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National Programmes · NP1, NP2 & NP3

Digital Record Keeping for National Programme 1, 2 & 3

National Programme businesses don't write a Food Control Plan — but they must register, meet food safety standards, keep records and get verified. KitchenSorted keeps those records — training, suppliers, transport temperatures, mock recalls — dated, attributed and ready to show your verifier, free.

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What is a National Programme?

National Programmes let lower and medium-risk food businesses in NZ operate without a written Food Control Plan. You still must register, meet food safety standards, keep records and undergo verification checks — MPI's own list of universal requirements includes “Record keeping to show that you're selling safe food” (MPI: National Programmes).

MPI's National Programme 1 guidance (December 2025, version 2) puts it plainly: under a National Programme you don't need written procedures or a documented Food Control Plan — those are for high-risk businesses — but “you must be able to demonstrate that you are meeting the requirements… by following procedures and keeping records for some of the things you do.” The paperwork is lighter than an FCP. It is not zero.

'Kitchen' is in our name, but you don't need a kitchen. KitchenSorted covers non-kitchen National Programme operators too — transport, honey, bakery and handle-and-sell.

Which National Programme level is my business?

Three levels, by risk: NP1 is lowest, NP3 is highest. The lists below come from MPI's December 2025 guidance documents. Not sure which applies — or whether you need a Food Control Plan instead? Run MPI's official My Food Rules questionnaire before you register.

NP1 — lowest risk

  • Extract or pack honey
  • Grow or pack fruit, vegetables or other horticultural products
  • Make sugar, molasses, syrups or related products
  • Sell tea, coffee, hot chocolate and packaged shelf-stable food only
  • Sell packaged ice creams, ice blocks or similar items only
  • Store or transport food only

Source: NP1 guidance, Dec 2025 v2 (PDF)

NP2 — medium-low risk

  • Pre-school and early-childhood-education food services
  • Retailers of manufacturer-packaged chilled and frozen food
  • Processors of nuts and seeds
  • Manufacturers of bread and other shelf-stable grain-based products
  • Manufacturers of confectionery, condiments, dried or dehydrated produce, frozen fruit and vegetables

Source: NP2 guidance, Dec 2025 (PDF) · Steps to NP2

NP3 — medium risk

  • Retailers who handle food without preparing it — reheating pies, scooping ice cream: the “handle and sell” group
  • Processors of grain, herbs and spices
  • Manufacturers of oils and fats
  • Manufacturers of alcoholic and non-alcoholic drinks, including brewers and distillers

Source: NP3 guidance, Dec 2025 (PDF) · Steps to NP3

In practice that's coffee carts selling hot drinks and packaged snacks, honey extractors and packers, bakeries making shelf-stable bread, food transport and storage operators, and dairies scooping ice cream. Note the ice cream split: selling packaged ice creams only is NP1; scooping it is handling, which is NP3. If you prepare or cook food for direct sale, you're likely outside National Programmes and need a Food Control Plan instead.

How often are National Programme businesses verified?

NP3 businesses are verified at least once every 2 years, NP2 at least once every 3 years, and NP1 gets an initial verification only — after that, a verifier must not carry out further verifications unless something goes wrong and regulation 102 (unscheduled verification) applies. That's regulations 91–94 of the Food Regulations 2015.

LevelVerification frequencyLegal basis
NP3At least once every 2 yearsReg 91
NP2At least once every 3 yearsReg 92
NP1Initial verification only; further checks only if regulation 102 (unscheduled verification) appliesRegs 93–94

The actual gap moves with your outcomes: reg 94's frequency table runs from 3 months up to 3 years — and, for NP1, a “no verification” step. Verification isn't free, either: MPI's own Steps to NP2 page notes verifiers charge $115 to $210 an hour plus travel fees, so records your verifier can review quickly are worth real money. More detail on cadence, first-visit timing and what shifts your frequency: how often food businesses are verified in NZ.

