Risk Management Proposal  
Aquatic Animal Products  
AQUAPROD.GEN  
[Document Date]  Risk Management Proposal:  Aquatic Animal Products  [Document Date ] 
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)  
Biosecurity New Zealand  
Animal Imports  
PO Box 2526  
Wellington 6140  
Email: animal.imports@mpi.govt.nz  Risk Management Proposal:  Aquatic Animal Products  [Document Date ] 
Ministry for Primary Industries   Page 2  
Contents  
1 Purpose  3 
2 Background  3 
3 General Recommendations  3 
3.1 Straddling fish from Australia  3 
3.2 Aquatic animal product imports from Australia  4 
3.3 Low-risk fish products  4 
3.4 Government -endorsed manufacturer’s declaration  5 
3.5 Angiostrongylus cantonensis  reassessment  5 
3.6 Health certification not required for fish imported for further processing  6 
3.7 Bill of lading for freezing duration d etermination  6 
3.8 Annelid products  6 
3.9 Composite products  6 
3.10  Transition period  6 
3.11  Rephrasing for clarity  6 
3.12  Corrigenda  7 
Appendix 1 – Document History  8 
 
  
Ministry for Primary Industries   Page 3 1 Purpose  
(1) The purpose of this document is to:  
a) Show the updated risk management decisions for the Import Health Standard  (IHS) : Aquatic Animal 
Products, AQUAPROD.GEN . 
2 Background  
(1) IHS AQUAPROD.GEN  was issued on 11 May 2022. Since then, the Animal Imports team has received 
feedback prompting the amendment of the IHS to clarify some biosecurity import requirements and add 
new product categories.  The 11 May 2022 version of IHS AQUAPROD.GEN  can be foun d here: 
https://www.mpi.govt.nz/dmsdocument/51229 -Aquatic -Animal -Products -Import -health -standard . 
(2) This Risk Management Proposal (RMP) contains discussi on of new or updated risk management 
decisions. The 11 May 2022  version of RMP AQUAPROD.GEN  can be found here: 
https://www.mpi.govt.nz/dmsdocument/51 235-Aquatic -Animal -Products -Risk-Management -Proposal . 
3 General Recommendations  
3.1 Straddling fish from Australia  
(1) The Ministry for Primary Industries (MPI) proposes amending the fishery areas indicated in Clause 2.2.1 of 
the 11 May 2022 version of IHS AQUAPROD. GEN . This amendment is being made following  technical 
advice pertaining to fish present in the water areas shared between Australia and New Zealand.  The 
product category name has also been updated to include the word “straddling” to reflect the clause’s 
intent.  
 
Fisheries as presented in Clause 2.2.1 of IHS 
AQUAPROD.GEN, dated 11 May 2022  Fisheries as presented in the proposed 
amended version of IHS A QUAPROD.GEN  
a) The Commonwealth East Coast Deepwater 
Fishery  
b) The Commonwealth Scalefish Hook Sector  a) Lord Howe Rise Deepwater Fishery : 
The boundary for this fishery is included 
Schedule 2  of the proposed IHS as follows: The 
area covering the waters south of the fishery’s 
northern boundary at a line at 154° 40’ 04” East 
and 24° 29” 54” South, following the Australian 
Fishing Zone boundary to include Lord Howe 
Island, and intersect with a li ne from the 
Australian Fishing Zone boundary at 33° 34’ 54” 
South to the coast, excluding the inshore waters 
managed by the State Governments of Australia 
and the inshore areas of the Commonwealth 
Southeast Trawl Sector . 
b) Macquarie Island Fishery Zone : 
The boundary for this fishery is included 
Schedule 2  of the proposed IHS as follows: The 
area covering the waters within a 200 nautical 
mile radius of Macquarie Island, south of the 
New Zealand Exclusive Economic Zone . 
  
