Risk Management Proposal  
 
Specified Animal Products   
SPECPROD.ALL  
 
 
 
 
14 December 2022 Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 1  
 
 
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)  
Animal and Plant Health  
Animal Imports  
PO Box 2526  
Wellington 6140  
Email: animal.imports@mpi.govt.nz   
Telephone:  04 890 0134  
  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 2 Contents  
1 Purpose  3 
2 Background  3 
3 General recommendations  3 
3.1 Part 3 and Part 4 of the IHS  3 
3.2 New or amended definitions  3 
3.3 Guidance throughout the IHS updated  3 
4 Recommenda tions for goods containing animal products for human consumption 4 
4.1 Edible bird’s nests  4 
4.2 Canned or retorted products  4 
4.3 Canned or retorted beef products and collagen of bovine origin  4 
4.4 Collagen  4 
4.5 Dietary protein supplements  4 
4.6 Products containing 5% or less animal products  5 
4.7 Products containing more than 5% animal products  5 
4.8 Alcoholic drinks containing eggs  5 
4.9 Mayonnaise and salad dressing  6 
4.10  Mooncakes  6 
4.11  Insect and arachnid- based food products  6 
4.12  Processed foods containing meat -based ingredients  6 
5 Recommendations for other goods containing animal products  7 
5.1 Bile 7 
5.2 Dicalcium phosphate  8 
5.3 Gelatine  8 
5.4 Non-viable animal specimens  8 
5.5 Specified items  8 
5.6 Specified porcine enzymes  9 
5.7 Tallow and its derivatives  10 
5.8 Therapeutic products and dietary supplements  10 
Appendix 1 – Document History  11 
 
 
 
   Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 3 1 Purpose  
The purpose of this document is to:  
(1) Show the updated risk management decisions for the Import Health Standard (IHS) : Specified Animal 
Products , SPECPROD.ALL . 
2 Background  
(1) The IHS SPECPROD .ALL was issued on 25 June 2020 . Since then, the A nimal Imports  team has 
received new import requests  and feedback  from importers and border inspectors . Some areas of the IHS  
also need clarification .  
(2) Import provisions in  the IHS INETROIC.ALL  have been reviewed, result ing in the incorporat ion of game 
trophies and other specified items of animal origin  into the IHS SPECPROD.ALL , after which time the IHS 
INETROIC.ALL  will be revoked .  
(3) This RMP contains discussions of new or updated risk management decis ions.  The previous version of 
the RMP SPECPROD.ALL , 25 June 2020, which contains the risk management decisions for all 
unchanged clauses of the IHS, can be found here: https://www.mpi.govt.nz/dmsdocument/41070 -Risk-
management -proposal -to-IHS-for-Specified -Animal -Products . 
3 General recommendations  
3.1 Part 3 and Part 4 of the IHS  
(1) Part 3  and Part 4  of the existing IHS ha ve been combined into a single section named Part 3 Specified 
requirements for other goods containing animal products.  
3.2 New or amended definitions  
(1) Definitions for : bee products, finished game trophy, fully tanned leather and leather goods, medical 
preparatio n, non -viable animal or animal tissues, ornamental products of animal origin, retail packaging , 
size, visible contamination , and World Organisation for Animal Health (WOAH)  have been added or 
amended.  
3.3 Guidance throughout the IHS updated  
(1) Guidance information has been added to clause s 1.6, 2.1, 2.2, 2.3, 2.5, 2.6, 2.7, 3. 1, 3.2, 3.6, 3.8 , and  3.9 
of the IHS to enhance operational clarity for MPI inspectors.   
(2) A model  certificate template for insect - and arachnid -based products , bile derivatives, bovine and ovine 
concentrated bile, dicalcium phosphate, game trophies from the EU, and tallow and its derivatives  have 
been added to the IHS.  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 4 4 Recommendations for g oods containing animal products for 
human consumption 
4.1 Edible bird’s nest s  
4.1.1 Edible bird’s nests and products containing edible bird’s nests  - clause 2.1(1) of the IHS  
(1) The IHS has a provision to allow product s that ha ve been manufactured in a third country and imported 
into Australia to be given biosecurity clearance in New Zealand. This was not intended to apply to  edible 
bird’s nest s and products containing edible bird’s nests that ha ve been imported into Australia fro m a third 
country. To clarify  this intent , an exclusion  clause  has been added to the IHS.  
