Source
https://www.mpi.govt.nz/dmsdocument/11473-Animal-Products-Notice-Raw-Milk-for-Sale-to-Consumers-Regulated-Control-Scheme — original source (opens in a new tab; the file is not redistributed)
Animal Products Notice: Raw Milk for Sale to Consumers
The operational instrument that sits underneath REG_031 and carries the numbers the Regulations do not
Issued 9 March 2022 under the Animal Products Act 1999 (s 167(2)) and the Food Act 2014 (s 405), to supplement the Raw Milk for Sale to Consumers Regulations 2015. 68pp. This is where the 4-day use-by and the “heat to 70°C for one minute” text actually live — both were mis-attributed to the Regulations by the upstream research report (corrected at REG_031). 🔴 The 70°C/1-minute figure is a MANDATED CONSUMER LABEL WARNING (cl 8.4), NOT a producer heat-treatment obligation. The scheme explicitly permits raw, unpasteurised sale — the label must read “raw (unpasteurised) milk” (cl 8.1). On-farm pasteurisation is not required; the compliance burden is a testing + cold-chain + records regime, not heat treatment.
Summary
The Animal Products Notice: Raw Milk for Sale to Consumers (9 March 2022) is the Ministry for Primary Industries instrument that fills in the detailed operating specifications of the raw-milk regulated control scheme (RCS). It is issued under both the Animal Products Act 1999 and the Food Act 2014 to supplement the Raw Milk for Sale to Consumers Regulations 2015 (REG_031), and it is explicit that the two must be read together — many core requirements (who may register, who may sell) live in the Regulations, while the operational detail (use-by, labelling, testing frequency, records, temperature) lives here.
For Neobiome this Notice resolves the operational-detail gap that REG_031 flagged as RT_390. It confirms the community-dairy pathway does not require pasteurisation: a registered farm dairy may sell raw, unpasteurised milk, subject to a defined regime — milk held at ≤6°C, a 30-hour sell-by, a use-by no more than 4 days after milking commenced, a pathogen-testing schedule every 10 days (reducible on sustained good performance), records kept ≥4 years, and a mandated on-label consumer warning to heat the milk to 70°C for one minute. The “70°C” therefore prices as a label line, not as on-farm plant.
Key claims
- claim: "WHAT THIS INSTRUMENT IS. An MPI Animal Products Notice issued under s 167(2) of the Animal Products Act 1999 (for the purposes of s 38(2)(a)) and s 405 of the Food Act 2014 (for the purposes of s 383(3)), to SUPPLEMENT the Raw Milk for Sale to Consumers Regulations 2015; in force 9 March 2022. Requirements set out in the Regulations are not generally repeated here, so the two must be read together. [verified verbatim against the source]"
source_location: "Animal Products Notice: Raw Milk for Sale to Consumers (9 March 2022), Title/Issuing Authority (p1) and Introduction, Purpose (1)-(2) (p6)."
- claim: "THE SCHEME PERMITS RAW, UNPASTEURISED SALE — NO PRODUCER PASTEURISATION OBLIGATION. Each packaged container must be labelled as containing, verbatim, 'raw (unpasteurised) milk'. (Pasteurisation is described only as the treatment applied to ordinary milk — 'equivalent to 72°C for 15 seconds' — not as a requirement of this scheme.) [verified verbatim against the source]"
source_location: "Animal Products Notice (9 March 2022), cl 8.1(1)(a) (p47); Introduction, Background (1) (p6)."
- claim: "USE-BY DATE = NO MORE THAN 4 DAYS AFTER MILKING COMMENCED. The use-by date on an RCS container or dispensing-device notice is, verbatim, 'the date that is no more than 4 days after the date on which milking for the oldest milk in the container or device commenced.' [verified verbatim against the source]"
source_location: "Animal Products Notice (9 March 2022), cl 8.2(1) (p47); restated in Introduction, Background (4)(e) (p6)."
- claim: "THE '70°C FOR ONE MINUTE' IS A MANDATED CONSUMER LABEL WARNING, NOT A PRODUCER HEAT-TREATMENT RULE. The label must carry the specified warning information, verbatim: 'Raw milk may contain harmful microorganisms that can cause serious illness. To reduce the risk of illness, raw milk should be heated to at least 70°C for one minute. This is critical for infants, young children, the elderly, pregnant women, and people with weakened immune systems'. It is a labelling obligation on the supplier (cl 8.1(1)(e)); the heating is done by the CONSUMER, at their option. [verified verbatim against the source]"
source_location: "Animal Products Notice (9 March 2022), cl 8.4(1) and cl 8.1(1)(e) (p47)."
- claim: "SPECIFIED STORAGE DIRECTIONS (on-label): 'Store at or below 4°C. Do not consume after the use-by date.' This is the consumer-facing storage line, distinct from the ≤6°C process temperature below. [verified verbatim against the source]"
source_location: "Animal Products Notice (9 March 2022), cl 8.3(1) (p47)."
- claim: "PROCESS TEMPERATURE AND TIME. RCS raw milk must be maintained at or below 6°C at all times between initial cooling and delivery to the consumer, and the SELL-BY time is 30 hours after the commencement of milking for the oldest milk in the lot (the maximum harvest-to-delivery time). [verified verbatim against the source]"
source_location: "Animal Products Notice (9 March 2022), Introduction, Background (4)(a) and (4)(d) (p6); Sell-by time cl 6.9(1) (p39)."
