EventsFood safetyLabelling

Canned drinks at pop-ups: NZ food safety and labelling guide

What New Zealand food law asks of anyone sealing drinks into cans at markets, pop-ups and events: when a full label is not needed, and the registration, allergen, food safety and alcohol rules that still apply.

15 October 2026· Jordan Smith

Overview

Sealing drinks into cans to order is a popular way to sell at markets, pop-ups and events. This guide sets out what New Zealand food law asks of sellers doing it, covering labelling, registration, food safety and alcohol.

The key point is that drinks canned in front of the buyer, or made and canned at the stall they are sold from, do not need a full printed label. That exemption covers the label only. Food Act registration, allergen information, temperature control and, where alcohol is involved, a liquor licence all still apply.

This guide is general information only, current as at October 2026. Read the disclaimer at the end before relying on it.

No full label needed: drinks canned in the presence of the buyer, or made and canned at the stall they are sold from (Food Standards Code, Standard 1.2.1).
Full label needed: drinks canned in advance at home, in a kitchen or by a co-packer, then brought to the event to sell.
Common practice: cafés, delis and bubble tea shops rely on the same exemptions. They work because the buyer can ask the seller directly, so anyone serving must be able to answer allergen and ingredient questions on the spot.

The labelling exemptions

In NZ, food labels must follow the Australia New Zealand Food Standards Code, alongside the Food Act 2014 (MPI, labelling food for retail sale). MPI lists the food that does not need a label: food "packaged in front of the customer", food "made and packaged at the same place it is sold", and food sold at a fundraising event. These match section 1.2.1—6(1) of the Code. Three are relevant to a drinks pop-up.

Exemption (1.2.1—6(1))	How it applies to canned drinks	Confidence
(b) Packaged in the presence of the purchaser	Your customer orders, then you pour the drink and seal the lid in front of them. The cleanest fit.	High, plain reading of the text
(a) Made and packaged on the premises from which it is sold	Drinks mixed and canned at the stall during the event, then sold from a chiller there.	Medium. Whether a temporary stall counts as "premises" is not defined in 1.2.1. Confirm with the council or MPI.
(e) Sold at a fund raising event	Only for genuine fundraising, not a commercial pop-up.	High that it does not apply to a business

What does not qualify: cans filled and sealed at home, a commercial kitchen or a co-packer, then brought to the event. That is pre-packaged food and needs the full label under 1.2.1—8, including name, business name and NZ address, lot identification, date marking, ingredients, allergen summary, nutrition information panel and storage directions where needed.

The Code does not say the sealing must happen at the event, only that it happens in front of the buyer or at the place of sale. Pre-canning a stock of drinks in the morning at a separate kitchen breaks the exemption.

What still applies without a label

The exemption moves the information off the can. It does not remove it. Section 1.2.1—9 sets out what you must still give your customers when you sell without a label.

Information	How it must be given	Notes for a drinks stall
Allergen information (milk, soy, tree nuts, sesame and so on)	Displayed with the drinks, or provided on request	MPI says unlabelled food must have product information, such as allergens, available on request (MPI). The plain English allergen rules apply from 25 February 2024 (MPI). Name the specific allergen, for example "almond". Staff must know the answer.
Name of the drink, advisory statements	Displayed or on request	A menu board covers this.
Mandatory warning statements (Code 1.2.3—3)	Displayed with the food or accompanying it	Not usually triggered by common drinks. Check the ingredient list against 1.2.3—3.
Advisory statements for formulated caffeinated beverages	Displayed or on request	Relevant if selling energy-drink style products.
Nutrition panel	Only if a nutrition or health claim is made	Saying "low sugar" or "high in vitamin C" brings this back in.

Three practical additions, not strictly required by the label exemption but strongly advised:

A small sticker on each can: drink name, business name, "Keep refrigerated" and "Drink within 24 hours" (or whatever shelf life you can justify).
A printed allergen and ingredients sheet on the counter.
A lot or date record for each batch, so a problem can be traced.

Registration under the Food Act 2014

A business selling drinks at pop-ups more than once a year must be registered. The label exemption has no effect on this.

Business model	Likely registration	Register with
Drinks made and sealed to order at the stall, for drinking now (bubble tea, mocktails, cold brew)	Food Control Plan, usually MPI's template for food service and retail. MPI's case study of an event stall selling soft drinks, tea and coffee sits here (MPI case studies).	Local council (home council for a mobile business)
Drinks made and canned in a kitchen as a product, sold at events, shops or online	National Programme 3. MPI lists "manufacture non-alcoholic beverages" under NP3, medium to high risk (MPI NP3 guidance, 2017). A custom FCP is the alternative.	Council (NP) or MPI (custom FCP). A verifier letter is needed before registering (MPI).
Genuine fundraising, fewer than 20 times a year, or one event a calendar year	Exempt from registration. Food must still be safe and suitable (MPI).	None

Event organisers are expected to check every stallholder's registration, and Auckland Council says so explicitly (Auckland Council). Expect to be asked for the notice of registration.

Note: if most cans leave the event unopened and are drunk days later, a verifier may view the activity as beverage manufacture rather than food service, whatever happens with the label. Describe your full model to the council before choosing a plan. MPI's NP3 guidance is from 2017, so confirm the current classification with MPI (0800 00 83 33).

Food safety risks of canning drinks

A sealed can looks shelf stable but is not. Without heat treatment or a validated recipe, a drink sealed at a stall is a perishable product in an airtight, low-oxygen container, and your customers may leave it in a hot car or pantry for days.