4.2 Canned or retorted products  
4.2.1 Canned or retorted products with 5% or less beef -  clause 2.1(2) of the IHS  
(1) Canned or retorted beef products currently require bovine spo ngiform encephalitis ( BSE) certification.  
There has been a longstanding import provision to allow shelf -stable products containing 5% or less meat 
to be imported with a manufacturer’s declaration without BSE certification.  In line with th is provision, it is 
proposed that canned or retorted animal products containing 5% or less beef be  exempt from BSE 
certification.  
4.3 Canned or retorted beef products and collagen of bovine origin  
4.3.1 Canned or retorted beef products and collagen of bovine origin - clause 2.1(2) and 2.2 of 
the IHS  
(1) The IHS allows canned or retorted  meat  and collagen of bovine origin to be imported from  compartment s 
with a negligible BSE risk or controlled BSE risk. As the WOAH  does not recognise BSE compartments, 
the RMP propose s removing from the IHS the ability to import canned or retorted  meat  and collagen of 
bovine origin from compartment s. These commodities  may be eligible for importation under the IHS 
Ruminant Meat and Ruminant Meat Products . 
4.4 Collagen 
4.4.1 Collagen not of bovine origin -  clause 2.2(2) of the IHS  
(1) As collagen under Part 2  of the IHS is for human consumption, the word ing ‘edible’ is superfluous and has 
been removed.  
(2) Cartilage does not carry any BSE risk.  
(3) The RMP proposes that collagen derived from Bos taurus  or B. indicus  and prepared exclusively from 
cartilage  is eligible for importation when accompanied by an offic ial certificate.  
4.5 Dietary protein supplements  
4.5.1 Dietary protein supplements and protein bars containing dairy and/or egg -  clause 2. 3.3 of 
the IHS  
(1) Bulk dietary protein supplements containing dairy and/or egg should be imported under other applicable 
IHSs, e.g. IHS EGGPRODS. GEN  and IHS EDIPROIC.ALL  (or the generic dairy products IHS that will 
replace it) , meeting any applicable certification requirements.  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 5 (2) This clause is  only applicable to  products  in retail  packag ing. This clarification has been added to the 
clause.   
(3) Protein bars containing dairy and/or egg are also eligible to be imported when all requirements under this 
clause are met.  
4.6 Products containing 5% or less animal products  
4.6.1 Products containing 5% or less animal products -  clause 2.3. 5 and 2. 6.1 of the IHS  
(1) The wording ‘less than 5%’ has been modified to ‘5% or less’ to enable importation of products that 
contain exactly 5% of the two specif ied animal product s.  
4.7 Products containing more than 5% animal products  
4.7.1 Products containing more than 5% each of aquatic animal, dairy or egg products  - clause 
2.3.6 of the IHS  
(1) MPI previously  allowed the imp ortation of shelf -stable products containing more than 5% aquatic animal, 
dairy, or egg products  where the products are accompanied by a manufacturer’s declaration stating that 
they have be en heat -treated to achieve an F0 value of 3 or more . This ability w as lost with the issue of the 
IHS SPECPROD.ALL , 25 June 2020 , and is being reinstated  in this amendment of the IHS . 
(2) However, a manufacturer’s declaration does not provide appropriate assurance  to MPI , and t he RMP 
therefore proposes that an official certificate is required.  
(3) The RMP proposes that products containing more than 5% each of aquatic animal, dairy or egg products may be imported from any country provided all the following requirements are met.  
a) The product does not require refrigeration before the package is opened.  
b) The product is commercially manufactured into retail packaging.  
c) The product is in its original sealed packaging on arrival.  
d) The product is accompanied by a n official certificate stating that the product h as been heat -treated to 
an F0 value of 3 or more.  
