Compliant Always
Get in touch

Selling infant formula and baby food in New Zealand

New Zealand opted out of the joint infant formula standard, Standard 2.9.1, and that joint standard does not govern infant formula or follow-on formula sold in New Zealand. Food for infants follows Standard 2.9.2, with limits on sodium, sugars and honey, and age statements. Formulated supplementary foods for children aged 1 to 3 follow Standard 2.9.3.

Updated · Each section links to the official source it comes from

Infant formula
Standard 2.9.1 does not apply in New Zealand
Food for infants
Standard 2.9.2
Foods for ages 1 to 3
Standard 2.9.3, Division 4
Minimum age on labels
Not under 4 months
Who enforces
Ministry for Primary Industries (MPI)

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Is it an infant formula product, a food for infants, or a food for young children? Read more
  2. 2Does food for infants meet the sodium, sugar, iron and honey limits? Read more
  3. 3Does the label state the minimum age and consistency, with the warnings that apply? Read more
  4. 4For a toddler food, does a serving meet the minimum protein, energy and nutrient levels? Read more
  5. 5Who imports it into New Zealand? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Infant formula and follow-on formula

Where New Zealand departs from the joint Code.

  • Standard 2.9.1, Infant formula products, applies in Australia only: New Zealand opted out of it under Annex D of the agreement between the two governments on a joint food standards system.
  • The Code notes that Standard 2.9.1 has not been incorporated by reference into a food standard under the Food Act 2014.
  • The revised Australian standard came into effect on 13 September 2024 after Proposal P1028, with a five-year transition to 13 September 2029.
  • In the Code, infant formula is a breast milk substitute that satisfies by itself the nutritional needs of infants under 6 months; follow-on formula is the principal liquid in a diversified diet from 6 months.
  • Standard 2.9.6, a transitional standard for special purpose foods, applies in New Zealand only.

How we help: Compliant Always keeps infant formula specifications and labels apart for New Zealand and Australia, so the rules for each market are read separately. Ask about this

Food for infants: composition

What food for infants may contain.

  • Food for infants means food intended or represented as nourishment for infants, other than infant formula products, meal replacements, supplementary foods and unprocessed fruit and vegetables.
  • Sodium is capped at 350 mg/100 g for rusks, 300 mg/100 g for biscuits and 100 mg/100 g for most ready-to-eat foods; fruit-based foods and juices must not contain added salt.
  • Honey may be used only if treated to inactivate Clostridium botulinum spores.
  • Fruit drinks, vegetable juices and non-alcoholic beverages for infants may contain no more than 4 g/100 g of monosaccharides and disaccharides.
  • Cereal-based food promoted from 6 months, with more than 70% cereal, must contain at least 20 mg/100 g of iron, and food for infants under 6 months must have a consistency that minimises the risk of choking.

How we help: Compliant Always reads your recipe and lab results against the Standard 2.9.2 limits for that kind of food. Ask about this

Food for infants: labelling

The statements and prohibitions on a label for infant food.

  • The label must not suggest that the food is suitable for infants under 4 months.
  • It states the consistency of the food and the minimum age, in numbers; food recommended under 6 months adds 'Not recommended for infants under the age of 4 months'.
  • The word 'sweetened' is required above 4 g/100 g of sugars from added sugars or honey, and 'sterilised' goes with 'honey' where honey is an ingredient.
  • Food with more than 3 g protein per 100 kJ carries 'Not suitable for infants under the age of 6 months'.
  • Food must not be represented as the sole or principal source of nutrition for infants, or recommended for adding to bottle feeds.
  • Storage instructions cover the period after opening, and dehydrated foods carry reconstitution directions.

How we help: Compliant Always checks each required statement and prohibited representation on your artwork, with the section beside it. Ask about this

Formulated supplementary foods for young children

Foods for children aged 1 to 3.

  • A formulated supplementary food for young children is one for children aged 1 to 3 years.
  • A serving must contain at least 2.5 g protein, 330 kJ and 20% of the recommended dietary intake of at least one listed vitamin or mineral.
  • Inulin-type fructans and galacto-oligosaccharides are limited to 1.6 g per serving, and lutein to 100 µg per serving.
  • The nutrition information panel declares the vitamins and minerals used as nutritive substances, and vitamin and mineral claims have set thresholds.

How we help: Compliant Always sets your nutrient analysis beside the serving minimums and claim thresholds. Ask about this

Import and enforcement

How these foods come into New Zealand and who checks them.

  • Food imported for sale comes in through an importer registered with MPI under the Food Act 2014.
  • Customs holds alerts on tariff items, such as dairy products, that need biosecurity or food safety clearance.
  • MPI enforces the Food Standards Code in New Zealand and handles food safety recalls.

How we help: Compliant Always keeps importer registration, clearances and supplier certificates with each shipment. Ask about this

Who answers for what

WhoWhat they answer forHow we help
BrandThe label, the age statements and any claims.The label read against the standard for that product, line by line.
ManufacturerComposition within the limits and the evidence behind it.Specifications and lab reports kept by lot.
Registered food importerBringing the food in for sale under the Food Act 2014.Suppliers' documents read and dated before the goods arrive.

Questions businesses ask

Does the Food Standards Code infant formula standard apply in New Zealand?
No. Standard 2.9.1, Infant formula products, applies in Australia only. New Zealand opted out of it under Annex D of the joint food standards agreement, and the Code notes it is not incorporated into a food standard under the Food Act 2014.
Which standard covers baby food in New Zealand?
Standard 2.9.2, Food for infants, which applies in New Zealand. It covers foods for infants other than infant formula products and unprocessed fruit and vegetables.
Can a baby food be labelled as suitable from 4 months?
Yes, but not younger: the label must not suggest the food suits infants under 4 months. Food recommended under 6 months carries 'Not recommended for infants under the age of 4 months'.
Can baby food contain honey in New Zealand?
Only if the honey has been treated to inactivate Clostridium botulinum spores, and the label then uses the word 'sterilised' with 'honey'.
How much salt can baby food contain?
No more than 350 mg/100 g of sodium for rusks, 300 mg/100 g for biscuits and 100 mg/100 g for most ready-to-eat infant foods. Fruit-based foods and juices must not contain added salt.
When must a baby food say 'sweetened'?
When it contains more than 4 g/100 g of monosaccharides and disaccharides from added sugars or honey.
Which rules cover toddler milks and foods for ages 1 to 3?
Formulated supplementary foods for young children follow Division 4 of Standard 2.9.3, with minimum protein, energy and vitamin or mineral levels per serving.
Can a baby food be sold as a complete diet?
No. A food must not be represented as the sole or principal source of nutrition for infants, nor recommended for adding to bottle feeds.
Who enforces baby food rules in New Zealand?
The Ministry for Primary Industries enforces the Food Standards Code in New Zealand, and food imported for sale must come in through an importer registered with MPI.
How does Compliant Always help with selling in New Zealand?
Our team reads the rules for the markets you sell in, including the Food Standards Code New Zealand shares with Australia. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in New Zealand and what your paperwork needs to show.

Get in touch

No card, no account, and no call to book. Tell us what you make and where you sell it, and we will come back to you.

Get in touch