Food safety for horticulture producers

In August 2022, three new national horticulture primary production and processing standards were introduced into the Australia New Zealand Food Standards Code: Standards 4.2.7, 4.2.8 and 4.2.9 – Primary Production and Processing Standards for berries, leafy vegetables, and melons.

The standards come into effect on 12 February 2025.

Standards were developed through Proposal P1052, led by Food Standards Australia New Zealand and aim to reduce the incidence of foodborne illness.

The standard development process involved extensive stakeholder consultation, including two formal public calls for submission. Evidence considered included technical assessments of food safety risks, cost benefit analysis, a decision regulation impact statement, and consideration of implementation arrangements. Industry was provided opportunity to engage throughout this process, including through formal submissions, farm visits and technical advisory roles.

Under the Food Act 1984, all producers (of all commodities) have an obligation to ensure that food for sale is safe and suitable for human consumption and to comply with the Food Standards Code, where applicable.

Implementation of new standards is the responsibility of individual state governments. Agriculture Victoria is determining how standards will be implemented and enforced in Victoria. Our regulatory aim is to take a proportionate, educative approach to these new requirements.

Agriculture Victoria has consulted peak industry bodies to assist in regulatory design. Agriculture Victoria will support businesses to meet their obligations under the standards through an education and awareness campaign targeting industry and grower groups. This engagement will continue after the February 2025 implementation date.

Information on the standards, the development process and general information can be found on the Food Standards Australia New Zealand website.

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Standard 4.2.7 – Primary Production and Processing Standard for Berries requires businesses that grow or complete primary or ‘early-stage’ processing to identify and control food safety hazards associated with berry growing and primary processing, and to notify regulators of their activities.

  • Berries are defined in the standard as fresh berries and includes berries such as strawberries, blueberries, and berries from the genus Rubus.
  • Examples of berries included are, but not limited to those listed and raspberries, blackberries, boysenberry, loganberry, silvanberry and youngberry. ​

Registration Pathway 1 – Berry Notification

  • For berry businesses, you will be required to register and notify Agriculture Victoria of how you are complying with the standards. If your business is already in a third party or industry food safety scheme, specifically those certified under the Global Food Safety Initiative (GFSI), you must register and provide information so that Agriculture Victoria can verify your certification(s).
  • Businesses will need to:
    • register on Agriculture Victoria Connect
    • provide business details
    • provide a brief description of how the business is meeting the Standards OR current GFSI scheme certificate
    • pay an annual registration fee: $33 to $653 per business scaled to production area*.

* Note: These figures are indicative and subject to approval of regulations by Governor in Council and other parliamentary processes.

Standard 4.2.8 – Primary Production and Processing Standard for Leafy Vegetables requires businesses that grow or complete primary or ‘early-stage’ processing to identify and control food safety hazards associated with growing and primary processing of leafy vegetables. It also requires relevant businesses to have an approved food safety management statement which includes notifying regulators of their activities.

Leafy vegetables have been defined in the standard as vegetables of a leafy nature where the leaf is consumed raw; and includes baby leaves, lettuce, and leafy herbs; and does not include seed sprouts (requirements found in a separate standard).

  • Examples of leafy vegetables include but are not limited to all lettuces (iceberg (crisphead), rocket, romaine (cos), red leaf, butterhead, endive, oak leaf, watercress, radicchio, baby leaf, battavia, all other loose-leaf lettuces), kale, chicory, watercress, swiss chard, Asian leafy greens (e.g. bok choy), all leafy herbs consumed raw (e.g. parsley, basil, coriander, dill, fennel leaves, mint, thyme, rosemary, oregano, marjoram, chives), spring onions, microgreens, spinach leaves, silverbeet and cabbage.
  • Examples of vegetables that are not considered leafy vegetables include broccoli, broccolini, cauliflower, asparagus, artichoke, root and tuber vegetables, bulb vegetables, brussel sprouts, kohlrabi, cucumbers, peppers, eggplant, rhubarb, squash, celery and leek.

Registration Pathway 2 – GFSI Recognition

  • For leafy vegetable businesses within recognised Global Food Safety Initiative (GFSI) schemes (such as Freshcare and SQF^), you will need to register and notify Agriculture Victoria of your certification. Provided your certification is maintained, and available for review and verification by Agriculture Victoria, your business will be immediately recognised as meeting the relevant standard.
  • Businesses will need to:
    • register on Agriculture Victoria Connect
    • provide business details
    • provide current GFSI certificate
    • approve data sharing with scheme owners
    • pay an annual registration and GFSI recognition fee: $33 to $849 per business scaled to production area*.