4.8 Alcoholic drinks containing eggs  
4.8.1 Alcoholic drinks containing eggs and at least 14% alcohol  - clause 2. 4.1 of the IHS  
(1) This commodity is currently eligible to be imported under the  IHS EGGPRODS.GEN  when it is:  
a) Shelf-stable  
b) Commercially  manufactured and packaged ; and  
c) Contain at least 14% alcohol.  
(2) The RRA: Miscellaneous Egg Products for Human Consumption  2014 included an assessment of the risks 
associated with drinks containing eggs  and at least 14% alcohol . 
(3) As the product has a low risk profile and the IHS EGGPRODS.GEN  is for egg products that generally 
require certification and MPI assessment, the RMP proposes that the import requirements for this 
commodity are  placed in the IHS SPECPROD.ALL .  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 6 4.9 Mayonnaise and salad dressing  
4.9.1 Mayonnaise and salad dressing containing no more than 20% egg ingredient  - clause 2.4.2  
of the IHS  
(1) Mayonnaise and salad dressi ngs containing no more than 20% egg ingredient are currently imported 
under the  IHS EGGPRODS.GEN . These requirements will be transferred to the IHS SPECPROD.ALL .  
(2) The RRA: Miscellaneous Egg Products for Human Consumption  2014 included an assessment of the risks 
associated with  mayonnaise  and salad dressing containing no more than 20% egg ingredient . 
(3) This clause is only applicable to products  in retail packag ing.  
(4) Mayonnaise and salad dressings that are not in retail ready packing or that contain more than 20% egg 
ingredients can be import ed under the IHS EGGPRODS.GEN .  
4.10 Mooncakes  
4.10.1  Mooncake s with discernible whole egg  - clause 2.4.3 of the IHS  
(1) Mooncakes with discernible whole egg  are currently import ed under the  IHS EGGPRODS.GEN . These 
requirements will be transferred to the IHS SPECPROD.ALL .  
4.11 Insect and arachnid- based food products  
4.11.1  Insect and arachnid -based food products for human consumption (excluding bee 
products) - clause 2. 5 of the IHS  
(1) Bee products (e.g. bee larva) are not eligible under the provision for ‘insect and arachnid -based food 
products’. The wording ‘excluding bee prod ucts’ has been added to the title.  
4.12 Processed foods containing meat -based ingredients  
4.12.1  Meat-based ingredients or meat floss  - clause 2. 6.2(1) and 2. 6.2(2) of the IHS  
(1) It is intended that meat -based ingredients or meat floss do not contain discernible meat pieces . This has 
been in the IHS as guidance information. As it is a requirement, it is now in the body of the IHS in clause 
2.6.2(1)a) and 2. 6.2(2)a).  
(2) It has been made clear in the provision that meat -based ingredients mean broth, concen trate, meat 
extract, rendered fat, flavours, stock , or tallow.  
(3) Importers’ and MPI internal feedback indicate that the requirement ‘the product is not in bulk form’ is 
unclear.  This requirement  intends to limit the exposure pathway of  meat -based ingredient s and meat floss  
by limiting this product to small household quantities.   
(4) To clarify this intent, ‘the product is not in bulk form’ has been replaced by  ‘the product is commercially 
manufactured into retail packaging’ , and a definition for  retail  packaging  has been added. The wording 
‘household ’ has been inserted  to ensure the products are of small household quantities . Clause 
2.6.2(2) d)i)2) reads ‘ the product is commercially manufactured into retail packaging for u se as an 
ingredient in the house hold preparation of food for human consumption’ .  