Ministry for Primary Industries   Page 4 3.2 Aquatic animal product  import s from  Australia  
(1) Recognising that Australia’s import biosecurity requirements and systems and domestic regulatory 
requirements for manufacturing aquatic animal products  are very similar to New Zealand’s, and the 
agreement to reduce unnecessary barriers to trade  between our countries , documentation requirements  
for product s manufactured in Australia and imported into Australia  have been reviewed . 
(2) Processed  product categories under clauses 2.2.1  (Non -salmonid straddling fish from Australia) , 2.2.3  
(Low-risk non -salmonid fish products from any country ), 2.2.5  (Non-salmonid fish skin -off fillets ), 2.2.6  
(Heat -treated non -salmonid fish products ), 2.2.7  (Dried non -salmonid fish products ), 2.2.8  (Non-salmonid 
fish products commercially packaged for direct retail sale ), 2.3.2  (Heat -treated crustacean products ), 2.3.3  
(Frozen crustacean products ), 2.3.4  (Crustacean products commercially packaged for direct retail sale ), 
2.4.1  (Haliotis  spp. (abalone) pro ducts ), 2.4.2  (Mollusc products other than Haliotis  spp. (abalone) ), and 
2.9 (Aquatic animal meal and aquatic animal oil ) of the amended version of IHS AQUAPROD.GEN  can be 
considered for import ation based on an exporter’s declaratio n. 
(3) A model exporter’s declaration has been included in the Guidance Document accompanying the updated 
IHS. 
3.3 Low-risk fish products  
(1) Some exporting countries commented that certain fish species migrate through New Zealand’s 
international waters, making biosecurity requirements for these meaningless.  
(2) To address this issue , MPI completed the Technical Advice on Risks Associated with Imports of Whole or 
Processed Highly Migratory Finfish for Human Consumption . 
(3) MPI prop oses amending Schedules 4  and 6 to add fish species in alignment with this technical advice. 
The amended  schedules are applicable under clause 2.2.3 (Low-risk non -salmonid fish products from any 
country ) of IHS AQUAPROD.GEN . 
(4) Schedule 4  lists the following fish species that can be imported in whole  form from all countries because 
they are highly migratory : 
 
1. Alopias superciliosus  2. Auxis rochei  
3. Auxis thazard  4. Brama brama  
5. Carcharhinus brachyurus  6. Carcharhinus falciformis  
7. Carcharhinus galapagensis  8. Carcharhinus longimanus  
9. Cetorhinus maximus  10. Cololabis adocetus  
11. Coryphaena equiselis  12. Coryphaena hippurus  
13. Euthunnus affinis  14. Galeocerdo cuvier  
15. Hexanchus griseus  16. Istiompax [Makaira] indica  
17. Istiophorus platypterus  18. Isurus oxyrinchus  
19. Isurus paucus  20. Kajikia [T etrapterus] audax  
21. Katsuwonus pelamis  22. Lamna nasus  
23. Lampris guttatus  24. Lampris immaculatus  
25. Makaira mazara  26. Makaira nigricans  
27. Prionace glauca  28. Rhinocodon typus  
29. Sphyrna zygaena  30. Tetrapturus angustirostris  
31. Thunnus alalunga  32. Thunnus albacares  
33. Thunnus maccoyii  34. Thunnus obesus  
35. Thunnus orientalis  36. Xiphias gladius  
 