Registration Pathway 3 – FSMS Approval

  • For leafy vegetable businesses not within recognised schemes, you will need to complete an online Food Safety Management Statement (FSMS) and participate in an audit to verify directly if the business is compliant with the Food Standards Code.
  • The online FSMS is completed as part of the registration process and includes several questions that:
    • summarise your business activities
    • identify your businesses food safety risks and how you manage them.
  • Business will need to:
    • register on Agriculture Victoria Connect
    • provide business details
    • provide detailed food safety data through the online FSMS
    • be audited by Agriculture Victoria
    • pay an annual registration and FSMS approval fee: $33 to $1632 per business scaled to production area, plus time-based travel and audit fees*.

^ Note: Currently only Freshcare will be sharing data directly with Agriculture Victoria. If you are registering under any other GFSI scheme, you will need to provide some additional information and upload a copy of your most recent audit report.

* Note: These figures are indicative and subject to approval of regulations by Governor in Council and other parliamentary processes.

Standard 4.2.9 – Primary Production and Processing Standard for Melons requires businesses that grow or complete primary or ‘early-stage’ processing to identify and control food safety hazards associated with the growing and primary processing of melons. It also requires relevant businesses to have an approved food safety management statement which includes notifying regulators of their activities.

  • Melons have been defined in the standard as fresh melons and includes watermelon, rockmelon, honeydew melon and piel de sapo.
  • Examples of melons included are, but not limited to those listed and, galia melon, charentais melon, Korean melon, hami melon.

Registration Pathway 2 – GFSI Recognition

  • For melon businesses within recognised Global Food Safety Initiative (GFSI) schemes (such as Freshcare and SQF^), you will need to register and notify Agriculture Victoria of your certification. Provided your certification is maintained, and available for review and verification by Agriculture Victoria, your business will be immediately recognised as meeting the relevant standard.
  • Businesses will need to:
    • register on Agriculture Victoria Connect
    • provide business details
    • provide current GFSI certificate
    • approve data sharing with scheme owners
    • pay an annual registration and GFSI recognition fee: $33 to $849 per business scaled to production area*.

Registration Pathway 3 – FSMS Approval

  • For melon businesses not within recognised schemes, you will need to complete an online Food Safety Management Statement (FSMS) and participate in an audit to verify directly if the business is compliant with the Food Standards Code.
  • The online FSMS is completed as part of the registration process and includes several questions that:
    • summarise your business activities
    • identify your businesses food safety risks and how you manage them.
  • Businesses will need to:
    • register on Agriculture Victoria Connect
    • provide business details
    • provide detailed food safety data through the online FSMS
    • be audited by Agriculture Victoria
    • pay an annual registration and FSMS approval fee: $33 to $1632 per business scaled to production area, plus time-based travel and audit fees*.

^  Note: Currently only Freshcare will be sharing data directly with Agriculture Victoria. If you are registering under any other GFSI scheme, you will need to provide some additional information and upload a copy of your most recent audit report.

* Note: these figures are indicative and subject to approval of regulations by Governor in Council and other parliamentary processes.

Agriculture Victoria is working to implement these changes through a new registration scheme.

From 12 February 2025, businesses that grow or complete primary or ‘early-stage’ processing will need to register with Agriculture Victoria via the Agriculture Victoria Connect online system. Through this system, business must provide information demonstrating how they will meet the requirements of the standards. This includes explaining business practices on product traceability, managing safety of inputs such as water, worker hygiene and premises hygiene.

There are different requirements for different commodities and businesses, including the following:

  • Berry businesses will be required to inform Agriculture Victoria of how they are complying with the standards.
  • Leafy vegetable and melon businesses in recognised Global Food Safety Initiative (GFSI) schemes (such as Freshcare and SQF^) can notify Agriculture Victoria of their certification via their online registration, and this will be recognised as meeting the requirements. This recognition will reduce regulatory burden for businesses, avoid duplicative audits and reduce fees for businesses.
  • Leafy vegetable and melon businesses not in recognised schemes will need to submit a food safety management statement to Agriculture Victoria and participate in an audit to verify directly that their business is compliant with the Food Standards Code.

A food safety management statement (FSMS) is a document that:

  • summarises your business activities
  • identifies food safety risks and how you manage them
  • is approved by Agriculture Victoria
  • is checked and updated by you or your staff
  • can be verified by Agriculture Victoria (for example, through an audit).

There will be an annual fee to register with Agriculture Victoria through the online system and a fee for audits, where required. The fees will be scaled to the size of your business. Penalties may apply for failing to register and failing to follow these new standards.