(5) If the meat- based ingredients or  meat  floss are not able to meet the  retail packaging requirement s, they 
may be accompanied by an import permit and directed to a transitional facility approved to Facility 
Standard: Transitional Facilities for Animal Products , MPI -STD-ANIPRODS  where the product may  be 
commercially  manufactured  into retail packaging  for direct human consumption , or use as an ingredient in 
the household preparation of food for human consumption.  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 7 5 Recommendations for other goods containing animal 
products  
5.1 Bile  
5.1.1 Bile derivatives, and bovine and ovine concentrated bile –  clause 3.1 of the IHS  
(1) The MPI Technical Advice on Processed Bovine and Ovine Bile  (TA, dated 2 Oct 2019) considered the 
following industrial processes for  bovine and ovine bile :  
a) Heat treatment at a minimum of 100 degrees Celsius for a minimum of 8 hours; and  
b) Treatment with sodium hydroxide . 
(2) The existing import requirements for  bovine and ovine concentrated bile in the IHS SPECPROD.ALL  are 
as follow s: 
a) Bovine and ovine concentrated bile may be imported from any country provided the product is 
accompanied by 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 undergone a  heat treatment of 100 °C for a minimum of 8 hours.  
iii) Has been treated with sodium hydroxide.  
iv) Has been managed in a way that prevents contamination prior to dispatch from the processing 
premises.  
v) Is in packaging that is clean and free from visible signs of co ntamination  
(3) Of all the hazards  identified in the TA , Rift Valley fever virus (RVFV) and bovine spongiform 
encephalopathy (BSE) prion may remain after the heat treatment as described in clause  5.1.1(1)a). The 
TA states that the subsequent t reatment with sod ium hydroxide  will inactivate RVFV and BSE  prion . 
(4) Regarding RVFV,  since the publication of the TA, the WOAH has updated the disease card for Rift Valley 
fever (woah.org) , which states that the ‘virus is destroyed by heat treatment of serum for 120 minutes at 
56°C ’. The h eat treatment as described in clause 5.1.1(1)a) is sufficient  to inactivat e RVFV . 
(5) Regarding BSE, a New Zealand importer has submitted to MPI that bile does not carry BSE/TSE risk as bile is considered in the WHO Guidelines on Tissue Infectivity Distribution in Transmissible Spongiform 
Encephalopathies  (WHO Guidelines, 2006) as a  tissue with no detectable infectivity. The importer’s 
submission is f urther  supported by  an expert report , where t he author  argues that ‘PrPC is barely 
detectable in liver, which means that PrPSC would be unlikely to be present because it is made in vivo by a 
PrPC→PrPSC conformational change and if PrPC is not expressed PrPSC cannot be formed ’. 
(6) Considering the se arguments , the RMP recommends  the treatment with sodium hydroxide be removed.  
(7) The existing import requirement for bile derivatives allows bile derivatives from  any species to be imported 
from any country, without offic ial certification. This has been discussed in clause 6.1 of the RMP 
SPECPROD.ALL  25 June 2020.  
(8) As bile derivatives are derived from conc entrated bile, the same certification requirements for 
concentrated bile may be applied to bile derivatives.  
(9) MPI proposes that bile derivatives, and bovine and ovine concentrated bile may be imported from any 
country provided the product is accompanied by  an official certificate that states the product:  
a) Has been collected from animals that have passed ante - and post -mortem inspection at premises 
with competent authority oversight;  
b) Has undergone a heat treatment of 100°C for a minimum of 8 hours;  
c) Has been m anaged in a way that prevents contamination before dispatch from the processing 
premises; and  
d) Is in packaging that is clean and free from visible signs of contamination.  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 8 5.2 Dicalcium phosphate  
5.2.1 Dicalcium phosphate -  clause 3. 2 of the IHS  
(1) According to the BSE chapter of the  WOAH  Terrestrial Animal Health Code  (the Code ), dicalcium 
phosphate with no trace of protein or fat  does not carry BSE risk.  
(2) MPI considers an official certificate attesting the product has no trace of protein or fat is required for 
biosecurity clearance . 
(3) The RMP propose s that  dicalcium phosphate derived from degreased bones from any country may be 
imported provided it is accompanied by an official certificate stating that it has no trace of protein or fat . 
