Risk Management P roposal   
Amendment to I mport Health Standard  for Specified 
Foods for Human Consumption  Containing Animal 
Products  
 
EDIPROIC.ALL  
 
 
 
 
 
 
 
 
 
 
 
28 January  2014    
 
  
 
 
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.  
 
 
Requests for further copies should be directed to:  
 
Ministry for Primary Industries  
Standards Branch  
Animal Imports  
PO Box 2526  
WELLINGTON 6140  
 
Email:   animalimports@mpi.govt.nz  
Telephone:  04 890 0134  
Facsimile:  04 894 0733  
 
 
 
© Crown Copyright - Ministry for Primary Industries   
i Contents  Page 
 
1 Purpose  1 
2 Background  1 
3 Objective  1 
4 Recommendations for identified risk items  1 
4.1 Meat Jerky  Error! Bookmark not defined.  
4.2 Dairy Products  2 
4.3 Mayonnaise and Salad Dressings Containing Egg  3 
4.4 Mooncakes  3 
4.5 Muscle Protein Powders  4 
4.6 Pork Crackling  5 
4.7 Products Containing Egg Ingredients  6 
4.8 Private Consignments of Meat and Meat Products from Specified Countries  6 
4.9 Tea Bags Contai ning Honey  6 
  
Ministry for Primary Industries   Risk Management Proposal for Changes to EDIPROIC.ALL  
 1 1 Purpose  
The purpose of this document is to:  
 show how options for the management of some potential risk items have been assessed; and  
 provide recommendations for amended import requirements .  
 
2 Background  
Amendments are made to Import Health Standards (IHS)  as required to reflect changes in biosecurity 
needs and products being imported into New Zealand . The IHS for Specified Foods for Human 
Consumpt ion Containing Animal Products, EDIPROIC.ALL  (new shortcode EDIPROIC.GEN).  
http://www.biosecurity.govt.nz/imports/animals/standards/ediproic.all.htm  is being updated following 
appropriate risk decisions on specified foods for human consumption.   
 
All risk decisions in this document are derived from rapid risk asse ssments conducted at MPI or 
changes in international trade processes for each specific item listed below.  
 
3 Objective  
The objective for amending this IHS is to effectively manage biosecurity risks associated with the import 
of specified foods for human consumption containing animal products, consistent with New Zealand’s 
domestic legislation and international obligations.  
 
4 Recommendations for identified risk items  
Rapid r isk assessments have recently been conducted for a number of specified risk items  included in 
the IHS EDIPROIC. ALL. These are summari sed below.  
4.1 DRIED CURED MEAT  
 
Private consignments of commercially prepared beef jerky are currently permitted for importation from 
the USA, Canada, European Union, Australia, Vanuatu and Finland under EDIPROIC .ALL provided:  
 
i. The product is commercially prepared and packaged . 
ii. The produc t is in its original sealed packaging on arrival . 
iii. The country of origin is identifiable from the packaging .  
iv. The total weight of the consignment is 20 kilograms or less.  
 
Many meat jerky products use meat from other countries, making it im possible to determine the origin of 
the imported meat from the package label.  This makes it difficult for border staff to adequately assess 
biosecurity risks associated with this commodity.  
 
Meat  jerky and other dried cured meat products such as biltong a nd prosciutto ham  are high value (~NZ 
$10 per 100 grams), shelf stable product s which are normally sold in snack quantities of a few hundred 
grams. These factors reduce the likelihood of environmental contamination as very little wastage is 
expected.  
  
2 
 Risk Management Proposal –Amendment to EDIPROIC.ALL  Ministry for Primary Industries  The high value, long shelf life and a weight restriction reduced to a single k ilogram per person for 
private consignments of dried cured meat from mammalian, avian and reptilian sources would result in a 
negligible likelihood of environmental exposure.  
 
4.1.1 Recom mendation:  
It is propos ed that p rivate consignments of dried cured meat may be given biosecurity clearance from all 
countries  provided:  
 
i. The product is commercially prepared and packaged . 
ii. The product is in its original sealed packaging on arrival . 
iii. The total weight of the consignment is 1 kilogram or less . 
 