^ Note: Currently only Freshcare will be sharing data directly with Agriculture Victoria. If you are registering under any other GFSI scheme, you will need to provide some additional information and upload a copy of your most recent audit report

These resources provide general best practice information regarding food safety in horticulture. They may be useful to consider when creating or reviewing your businesses food safety systems, particularly for business who do not currently operate under an existing industry food safety scheme.

I have seen information from Food Safety Australia and New Zealand (FSANZ) and from other States, and it seems there’s a slightly different approach. I’m confused.

  • Messaging from FSANZ is national. However, each state may vary on when and how the standards are implemented.
  • Once the standards are live from 12 February 2025, Victorian growers are required to log into Agriculture Victoria Connect to register and provide information about how they are meeting and complying with the standards.
  • While we expect businesses to make reasonable attempts to register soon after 12 February 2025, we understand that it’s a busy time in the season and there may be a short delay. We’re initially adopting and educative and awareness approach to registration.
  • Businesses that grow in multiple States will need to meet each state’s requirements for the standards.

How do I define my production area?

  • A business’s production area is the area of land (in hectares) under production or intended for production of the selected crop(s) for the next 1 year(s).

What Global Food Safety Initiative (GFSI) Schemes will be recognised?

  • GlobalG.A.P, Freshcare, Safe Quality Foods (SQF) and BRCGS are the recognised GFSI benchmarked schemes. If you are a member of Freshcare, your membership will allow you the most streamlined access.

Can you tell me more about the Food Safety Management Statement (FSMS) in Pathway 3?

  • If you are a leafy vegetable or melon business that falls under Pathway 3, you will create a FSMS as part of the online registration process through Agriculture Victoria Connect.
  • The online form includes yes/no questions, multiple choice questions and short responses focusing on the elements of the relevant standard such as traceability, inputs, premises and equipment management, your staff’s hygiene and food safety training, and your systems to manage unsafe product.
  • You will not be required to upload any documentation at the time of registration, but having supporting documents on hand will be helpful during the process. The online FSMS questions and information boxes will help you to understand what documentation you will need for the on-farm audit and to ensure ongoing food safety.
  • The FSMS requires approval by Agriculture Victoria. Following this, you will need to implement the agreed FSMS within your business. Agriculture Victoria will verify that you are implementing your FSMS through an audit.
  • We recommend growers read the Safe Horticulture Australia Guide to the Primary Production and Processing Standards for more information on best practice.

My business falls within Pathway 3. Will I be audited every year?

  • Yes, businesses who are in Pathway 3 will be required to complete an online FSMS and be audited annually by Agriculture Victoria.

What are the consequences of non-compliance?

  • The focus from 12 February 2025 will be on education and awareness. There will be a transition period before regulatory action will be taken by Agriculture Victoria, to allow time to build awareness of the requirements and for businesses to register. It is a legal requirement to register with Agriculture Victoria and follow the standards.
  • Enforcement activities for unregistered growers will be considered from 1 July 2025, noting the intention to work with growers before considering compliance options.

Are microgreens included in the leafy vegetable standard?

  • The leafy vegetable standard applies to fresh vegetables of a leafy nature where the leaf is consumed raw, included in that is microgreens. The standard applies to horticulture businesses that grow and/or harvest leafy vegetables.

I supply seedlings for the purpose of growing out to a larger plant. Do I need to register?

  • No, a person or business that sells seedlings for the purpose of growing on will be exempt from the standards. Any business that grows the seedlings into produce intended to be sold for human consumption or sells seedlings (such as microgreens) for human consumption, will be required to register.

What if my business is already registered with Local Government?

  • Some farm businesses may already be registered with local government (council) if they conduct substantial transformation, wholesale, food service, retail or off-farm processing activities. From 12 February 2025, depending on a business’s activities, registration will be required with Agriculture Victoria, local government, or both (see ‘Begistration requirements’ table). Businesses that grow or complete primary or ‘early-stage’ processing will need to register with Agriculture Victoria. Activities further along the supply chain will require continued registration with local government.
Registration requirements
ActivityAgriculture VictoriaLocal council
Growing/cultivating/harvestingYesNo
Early-stage processing: washing, trimming, sorting, sanitising or storingYesNo
Wholesale (as the sole activity)NoYes
Further processing: mixing, cutting, packingNoYes
Manufacturing (e.g. packaged salad meals)NoYes
RetailNoYes

Will my organics certification be recognised as meeting the standards?

  • Organic certification on its own will not be recognised. Organic producers are still required to register with Agriculture Victoria for the standards.
  • Organic producers that are part of a GFSI scheme will be recognised as meeting the standards via their GFSI scheme certification.

Producers not in a GFSI scheme will need to create and follow a FSMS.  Producers will create a FSMS as part of the online registration process through Agriculture Victoria Connect.

Page last updated: 13 Dec 2024