5.3 Gelatine  
5.3.1 Gelatine and gelatine  products - clause 3.4 of the IHS  
(1) Edible gelatine and inedible gelatine have the same import requirements. Both requirements have been 
combined and placed in Part 3  of the IHS.  
(2) Products containing gelatine are eligible for importation. Gelatine products have been added to the title of 
the commodity.  
5.4 Non-viable animal specimens  
5.4.1 Non-viable animal specimens - clause 3.6 of the IHS  
(1) When MPI reviewed import requirements for non -viable animal specimens  in the  IHS for Nonviable Animal 
Specimens from All Countries, IHS INESPEIC.ALL , the reviewed im port requirements were  incorporated 
into the IHS for Personal Consignments of Animal Products,  PERSONAL.ALL , in December 2019 . The 
RMP PERSONAL.ALL  has more details . The  IHS INESPEIC.ALL was subsequently revoked.  
(2) The same import provisions for personal consignments of non- viable animal specimens from the IHS 
PERSONAL.ALL  have been assessed as appropriate risk mitigation measures for c ommercial 
consignments  of non- viable animal specimens. These provisions have been incorporated into the IHS 
SPECPROD.ALL  to allow for commercial imports.  
5.5 Specified items   
5.5.1 Specified items of animal origin including game trophies  - clause 3.7 of the IHS  
(1) Existing import provisions for ornamental products of animal origin  (see definition in Schedule 2 of the IHS 
SPECPROD.ALL ) from clause 3.1 of the IHS INETROIC.ALL  have been reviewed . While p ersonal 
consignments of ornamental products of animal origin have already been  incorporated into  the IHS 
PERSONAL.ALL , the remaining provisions for commercial consignments of ornamental products  of animal 
origin have now been revie wed and added to the IHS SPECPROD.ALL . Import requirements  remain 
unchanged.  The IHS INETROIC.ALL  will be revoked as a result.  
(2) Goldbeater’s  skin is a shelf -stable, commercially manufactured item made of the outer membrane of the 
intestine of cattle. It is highly processed and is neither used for human nor animal consumption. 
Biosecurity risk of commercial consignments of goldbeater’s skin is negligible, and the product is eligible 
for importation.  
(3) Commercially manufactured parchment and vellum could be imported under the IHS INEPROIC.ALL . It 
has now be en added into the IHS SPECPROD.ALL . Import requirements remain unchanged.  
(4) The e xisting import provision for l anolin and lanolin- based products  from the IHS ANIFIBRE.GEN  has 
been added to the IHS SPECPROD.ALL . Import requirements remain unchanged.  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 9 (5) Commodities  discussed in clause 5. 5.1 (1) – ( 4) are required to be commercially manufactured and are 
grouped together  as ‘commercially manufactured specified items of animal origin ’ in the IHS 
SPECPROD.ALL . 
(6) Animal skin/hide glue is an existing  import  provisio n in the IHS SPECPROD.ALL . It is appropriate to group  
it under c ommercially manufactured specified items of animal origi n. 
(7) Existing import provisions  from the IHS INETROIC.ALL  for game trophy animal parts  (skulls, horns, 
hooves, antlers, bones, tusks, claws, and teeth ) from all countries  are as foll ows: 
a) All imported consignments of game trophy skulls, horns, hooves, antlers, bones, tusks, claws, and 
teeth must be:  
i) mounted; or  
ii) professionally cleaned and processed to a high standard of whiteness; or  
iii) accompanied by a manufacturer’s declaration verifying that they have been boiled at a minimum of 100°C for at least 30 minutes, and packaged immediately after treatment in a manner s o as to ensure that there is no subsequent contamination with untreated goods of a 
similar nature; or  
b) All imported consignments of unmounted game trophy skulls, horns, hooves, antlers, bones, tusks, 
claws, and teeth must free of extraneous organic material , pest infestation, and evidence of decay 
on arrival.  
(8) Beaks are a commonly imported commodity and are eligible for importation if meeting existing requirements described above.  