Risk	Why it matters	Control
Botulism in low-acid drinks	C. botulinum grows in sealed, low-oxygen packaging, and some strains grow at fridge temperatures down to 3 °C (ESR risk profile for MPI, 2012). That profile covers sealed seafood, but the same conditions apply to a sealed can of a low-acid drink. Cold brew, milk tea, plant milks and vegetable juices are the main concern.	Keep cold from making to drinking, short use-by, "Keep refrigerated" on the can. Do not sell low-acid drinks for take-home storage without specialist process advice and verifier sign-off.
General spoilage and pathogens	Fresh juice, dairy and syrups grow bacteria above 5 °C. Cans can swell or burst.	Keep cold items at 5 °C or colder, including in transport (Marlborough District Council). Time limits out of the fridge come from your registered food control plan, so follow that.
Carbonation and gas	Over-carbonated or still-fermenting drinks (kombucha, fresh fruit) can over-pressurise a sealed can.	Avoid canning actively fermenting drinks at events. Leave correct headspace.
Seal failure	A poorly sealed lid leaks or lets contaminants in.	Use lids matched to the can, check seals regularly, follow the sealer's setup guide.
Can and lid hygiene	Open cans at an outdoor stall collect dust and insects.	Store cans inverted and covered, use food-grade cans and lids from a traceable supplier.
Ice and water	Ice used in drinks is food.	Use potable water and ice from a safe source, not the cooling ice for the chiller.

The safest model is seal-and-drink: canned to order, drunk at the event or within a day, kept cold. The further it moves towards take-home stock, the more it looks like beverage manufacturing with process validation needed.

If the drinks contain alcohol

Canned cocktails need a liquor licence under the Sale and Supply of Alcohol Act 2012, on top of everything above. Apply to the local council's district licensing committee at least 20 working days before the event (Ministry of Justice).

On-site special licence: alcohol drunk at the event. Usually held by the event organiser, with stallholders operating under it.
Off-site special licence: alcohol taken away. The Ministry's guidance limits this to the licensee's own alcohol, for example a producer selling what it makes.

A sealed can makes take-away easy, which is exactly what an on-site licence does not allow. Confirm with the licensing inspector whether cans may leave the event, and what manager and host responsibility conditions apply. The Ministry's page was last updated in December 2020, so check current requirements with the council.

Recommended setups compared

Seal-to-order at the stall is the right model for most pop-ups. Pre-canning only makes sense once you are ready to run a registered beverage manufacturing operation.

	Seal-to-order at the stall	Pre-canned and labelled
Full printed label	Not required (1.2.1—6(1)(b))	Required (1.2.1—8)
Food Act registration	Food Control Plan, usually template, via council	National Programme 3 or custom FCP, verifier needed first
Allergen info	Menu board or counter sheet, staff can answer	On the label
Shelf life	Hours to a day, kept cold	Must be validated for the claimed date
Speed of service	Slower, each can filled and sealed per order	Fast, grab from chiller
Sell elsewhere (shops, online)	No	Yes
Main risk	Queue times, cold chain at the stall	Process validation, botulism for low-acid drinks, recall readiness

A hybrid works well: batch the drink in a registered kitchen, transport it cold in bulk, then fill and seal each can at the stall when ordered. The label exemption still applies because the packaging happens in front of the buyer. The kitchen preparation must be covered by your registration.

Checklist for you

Decide the model: seal-to-order, pre-canned, or hybrid
Call the home council's environmental health team, describe the model, and confirm the plan type (template FCP, NP3 or custom FCP)
Register before the first paid event and keep the notice of registration at the stall
Write an allergen and ingredients sheet using the specific allergen terms, and brief all staff on it
Set a cold-chain routine: ingredients and filled cans at 5 °C or colder, thermometer at the stall, temperature log
Add a simple can sticker: drink name, business name, "Keep refrigerated", drink-within time
Check seal quality at the start of each event and every few hours
Avoid low-acid drinks for take-home unless you have specialist process advice
If alcohol is involved, talk to the council licensing inspector about on-site vs off-site special licences, 20+ working days out
Ask each event organiser for their food and alcohol requirements early

In short: sealing in front of the buyer lets you use the label exemption legitimately, but registration, allergen information and cold chain remain your responsibility. Your council makes the final call.

Disclaimer

This guide is general information for people selling canned drinks in New Zealand. It is not legal, regulatory or food safety advice, and it does not take into account any particular business, product or event.

Current as at October 2026. Laws, standards and official guidance change. Check the current versions before acting.
Your responsibility. Anyone producing or selling food or drink is responsible for complying with the Food Act 2014, the Food Standards Code, the Sale and Supply of Alcohol Act 2012, and any council or event rules. Confirm your situation with your local council, MPI, your food safety verifier or a licensing inspector, and get professional advice where needed.
No guarantee. Candin has taken care preparing this guide but makes no promise that it is complete, accurate or suitable for your circumstances. Following it does not guarantee registration, approval, a licence or compliance.
Equipment is not compliance. Using a can sealer or any other equipment does not by itself make a product safe or legal. Always use equipment in line with the manufacturer's instructions.
Limitation of liability. To the extent permitted by law, Candin is not liable for any loss or damage arising from use of, or reliance on, this guide. Nothing in this disclaimer limits any rights you have under the Consumer Guarantees Act 1993 or the Fair Trading Act 1986 that cannot be excluded.
Third-party links. Links to MPI, councils and other sources are provided for convenience. Candin does not control or endorse that content.

Sources and confidence

Your council or verifier makes the final call on your registration.

Verified from primary sources: the six label exemptions in 1.2.1—6(1) and the information rules in 1.2.1—9 (June 2026 compilation); fundraising exemption limits; registration routes; special licence types and the 20 working day lead time.

Inferred or to confirm: whether a temporary stall counts as "premises" for exemption (a); whether take-home canning shifts the activity to beverage manufacturing; current NP3 classification for non-alcoholic drinks (source is 2017); whether the alcohol pregnancy warning applies to exempt cans.