New Zealand food exporters do not need a passport

If you export food or drink from New Zealand, your product does not need a European Union (EU) digital product passport. Food sits outside the law that creates the passport. No EU law requires a passport for food or feed.

That answers the question for manuka honey, kiwifruit, chilled lamb, cheese, infant formula and a carton of Marlborough sauvignon blanc.

Two mistakes cost money here. You can buy a passport system that no rule requires. You can also assume the exclusion covers the carton, which it does not.

The exclusion is written in ESPR Article 1(2)

The Ecodesign for Sustainable Products Regulation (ESPR) creates the digital product passport. It is Regulation (EU) 2024/1781, and it is in force from 18 July 2024.

Article 1(2) lists the products the regulation does not cover. Food and feed are on that list. So are medicinal products, veterinary medicinal products, living plants and living animals.

So a later ESPR rule cannot reach your honey, your lamb or your wine. ESPR does not cover an excluded product at all. Food and feed are excluded gives the full list, and ESPR exclusions gives the article.

Drink counts as food, because ESPR borrows the meaning

ESPR does not define food itself. It takes the meaning from Article 2 of Regulation (EC) No 178/2002, the EU food law. That law says:

'Food' includes drink, chewing gum and any substance, including water, intentionally incorporated into the food

So a New Zealand wine, beer or fruit juice is outside ESPR scope. A bottle of water is outside scope too. See wine, beer and spirits.

The table below gives every date on this page.

The exclusion covers the product, not the company

Read this part if you sell more than one thing.

The exclusion attaches to the product, not to your company. If you sell manuka honey and woollen goods, you have one excluded product line and one that a later rule may cover.

The honey stays outside ESPR scope. For the woollen goods, the Commission plans a textile rule and has adopted none. That plan gives an adoption year, not a compliance date. See New Zealand apparel and textile exporters and how to read the timeline.

The same test applies to a skincare line or a supplement. Cosmetics stay inside ESPR scope. A natural health product follows its classification in the market you sell into. See cosmetics and natural health products and medicinal products are excluded.

Your packaging is a separate product, and it is not excluded

The bottle, the pouch, the label and the carton are separate physical goods in EU law, and the food exclusion does not cover them.

Packaging Regulation (EU) 2025/40 covers them instead, and it applies in phases from August 2026. The start date of its labelling article is not confirmed, so check the rule rather than a summary of it. See packaging.

The Ministry for Primary Industries published a notice on the EU packaging rules in April 2026. That notice never mentions digital product passports or ecodesign. Treat the two subjects as separate pieces of work.

What reaches you is a buyer request, not a law

A European buyer can ask you for product data as a condition of sale. No law requires that request. The buyer can still refuse to buy without the data. A buyer request is the indirect route by which EU rules arrive in New Zealand.

The Ministry of Foreign Affairs and Trade reported on the EU corporate sustainability due diligence rules in October 2024. EU customers under those rules may ask New Zealand partners for sustainability information. That request arrives through the contract, not through the regulation.

Answer such a request with the data you already hold. Do not build a digital product passport for a food product. Agree in writing who supplies each item, who approves it, and who updates it. See agreeing data duties with your EU importer.

One New Zealand government report covers this, from October 2025

This site searched for New Zealand material on 16 August 2026, in fifteen separate searches, and read 104 separate pages. The Ministry of Foreign Affairs and Trade wrote the substantial government account, in a market report of October 2025. See what New Zealand agencies have said.

That report is the only New Zealand government document given over to the subject. No other page in the search treats it at length. See what New Zealand industry has published and does this reach my product.

The report names Regulation (EU) 2024/1781. It tells exporters to learn the new rules. It tells them to prepare by setting up data tracking and reporting systems. It says those systems cost money in information technology infrastructure and in data management, and it gives no figure.

EU Circular Economy: Ecodesign, Digital Product Passports, and Green Public Procurement

Two cautions go with that report. Its per-category years are the years the Commission expects to adopt each rule. They are not dates on which a passport becomes mandatory.

The report is older than the six European standards for digital product passports, which appeared in 2026. Standards New Zealand sells all six, and no New Zealand source explains them. This site searched 104 New Zealand pages on 16 August 2026, and none gives the battery date of 18 February 2027. See what New Zealand agencies have said and which products need a passport, and when.

No New Zealand food sector body publishes guidance on this subject. A search in August 2026 covered the Meat Industry Association, DairyNZ and New Zealand Winegrowers, and found none.

Know where you keep your product data, even if no rule reaches you

Find out where you keep your product data, and who owns it. That is the one action worth taking even if no rule ever reaches your product.

Ask three questions inside your own company:

1. Who holds the current specification for each product line?
2. Who holds the certificates, the test results and the origin evidence?
3. Who updates all three when a recipe, a supplier or a label changes?

If nobody can answer within a day, fix that first. No EU law requires this data for a food product. A buyer can still ask for it, and the answer is the same set of data either way. See first steps for a New Zealand exporter.

The records behind an origin claim are your origin evidence. A provenance licence is not that evidence. See a provenance mark is not a passport.

Do not buy a passport system for a food product.