines containing animal products ’ 
does not sufficiently describe the commodity.  To align with other New Zealand legislations, ‘ Dietary 
supplements, s upplemented foods and therapeutic p roducts (including Chinese and Oriental medicines) ’, 
each have their own specific definition under the Dietary Supplements Regulatio ns 1985 administered by 
MedSafe, the New Zealand Food (Supplemented Food) Stan dards 2016, and Section 4 of the Medicines 
Act 1981, will be used.  
(5) The CTOd 2017 064 gives the a bility for bulk health supplements/Chinese and Oriental medicines 
containing animal products to be directed to a transitional facility for further processing (i.e. commercial 
manufacturing and compounding of the bulk product into pills, tablets, capsules, liquids, syrups, oils or 
medicated plasters ) to occur before biosecurity clearance may be given.  This provision will be added to 
the IHS.  
(6) Clause 6.2 of the IHS INEPROIC.ALL has the requirements for homeopathic medicines containing animal 
products , which m ay be imported  from any country provided all the following requirements are met:  
a) The product shall be commercially packaged  
b) The product shall be labelled as being a homeopathic medicine  
c) The product packaging shall indicate that the medicine is intended for  human use.  
Recommendation  
(7) RMP proposes that dietary supplements, supplemented foods and therapeutic products (including 
Chinese and Oriental medicines) containing animal products from any country may be imported provided 
they meet the following requiremen ts: 
a) The product is commercially manufactured and compounded into pills, tablets, capsules, liquids, 
syrups, oils or medicated plasters; or the product must be directed to a transitional facility for further 
processing into pills, tablets, capsules, liquids, syrups, oils or medicated plasters.  
b) The product does not require refrigeration before the package is opened.  
c) The packaging indicates that the product is intended for human use.  
(8) The RMP proposes that the requirements for homeopathic medicines containing animal products  remain 
unchanged.   Risk Management Proposal:  Specified Animal Products  29 November 2019  
Ministry for Primary Industries   Page 17 Schedule  1 – F03 Time and Temperature  
(1) Equivalent time/temperature combinations to achieve an F0 value of 3:  
 
 
Temperature at the 
slowest heating point of 
the product (°C)  Process time (min)  Temperature at the 
slowest heating point of 
the product (°C)  Process time (s)  
110 40 127 46 
111 32 128 37 
112 25 129 29 
113 20 130 23 
114 16 131 18 
115 13 132 15 
116 11 133 12 
117 9 134 9 
118 7 135 7 
119 6 136 6 
120 5   
121 3   
122 3   
123 3   
124 3   
125 2   
126 1   
 