(9) Operationally, all game trophies are inspected on arrival to ensure they are c lean and free from visible 
contamination. If they are found non -compliant, i.e. contaminated, they may either be treated onshore in 
accordance with Approved Biosecurity Treatments  (MPI -ABTRT) , reshipped , or destroyed.  The 
requirements as described in 5.5 .1(7)a)iii) are therefore redundant and have been removed. The heat 
treatment of boiling at a minimum of 100°C for at least 30 minutes will remai n for treat ing non-compliant 
consignments  of game trophies . 
(10) New Zealand has a veterinary certificate for commercial consignments of game trophies agreed with the 
EU. This certificate from the G uidance D ocument (GD)  INETROIC.ALL . has  now  been added to Schedule 
6 of the IHS SPECPROD.ALL . The provision for game troph ies from the EU has been added to clause 3.6 
of the IHS.  
(11) In addition to the game trophy animal parts as discussed in 5. 5.1(7) and ( 8), other  existing import 
provisions for ornamental products from clause 3.1 of the IHS INETROIC.ALL have been reviewed and 
the measures remain unch anged.  
(12) The RMP proposes that commodities  a) to g) below may be imported provided they are  clean, free from 
visible contamination (see definition in Schedule 2  of the IHS SPECPROD.ALL ) and meet any additional 
requirements  specified below.  Except for the co mmodities in  a), the import requirements for commodities  
b) to g)  remain unchanged.  
a) Antlers, beaks, bones, claws, hooves, horns, skulls, teeth, and tusks (either mounted or unmounted).  
b) Coral that is non -viable and dry.  
c) Egg shell ornaments (including blown eggs).  
d) Finished game trophies (see definition in Schedule 2  of the IHS SPECPROD.ALL ).  
e) Fly-tying material containing animal skin and/or hair that is dyed.  
f) Shells (terrestrial and marine) and marine ornaments that are dry.  
g) Rawhide articles and handicrafts.  
5.6 Specified porcine enzymes  
5.6.1 Specified porcine enzymes -  clause 3. 8 of the IHS  
(1) Porcine enzymes pancreatin and pepsin are currently eligible for importation from Australia.  Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 10 (2) To ascertain the animal product origin, a new subclause has been added to require that the country of 
origin ( i.e. Australia) is evident on product packaging or labelling.  
5.7 Tallow an d its derivatives  
5.7.1 Tallow and its derivatives - clause 3. 9 of the IHS  
(1) According to the BSE chapter of the  Code, tallow and its derivatives with a maximum level of insoluble 
impurities of 0.15% in weight does not carry  BSE risk .  
(2) MPI considers an official certificate attesting the maximum level of insoluble impurities of 0.15% in weight 
is required for biosecurity clearance.  
(3) The following provision has been added: t allow and its derivatives from any country may be imported 
provided they are  accompanied by an official certificate stating that the maximum level of insoluble 
impurities is 0.15% in weight . 
5.8 Therapeutic products and dietary supplements 
5.8.1 Therapeutic products and dietary supplements  for human use (excluding bee products)  - 
clause 3. 10 of the I HS 
(1) Therapeutic products and dietary supplements for human use that are in retail packaging ha ve a negligible 
risk exposure pathway. Products that are in retail packaging are also commercially manufactured. The requirement that  products are commercially manufactured has therefore been replaced by in retail 
packaging.  
(2) As therapeutic products and dieta ry supplements in retail packaging have a negligible risk  exposure 
pathway, MPI will remove the requirement that the product is in a certain form -  pills, tablets, capsules, 
liquids, syrups, oils, or medicated plasters.  
   Risk Management Proposal:  Specified Animal Products  14 December 2022  
Ministry for Primary Industries   Page 11 Appendix 1 – Document History  
Date First Issued  Title Shortcode  
14 December 2022  
 Risk Management Proposal: Specified 
Animal Products  RMP SPECPROD.ALL  
Date of Issued A mendments  Title Shortcode