 
4.2 DAIRY PRODUCTS  
Private consignments of non-shelf stable dairy products and products containing dairy ingredients are 
currently permitted from specifi ed countries under  EDIPROIC .ALL provided:  
i. The product is  commercially prepared and packaged . 
ii. The product is in its original sealed packaging on arrival . 
iii. The country of origin is identifiable from the packaging . 
iv. The total weight of the consignment is 20 kilograms or less . 
The majority of commercially prepared dairy products are subjected to pasteurisation  (72°C for 15 
seconds) . Pasteurisation has been shown to virtually eliminate pathogen s and reduce virus titre s. The 
most notable virus that can be transmitted in milk is fo ot and mouth disease virus (FMDV) . After 
pasteuri sation , the titre of FMDV is reduced to such a level that the animal biosecurity risk can be 
considered negligible . 
A small proportion of dairy products are made using raw (un -pasteurised) milk which could possibly  
transmit pathogens of concern. The European Union only permits the trade in raw milk cheese after it 
has been aged for 60 days to help mitigate the risk of spreading FMDV. Since the manufacturing 
process is unlikely to inactivate FMDV in raw milk products and also due to the ability of dairy products 
to be consumed by susceptible species, additional risk management measures are required.  
For dairy products that are not adequately heat treated the most practical measure that will still allow 
import ation of genuine private consignments to occur while also reducing the biosecurity risk to an 
acceptable level  is to place limits on the quantity permitted for importation. This limit will reduce the 
likelihood of a dairy product being fed directly to anim als and also simultaneously reduce the amount of 
wastage, as the product is more likely to be highly valued due to its scarcity (e.g. specialty cheeses). At 
present up to 20 kilograms of dairy products may be imported from specified countries, and if this was 
reduced, (2 kilograms is suggested), dairy products from all countries could be permitted for importation.   
As the manufacturing process may not mitigate the biosecurity risk, a lower  import weight restriction (2 
kilograms) is proposed to reduce the a nimal biosecurity risk to an acceptable level whilst allowing 
private importation of dairy products to occur irrespective of the country of origin.  
Concern has also been raised within MPI that this standard should not be used for the importation of 
product s that contain live microorganisms such as yoghurt or raw milk, that are intended as samples for  
Ministry for Primary Industries   Risk Management Proposal for Changes to EDIPROIC.ALL  
 3 industry or laboratory use. The standard will clarify that import for these uses is not possible in this 
standard.  
4.2.1 Recommendation:  
It is proposed that private  consignments  of non-shelf stable dairy products and products containing dairy 
ingredients may be imported into New Zealand provided all the following requirements are met:  
a) The product is commercially prepared and packaged . 
b) The product is in its original se aled packaging on arrival . 
c) The country of origin is clearly indicated from the packaging . 
a) The product is not for biological or microbiological analysis . 
b) The total weight of the consignment is  two (2) kilograms or less . 
 
4.3 MAYONNAISE AND SALAD DRESSINGS CONTAINING EGG 
Currently, commercially prepared mayonnaise and salad dressing containing egg may be imported from 
Australia, the European Union, Japan and the US under EDIPROIC.ALL provided:  
 
i. The product is shelf -stable . 
ii. The product is commercially prepared and packaged . 
iii. The product is in its original sealed packaging on arrival . 
iv. The county of origin is identifiable from the packaging.  
 
Pasteurisation of egg products and the acidic pH of mayonnaise/salad dr essing are likely to reduce the 
titre of pathogens within th is commo dity. However, some residual pathogens are likely to remain. 
Limiting the amount imported for human consumption is an additional risk management measure which 
will further reduce the animal biosecurity exposure risk to an acceptably low level.  
 
4.3.1 Recommenda tion:  
It is proposed that private consignments of mayonnaise and salad dressing containing egg may be 
imported provided all of the following requirements are met:  
a) The product is shelf -stable.  
b) The product is commercially prepared and packaged.  
c) The product is in its original sealed packaging on arrival.  
d) The total weight of the consignment:  
i) Is unlimited for products originating from Australia, Canada, the European Union, 
Japan or the United States; or  
ii) For products originating from all other countries is 1 ki logram or less.  
Guidance - Commercial consignments of mayonnaise and salad dressings must meet conditions 
specified in Clause 3.1.22 or the Import Health Standard POUEGGIC.SPE 
http://www.biosecurity.govt.nz/imports/animals/standards/poueggic.spe.htm  
 
4.4 MOONCAKES  
Mooncakes are commercially imported into New Zealand under  EDIPROIC.ALL , which permits 
biosecurity clearance to be given to commercially manufactured mooncakes pro vided that :  
 
i. The product is shelf -stable   
ii. The product does not contain any meat and/or meat product fillings .  
iii. The product is commercially prepared and packaged .   
4 
 Risk Management Proposal –Amendment to EDIPROIC.ALL  Ministry for Primary Industries  iv. The product is in its origi nal sealed packaging on arrival.  
v. The product must be accompanied by a manufacturer’s declaration stating that the product 
reached a core temperature greater than 60 ºC for no less than 3.5 minutes.  
 