The new duty most operators haven't heard of: simulated (mock) recalls

National Programme businesses now have a simulated (mock) recall duty — practising how you'd trace and pull a product before a real recall ever happens. It comes from regulation 72A of the Food Regulations 2015, and MPI's December 2025 (version 2) refresh of all three National Programme guidance documents builds mock recall procedures into each programme — the mock recall record sits in the NP1 required-records list itself.

Because the guidance refresh is recent, this is the obligation verifiers are most likely to ask about that operators are least likely to have on file. A useful mock recall record shows the date, who ran it, which product and batch you traced, which suppliers and customers you contacted, and what the run turned up. In KitchenSorted that's one log entry — dated and attributed like every other record — instead of a document you invent from scratch the week before your verification visit.

MPI provides no record templates for National Programmes

MPI's printable record blanks belong to the Simply Safe & Suitable template Food Control Plan — the official Forms and documents page lists no record templates for National Programmes at all. NP operators must keep records, but are left to design their own formats.

To be clear: paper is a perfectly legal way to do that, and a notebook or spreadsheet that meets the record rules is fine. The catch is the friction — you're inventing the format, remembering the cadence, chasing staff for entries, and later digging records out of a drawer for your verifier. KitchenSorted ships the National Programme record set ready to use: training, supplier and traceability, transport temperatures, mock recalls. Every entry captures the date, the result and who did it — the exact things regulation 82 requires of a National Programme record — and the verification pack assembles them into one dated PDF when your check comes around. The daily records are free, and stay free.

What records does an NP1 business need to keep?

Even at the lowest-risk level, MPI's NP1 guidance (December 2025, version 2) lists six records you must keep as a matter of course, plus a second set you must record whenever something goes wrong. NP2 and NP3 have their own record requirements, set out in their December 2025 guidance documents.

Required records (NP1)

  • Water test results — if you're on a self-supply
  • Competency and training
  • Sourcing, receiving and tracing
  • Allergens and knowing what's in your food
  • Transporting food — temperature checks
  • Simulated (mock) recall

Record when something goes wrong

  • Checking the programme is working well
  • Pests, maintenance, storage and display
  • Separating safe and unsafe food; foreign matter
  • Packing and labelling; recalling food

Verifiers also check core topics at every NP1 verification — competency and training, cleaning, personal hygiene and health, sourcing and tracing, process controls — plus sector-specific checks like tutin status for honey and temperature checks for ice cream, hot drinks and transport.

Every National Programme record must be kept for at least 4 years after it's created (regulation 81, Food Regulations 2015) — here's how the 4-year rule works. That duty is yours however you keep records; paper and exports satisfy it. In KitchenSorted, 4 years of history, verification packs and reminders live in the paid plan — your free-plan records are never deleted and unlock when you upgrade.

National Programme record-keeping FAQs

No. MPI's NP1 guidance states that under a National Programme you don't need written procedures or a documented Food Control Plan — those are required for high-risk businesses. You demonstrate you're meeting the requirements by following procedures and keeping records, and by registering and getting verified.

Yes — paper is legal, and MPI doesn't prescribe a format. Whatever you use, records must be legible, accurate and complete, state when the activity happened and its result, identify who did it, and be kept for at least 4 years (regulations 81–82, Food Regulations 2015). The case for an app is friction, not legality: reminders, no invented formats, and records you can find in seconds.

No app can guarantee compliance — meeting your National Programme is always the operator's responsibility, and your verifier decides the outcome. What KitchenSorted does is keep the records your programme requires organised, dated and easy to show.

Probably not — businesses that prepare or cook food for direct sale generally need a registered Food Control Plan rather than a National Programme. Check with MPI's My Food Rules tool, then see how KitchenSorted handles Food Control Plan records.

Sources & review

Reviewed on 2 August 2026 by the KitchenSorted team. Regulatory pages are re-reviewed quarterly, and immediately when MPI announces template or policy changes. Spotted something out of date? Tell us.

This page is general information, not legal or food-safety advice. Always confirm requirements with MPI, your registration authority, or your verifier.

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