- claim: "CONFORMANCE TESTING FREQUENCY (Table 6.11). Salmonella spp., Listeria monocytogenes, Campylobacter spp., Coagulase-Positive Staphylococci and Escherichia coli must be tested ONCE EVERY 10 DAYS (standard), reducible to ONCE PER CALENDAR MONTH only if the responsible verifier permits and the performance criteria in cl 6.11(2) are met (no more than 2 demerit points in 12 months, none in the past 3 months, all assessments/audits acceptable, no outstanding major non-conformances). Total coliforms and Aflatoxin M1: every 15 days; Aerobic Plate Count, Somatic Cell Count, Inhibitory Substances: every 10 days (not reducible). [verified verbatim against the source]"
source_location: "Animal Products Notice (9 March 2022), cl 6.11 and Table 6.11 (p40)."
- claim: "RECORD RETENTION. Records the Notice requires an operator to keep must be kept (hard copy or electronic) for AT LEAST 4 YEARS, and be complete, accurate, appropriately stored, readily accessible, and available for inspection. [verified verbatim against the source]"
source_location: "Animal Products Notice (9 March 2022), cl 1.2(1)(a)-(d) (p10)."Neobiome Intelligence relevance
Feeds d02_smart_food_systems as the operating layer of the community-dairy regulatory gate. REG_031 established who may sell and in what shape; this Notice establishes what it costs to run compliantly, and corrects the single most consequential mis-reading in the upstream research.
The correction that changes the model’s cost picture:
| Belief carried into the model | What the Notice actually says |
|---|---|
| Raw-milk supply requires heating to “70°C for 1 minute” (a plant/energy cost) | The 70°C/1-min text is a consumer label warning (cl 8.4). On-farm pasteurisation is not required; the scheme permits raw sale labelled “raw (unpasteurised) milk” (cl 8.1). |
| “4-day use-by” is a rule in the Regulations | It is cl 8.2 of this Notice (no more than 4 days after milking commenced). |
What the compliant-raw pathway actually carries as recurring burden (the real OpEx shape, not a heat-treatment CapEx line): a cold chain at ≤6°C from cooling to delivery; a 30-hour sell-by; pathogen testing every 10 days (5 pathogens: Salmonella, Listeria, Campylobacter, Coag-positive Staph, E. coli), only reducible to monthly on a clean track record; plus APC/SCC/coliform/inhibitory-substance testing; a 4-day use-by; ≥4-year record retention; and performance-based verification audits (Part 7). This sharpens REG_031’s “raw-vs-pasteurised is a design fork”: pasteurisation is optional, not mandated — the fork is between (a) the RCS testing/cold-chain/records regime for raw sale and (b) leaving this instrument entirely by pasteurising, which trades the testing regime for heat-treatment plant and energy.
No engine cell is auto-changed by this ingest. The output is a corrected feasibility shape: any future scoring of a community dairy must model the raw pathway as an RCS operating burden (testing + cold chain + records), and must not charge it a pasteurisation CapEx line as if the 70°C figure were a producer obligation.
Notes
- Authoritative regulatory primary (
data_quality: verified) — the MPI-issued Notice text, in force 9 March 2022. Not AI-prepared (direct authoritative download), so no retrieval-provenance block. - Clause-numbering correction. The conformance testing frequencies are in cl 6.11 / Table 6.11 (Part 6, Milking and Milk Quality), not “cl 7”. Part 7 covers verification and farm-dairy-assessment frequencies, which are a separate, performance-based schedule. Both were checked against the raw; the figures above use the correct clauses.
- Two temperatures, deliberately different. The process requirement is ≤6°C (Background (4)(a)); the on-label consumer storage direction is ≤4°C (cl 8.3). They are not the same number and should not be conflated in the model.
- Reads with, not instead of, REG_031. The Regulations carry registration, who-may-sell, and the reg 64 hand-over constraint; this Notice carries the operating detail. Anything the model says about raw-milk shelf life, testing cost, or cold-chain must cite this page; anything about the lawful distribution shape stays on REG_031.
Research targets
Documents to retrieve
- RT_390 — RESOLVED by this ingest. The MPI Animal Products Notice for raw milk supplied to consumers is now retrieved and ingested as REG_032. It carries the operational detail REG_031 lacked: the 4-day use-by (cl 8.2), the on-label 70°C/1-min consumer warning (cl 8.4, not a producer obligation), conformance-testing frequencies (cl 6.11), record-keeping ≥4 years (cl 1.2), and the ≤6°C / 30-hour cold-chain rules.
Research gaps
- Not raised as new RTs:
- Farm dairy registration cost and process — already folded into the dairy-CapEx gap RT_387 at OT_172; not duplicated here.
- Whether member distribution is a “sale” — a legal-interpretation question recorded on the REG_031 page, not a retrievable document; unaffected by this Notice.
Connections
Links to
Referenced by
Sources (2): REG_031 · REG_033
EDT domains (1): D02: Smart Food Systems & Agriculture