However, private consignments without manufacturer’s declarations are arriving at the bor der either 
accompanying passengers or sent as gifts.  
 
Once cooked, mooncakes do not require refrigeration and can be considered a shelf stable product.  
 
Mooncakes are a seasonal product associated with the Mid -Autumn Festival in September/October 
each yea r. The quantity imported over an entire year is expected to be low.  Mooncakes can be viewed 
as a ‘ceremonial’ product with sentimental value and are therefore unlikely to be wasted or discarded, 
making it highly unlikely that the products would be either intentionally or inadvertently fed to birds.  
 
The combination of the heat treatment applied , low quantities being imported due to their seasonal 
nature and the low probability of mooncakes containing egg being fed to birds , reduce the risk  
presented by  egg mooncakes  to an acceptably low level.  
 
4.4.1 Recommendation:  
It is propos ed that private consignments (up to 10 kg) of commercially prepared and packaged 
mooncakes containing egg may be imported without requiring a manufacturer’s declaration , provided 
that the following are met:   
 
i. The product is shelf -stable . 
i. The product does not contain any meat and/or meat product fillings . 
ii. The product is commercially prepared and packaged . 
iii. The product is in its original sealed packaging on arrival . 
iv. The product is limited to 1 0kg per private consignment . 
 
4.5 MUSCLE PROTEIN POWDERS  
Private consignments  of muscle protein powders containing dairy and egg products  from Australia, 
USA, Canada, and the European Union  may be given biosecurity clearance under EDIPROIC.ALL , 
provided the following requirements are met:   
i. The product is shelf stable . 
ii. The product is com mercially packaged and prepared.  
iii. The product is in its original sealed packaging on arrival . 
iv. The country of origin is identifiable from the packaging . 
v. The total weight of the cons ignment is 20 kilograms or less . 
 
This has previ ously been compared to the clause in EDIPROIC.ALL that allows biosecurity clearance of 
cake, pudding, sauce and baking mixtures containing  dairy  and/or egg ingredients  from any country  
provided all the follow ing requirements are met:  
 
i. The product is shelf -stable . 
ii. The product is commercially prepared and packaged . 
iii. The ingredients are homogenously mixed/distributed in the mixture . 
iv. The product is in its original sealed packaging on arrival.  
  
Ministry for Primary Industries   Risk Management Proposal for Changes to EDIPROIC.ALL  
 5 This comparison/combination of clauses has led to the previous decision that protein powder from any 
country and of commercial quantity can be released, provided it is shelf stable, and commercially 
prepared and packaged.  
 
Dairy (whey) powder , which const itutes the major ingredient in whey muscle protein powder , is exposed 
to a sufficient time temperature regime (pasteurisation) that pathogens of concern are likely to be 
inactivated. In the very unlikely event that calves or pigs were exposed to pasteurise d whey powder  
from animals infected with FMDV , they would have to consume at least 20 times more than the animal 
can physically consume  to receive an infectious dose . 
  
The amount of egg powder (whole egg or egg albumen) present in whey muscle protein powd er is 
generally low, but egg albumen is the main ingredient in egg muscle protein powders.  As discussed in 
the IRA for egg powders1, during manufacture whole egg powder is heat ed for at least 3.5 minutes at 
60°C and egg albumen is heat ed for at least 7 day s at 54.4°C. An additional heat treatment step, 
however, is applied to all types of egg powders during the spray drying process and this usually involves 
an inlet temperature of 155°C to 175°C and outlet temperature of 70°C to 80°C . This would be 
expected to further reduce the titre of any residual virus. It is expected that  most muscle protein 
powders will be directly consumed by humans and very little wastage should be produced as this 
product is shelf stable and of high value.  
 
Due to the various heat treatments applied to dairy ingredients and the lack of an exposure pathway for 
egg powders, the biosecurity risk associated with muscle protein powders is considered to be very low.  
4.5.1 Recommendation:  
It is proposed that m uscle protein powders containing dairy and/or egg products can continue to be 
imported into New Zealand  from all countries  in personal or commercial quantities provided the following 
requirements are met:  
 
i. The product is shelf -stable . 
ii. The product is commercially prepared  and packaged . 
iii. The ingredients are homogenously mixed/distributed in the mixture . 
iv. The product is in its original sealed packaging on arrival.  
 
