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Selling soft drinks, juices and waters in New Zealand

In New Zealand, non-alcoholic drinks follow the Australia New Zealand Food Standards Code, enforced by the Ministry for Primary Industries. Standards 2.6.1 and 2.6.2 cover juices, packaged water, fruit drinks and electrolyte drinks; Standard 2.6.4 caps caffeine in energy drinks at 320 mg per litre and sets their warnings. General food labelling and net quantity rules also apply.

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

Juices
Standard 2.6.1
Water and soft drinks
Standard 2.6.2
Energy drinks
Standard 2.6.4: 145 to 320 mg/L caffeine
Cola-type drinks
No more than 145 mg/kg caffeine
Who enforces
Ministry for Primary Industries (MPI)
Net quantity
Metric volume, at least 2 mm high

Before a product goes on sale

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

  1. 1Which standard covers the drink: juice, packaged water, fruit drink, electrolyte drink or formulated caffeinated beverage? Read more
  2. 2Does the caffeine content sit within the limit, with the statements it needs? Read more
  3. 3For packaged water, is fluoride within limits and declared? Read more
  4. 4Does the label carry the general food particulars, in English? Read more
  5. 5Is the volume marked correctly, and who imports it? Read more

The rules, by area

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

Juices, fruit drinks and soft drinks

What a drink must be to be sold under a given name.

  • Food sold as fruit juice must be fruit juice or a blend of fruit juices, and may contain no more than 40 g/kg of sugars, plus salt, herbs and spices.
  • Food sold as fruit drink must contain at least 50 mL/L of fruit, or 35 mL/L of passionfruit for passionfruit juice drink.
  • A non-alcoholic beverage or brewed soft drink must not be labelled or presented in a way that suggests it is an alcoholic beverage.
  • Electrolyte drinks and electrolyte drink bases have their own composition, labelling and claims rules in Division 4 of Standard 2.6.2.

How we help: Compliant Always reads your recipe and the name on the label against the standard for that kind of drink. Ask about this

Caffeine and energy drinks

Limits on added caffeine and the statements that go with it.

  • A formulated caffeinated beverage must contain no less than 145 mg/L and no more than 320 mg/L of caffeine from any source.
  • Its label declares caffeine per serving and per 100 mL, and states that the food contains caffeine and is not recommended for children, pregnant or lactating women, or individuals sensitive to caffeine.
  • Where it contains a listed substance, the label states that no more than a one-day quantity should be consumed per day.
  • In cola-type drinks, total caffeine must not exceed 145 mg/kg as consumed, and kola beverages with added caffeine state that they contain caffeine.
  • Foods containing guarana must be labelled as containing caffeine.
  • Some pure and highly concentrated caffeine products are banned in Australia and New Zealand.

How we help: Compliant Always reads your specification and lab report against the caffeine limits and checks the required statements on the label. Ask about this

Packaged water

The composition and labelling of water sold in packages.

  • Packaged water may contain carbon dioxide, but must not contain chemicals of health significance above the World Health Organization drinking-water guideline values, or naturally occurring fluoride above 1.0 mg/L.
  • Fluoride may be added only to still, unflavoured water, to a total of 0.6 to 1.0 mg/L, and the label then states that the water contains added fluoride.
  • A typical analysis of naturally occurring compounds in mg/L or parts per million may be shown, and is not a nutrition content claim.
  • Packaged water, tea and coffee do not need a nutrition information panel unless a claim is made.

How we help: Compliant Always sets your water analysis beside the guideline values and keeps it with each batch. Ask about this

Labelling

The general food labelling rules that apply to drinks.

  • Packaged drinks carry the Standard 1.2.1 particulars: name, lot identification, the supplier's name and New Zealand or Australian address, ingredients, date marking, storage and directions, and nutrition information.
  • Words required by the Code are in English, legible and prominent.
  • Advisory statements apply to ingredients such as aspartame, quinine and guarana.
  • Nutrition and health claims follow Standard 1.2.7.

How we help: Compliant Always reads your label against the particulars and statements that apply, with the standard for each. Ask about this

Net quantity and import

Volume marking, and how drinks come into New Zealand.

  • Prepackaged drinks are labelled with net quantity in metric units, such as millilitres or litres, at least 2 mm high and close to the name.
  • Multipacks not meant to be opened before sale show either the total quantity or the number and quantity of the packs inside.
  • Drinks imported for sale come in through an importer registered with MPI under the Food Act 2014.

How we help: Compliant Always checks the volume statement on your artwork and keeps fill records and import documents with each lot. Ask about this

Who answers for what

WhoWhat they answer forHow we help
BrandThe name, the label, the caffeine statements and any claims.The label checked against the drink's standard and the general rules.
Manufacturer or bottlerComposition, caffeine content, water quality and the stated volume.Specifications, analyses and fill records kept by lot.
Registered food importerBringing drinks in for sale under the Food Act 2014.Suppliers' documents read and dated before the goods arrive.

Questions businesses ask

How much caffeine can an energy drink contain in New Zealand?
A formulated caffeinated beverage must contain between 145 mg/L and 320 mg/L of caffeine from any source, under Standard 2.6.4 of the Food Standards Code.
What warnings does an energy drink need in New Zealand?
Statements that it contains caffeine and is not recommended for children, pregnant or lactating women or people sensitive to caffeine, plus the caffeine content per serving and per 100 mL.
How much caffeine can a cola contain?
Total caffeine in cola-type drinks must not exceed 145 mg/kg as consumed, and kola beverages with added caffeine must state that they contain caffeine.
What can be added to fruit juice in New Zealand?
Fruit juice may contain no more than 40 g/kg of sugars, plus salt, herbs and spices. Vegetable juice may contain sugars, salt, herbs and spices.
How much fruit must a fruit drink contain?
At least 50 mL/L of fruit, or 35 mL/L of passionfruit for a passionfruit juice drink, under Standard 2.6.2.
Can fluoride be added to bottled water in New Zealand?
Only to still water without sugars, sweeteners or flavours, to a total of 0.6 to 1.0 mg/L, using one of three permitted forms. The label must say the water contains added fluoride.
Does bottled water need a nutrition panel?
No, packaged water does not need a nutrition information panel unless a claim requiring nutrition information is made.
Can a non-alcoholic drink look like beer or wine?
A non-alcoholic beverage or brewed soft drink must not be labelled or presented in a way that expressly or by implication suggests it is an alcoholic beverage.
Who enforces drink labelling rules in New Zealand?
The Ministry for Primary Industries enforces the Food Standards Code in New Zealand. Trading Standards at MBIE checks net quantity, and the Commerce Commission enforces the Fair Trading Act.
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.

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