In IHS AQUAPROD.GEN , 11 May 2022 , Schedule 4 erroneously listed certain fish families. These families 
have now been removed and replaced entirely by the fish species listed above.  Ministry for Primary Industries  Page 5 (5) Schedule 6 , which list s fish species that c an be imported in whole form from all countries provided they
are frozen to a minimum core temperature of -18°C for a period of not less than four months,  will now
include only Euthynnus alletteratus, Sarda chilensis, Sarda lin eolate , and Sarda sarda . The other fish
species that were previously in this schedule, namely, Auxis rochei, Auxis thazard, Katsuwonas pelamis,
and Thunnus obesus , were assessed as highly migratory, so will now be listed under Schedule 4.
3.4 Government -endorsed manufacturer’s declaration  
(1) Some exporting countries have indicated that they are unable to issue health certification because of their
regulatory systems used for aquatic animal products. For these countries, MPI is proposing government
endorsement of a manufacturing declaration as an option for processed aquatic animal products covered
under clauses 2.2.3  (Low -risk non -salmonid fish products from any country) , 2.2.5  (Non -salmonid fish
skin-off fillets) , 2.2.6  (Heat -treated non -salmonid fish products) , 2.2.7  (Dried non -salmonid fish products) ,
2.2.8  (Non -salmonid fish products commercially packaged for direct retail sale) , 2.3.2  (Heat -treated
crustacean products) , 2.3.3  (Frozen crustacean products) , 2.3.4  (Crustacean products commercially
packaged for direct retail sale) , 2.4.1 ( Haliotis  spp. (abalone) products) , 2.4.2 (Mollusc products other than
Haliotis  spp. (abalone)) , and 2.9 (Aquatic animal meal and aquatic animal oil)  of the amended version of
IHS AQUAPROD.GEN .
3.5 Angiostrongylus c antonensis  reassessment  
(1) Based on emerging risk information, the  nematode  Angiostrongylus  cantonensis  has been re assessed as
being of non -negligible risk in freshwater crustacean products. The Import Risk Analysis: Crustaceans for
Human Consumption  recommended the following risk mitigation options:
a) Option 1:  Freshwater crustacean products could be imported from countries, zones or compartments
that have been recognised by MPI as free from A. cantonensis .
b) Option 2:  Freshwater crustacean products could be frozen to a minimum core temperature of -18°C
for a peri od of not less than 12 hours.
c) Option 3:  Freshwater crustacean products that have been cooked until all the protein in the
crustacean meat has coagulated.
(2) As a result of the above reassessment, MPI is proposing amending Clause 2.3.1 (Crustacean products
from recognised countries) of IHS AQUAPROD.GEN  to include the following as an additional requirement:
For products derived from freshwater crustaceans, the exporting country must be free from Angiostrogylus
cantonensis .
(3) MPI is also proposing amending Clause 2.3.3(1)(b) (Frozen crustacean products) to include 12 hours as
the minimum duration of freezing for crustacean product s. Currently, the IHS requirement is for freezing to
a minimum core temperature of -18°C while being silent on the duration.
(4) MPI has determined that the requirements as currently stated in clauses 2.3.2 (Heat -treated crustacean
products)  and 2.3.4 (Crustacean pro ducts commercially packaged for direct retail sale) will mitigate the
risk from A. strongylus . 
Ministry for Primary Industries   Page 6 3.6 Health certification not required for fish imported for further 
processing  
(1) MPI proposes removing the health certification requireme nt for non -salmonid fish imported for further 
processing  in New Zealand ( clause 2.2.4  of IHS AQUAPROD.GEN ). MPI determined that the requirement 
for health certification may be onerous for products that will be directed from the border to a transitional 
facility for further processing. All biosecurity risk is managed by preassessment of imports through the 
import permit system, and management of waste in an approved transitional facility. The import permit will 
be sufficient for enabling bios ecurity clearance of the consignment.  
3.7 Bill of lading for freezing duration determination  
(1) MPI proposes including the consignment’s bill of lading in clauses 2.2.3(1)(b)(ii)(2), 2.2.3(1)(c)(ii)(2), and 
2.2.5(1)(a)(ii) as an acceptable document for determinin g the duration of freezing completed during 
transport.  A bill of lading  accompanying a refrigerated container include s the storage temperature the 
product is transported in.  
3.8 Annelid products  
(1) MPI proposes inclusion of marine worms (annelid products) as a ne w category of aquatic animal products 
that can be imported under the amended IHS.  
3.9 Composite products  
(1) MPI proposes amending clause 2.8 of IHS AQUAPROD.GEN , 11 May 2022 to include a category f or 
composite products that may contain aquatic animal meal and/or aquatic animal oil . For these products, 
MPI proposes carrying over the biosecurity import requirements as set out in clause 7.2.3(i)(b) of the 
Import Health Standard for Fish Food and Fish Bait from All Countries  (FISFOOIC.ALL , 2 December 
2011 ), whi ch allow s biosecurity clearance provided the product is commercially prepared and packaged. 
The clause number for composite products in the amended IHS will be 2.9(1).  
(2) In line with the scope for IHS AQUAPROD.GEN , the composite product must not be a bait or  feed for 
aquatic animals.  
3.10 Transition period  
(1) The amended version of IHS AQUAPROD.GEN  is intended to be published to align with the revocation 
date for the IHSs listed in clause 1.11 of IHS AQUAPROD.GEN , 11 May 2022.  
3.11 Rephras ing for clarity  
(1) In clauses 2.2.8  (Non-salmonid fish products commercially packaged for direct retail sale ) and 2.3.4 
(Crustacean products commercially packaged for direct retail sale ) of the IHS, the requirements were 
rephrased to emphasise that products that are commercially packaged for direct retail sale with net 
content of more than 1.0 kg or 1.0 litre will need both an import permit and health certification.  
   
Ministry for Primary Industries   Page 7 3.12 Corrigenda  
(1) In IHS AQUAPROD.GEN , 11 May 2022, Paragonimus  spp. was included as a risk organism in 
crustaceans that the IHS managed. As explained in section 6.2 of the Risk Management Proposal: Aquatic 
Animal Products , 11 May 2022, the organism  was assessed as bein g of negligible risks in the imported 
commodities and therefore not managed under the IHS. In the amended IHS, Paragonimus  spp. is no 
longer listed as a risk organism in crustaceans.  
(2) In clause 1.6(1) and Schedule 2 of the published IHS AQUAPROD.GEN , the te rm “Hazard Analysis and 
Critical Control Point ” was incorrectly abbreviated to “HAACP”. The abbreviation has now been corrected 
to “HACCP” in the amended IHS.  
(3) In Schedule 3 of the published IHS AQUAPROD .GEN , the incorrectly spelled fish family “Chanidae” h as 
been deleted and the risk organism associated with it, namely, “ Nodaviruses  (#27)” is now listed under the 
correct fish family “Channidae”, which is already included in the schedule.  
   
Ministry for Primary Industries   Page 8 Appendix 1 – Document History  
Date s Issued  Title Shortcode  
11 May 2022  Risk Management Proposal: Aquatic 
Animal Products  RMP AQUAPROD.GEN  
Date of Drafts  Title Shortcode  
TBD Risk Management Proposal: Aquatic 
Animal Products  RMP AQUAPROD.GEN