4.6 PORK CRACKLING  
Private consignments of c ommercially prepared pork crackling currently enter New Zealand under 
EDIPR OIC.ALL , provided that:  
 
i. The product is shelf -stable . 
ii. The product is com mercially prepared and packaged.  
iii. The product is in its original sealed packaging on arrival . 
 
Commercial consignments require a manufacturer ’s declaration which shows retort to the proc essing 
standard Fo3 .  
 
Private consignments of pork crackling are likely to be imported in low volumes . Due to the heat 
treatment applied during the commercial manufacturing process it is unlikely that an infectious agent 
would be introduced into New Zeala nd by this commodity.  
                                                
1  Import Risk Analysis: Egg powders from all countries, MAF Biosecurity Publication October 21, 2008 (28 pp)   
http://www.biosecurity.govt.nz/files/regs/imports/risk/egg -powder -ra.pdf  
  
6 
 Risk Management Proposal –Amendment to EDIPROIC.ALL  Ministry for Primary Industries  4.6.1 Recommendation:  
It is proposed that p rivate consignments of commercially prepared pork crackling should continue to be 
permitted importation into New Zealand without a manufacturer ’s declaration.  
 
4.7 PRODUCTS CONTAINING EGG INGREDIENTS  
 
Under EDIPROIC.ALL , products containing egg in quantities greater than 5% are not eligible for  
clearance .  
 
As discussed in the IRA for egg powders f rom all countries , sufficient heat treatment has been 
demonstrated to destroy risk organisms  including avian influenza virus and Newcastle disease virus . 
Angara disease  has likewise been shown to be heat labile at sufficient times and temperatures . 
 
4.7.1 Recommendation:  
It is proposed that p roducts containing pasteurised egg in quantities greater than 5% and les s than 21% 
may be given clearance provided that the following requirements are met:  
The product(s) must be accompanied by a manufacturer’s declaration specifying that at any 
stage of the manufacturing process, the eggs must have undergone a minimum heat 
treatment of  
i 60 degrees Celsius for no less than 1 hour, or  
ii 80 degrees Celsius for no less than 10 minutes, or  
iii 100 degrees Celsius for no less than 5 minutes.  
 
4.8 PRIVATE CONSIGNMENTS OF MEAT  AND MEAT PRODUCTS FR OM 
SPECIFIED COUNTRIES  
Private consignments of specified meat and meat products from specified countries may be given 
biosecurity clearance under EDIPROIC .ALL.  
 
As Finland and Sweden are both free of Porcine Reproductive and Respiratory Syndrome Virus 
(PRRS), these two countrie s will be added to the table for meat products in EPIPROIC.ALL in a 
separate column . Private consignments of pork from Australia, Finland and Sweden are eligible for 
clearance if all of the conditions pertaining to meat imports are met.  
 
4.8.1 Recommendation:  
It is proposed that Norway and Switzerland will be added to the column for the European Union (EU), as 
disease risks for these countries are equivalent with those of the EU.  
 
4.9 PRIVATE CONSIGNMENTS  OF TEA BAGS CONTAINING HONEY  
Commercial consignments of t eabags containing honey may be imported into New Zealand under the 
IHS for specified processed bee products  (BEEPROIC.ALL) , which permits biosecurity clearance be 
given for commercially manufactured teabags containing honey provided that :  
 
i. The product must be commercially prepared and packaged ; and  
ii. The product must be;  either   
Ministry for Primary Industries   Risk Management Proposal for Changes to EDIPROIC.ALL  
 7 a. Accompanied by a manufacturer’s declaration certifying that the product contains less 
than 2% honey ; or 
b. Accompanied by a permit to import . 
 
The concentration of honey in commercially manufactured tea bags in personal consignments is likely to 
be similar to that of teabags which are permitted to be imported for commercial sale (≤ 2%).  This , 
combined with the low quantities being proposed for private importation makes it  unlikely that this 
commodity will be discarded without being used. The exposure pathway for bees in New Zealand can 
therefore be assessed as negligible . 
 
4.9.1 Recommendation : 
It is propos ed that private consignments of tea bags containing honey may be given bi osecurity 
clearance provided:  
 
i. The product is commercially prepared and packaged . 
ii. The product is in its original sealed packaging on arrival . 
iii. A maximum of one box (50 servings or less) per passenger is imported .