Wine Standards Management Plan (WSMP): the records your verifier will ask to see

Under the Wine Act 2003, most wine businesses in New Zealand must make wine under a registered Wine Standards Management Plan (WSMP). The plan says how you control hazards and keep wine fit for its intended purpose; your records are the proof that you follow it. When the verifier turns up, it is the records they spend most of the visit on. This guide sets out who needs a plan, how registration and verification work, and what MPI’s integrated WSMP model (version 2, November 2024) says you must record.

Who needs a WSMP

MPI treats you as a wine business if you do any of the following:

• Crushing or pressing a commodity (grapes, fruit, honey…) for juice.
• Fermenting juice into wine.
• Making additions to juice or wine.
• Storing, blending or mixing wine.
• Bottling or otherwise packaging wine.

A plan is linked to a place where wine is made. If several winemakers share a winery, MPI allows three set-ups: each has their own WSMP; one WSMP covers the site and one winemaker takes responsibility for everything made there; or one WSMP is shared and every winemaker makes sure their records are available at verification. Whichever you choose, write down who is responsible for what.

Exemptions: small winemakers, labellers and storage

Some businesses are exempt from operating under a registered WSMP, though they must still follow the Wine Act:

• Small winemakers who make less than 20,000 litres of wine over two years, notify MPI of the dates of that two-year period, and do not sell any wine for export. You apply with form WA3 before you make any wine, you appear on a public register, and the exemption lasts two years — before it ends you either notify MPI that you intend to renew or register a WSMP (Wine Regulations 2021, clause 19). MPI runs random audits of exempt winemakers.
• Businesses that only label wine bottles and packaging (clause 17).
• Businesses that only store wine after it has been bottled and before any further winemaking process (clause 18).

Wine made outside a registered WSMP — under a small winemaker exemption, for example — that is blended with or added to WSMP wine makes that wine ineligible for export (integrated WSMP model).

Choosing a plan and registering it

There are three types of WSMP: MPI’s integrated WSMP model, a pre-evaluated plan; New Zealand Winegrowers’ WSMP Code of Practice v3.1, also pre-evaluated and written for grape wine; or a custom plan, which must be independently evaluated. Registration then runs like this:

• Contract a verifier from a recognised agency and get a letter or email confirming they will verify your WSMP at every site where winemaking happens.
• Send application form WA4 to MPI with proof the registration fee is paid, a copy of your completed WSMP including site plans, the verifier’s confirmation and, for a custom plan, the evaluation report.
• Wait for MPI’s notice of registration — only then may you start making wine.
• Get your first verification within six months of registration. You cannot export any wine until the plan has been verified.

After that first visit, which sets your anniversary date, a winery making wine for export must be verified every 12 months. A business that performs well and makes wine for the domestic market only may have its frequency reduced to once every 24 to 36 months.

The ground rules for records

Records can be on paper or electronic, in whatever form suits you. The integrated model sets the standard they have to meet:

• Accurate and easy to read, and each one shows what was done, when, and who did it.
• Kept for at least 7 years.
• Provided within 2 working days when requested — or within 24 hours if they relate to traceability.
• Available to your verifier, a Wine Officer or a person authorised by MPI’s Director-General.
• Any document that is part of the WSMP is dated or marked for version control.

What to record from the vineyard to the bottle

When you receive grapes or any other commodity, record the supplier, the date, the quantity, any sprays or agricultural compounds applied, and whether contamination has or may have occurred (and what you did about it). For New Zealand grape wine you must also record the withholding period of each spray, the last date each spray was used, and any inputs added in the field, such as SO₂. If you buy in juice or wine, record the WSMP identification number it was made under.

In the winery, the model lists what to capture at each step for NZ grape wine where you make claims about variety, vintage or region:

• Receival: country of origin, region, variety, vintage, supplier, spray diary, weight and additions.
• Juice extraction: volume of juice and additions (SO₂, enzymes, acid).
• Fermentation: volume and additions (sugar, nutrients, yeast).
• Storage and racking: volume and batch additions, including wine used for topping up.
• Blending and filtering: volume and batch additions (SO₂, finings).
• Pre-dispatch for packaging or bulk: volume and additions (SO₂, gas).

You must also record the type and amount of every commodity and winemaking input used in each batch, identify each wine at every step (by label or production records), record every movement between sites, and record any adjustment made while the wine is in off-site storage or being bottled — plus the WSMP it was made under. The aim is a chain from the packaged wine back to the vineyard.

What the verifier checks

Traceability is at the centre of the visit. Expect the verifier to:

• Ask how you know your commodities and inputs are suitable for wine, and look at your receival records.
• Run a tracing test — from an input you received, or from a batch of wine you made.
• Ask for evidence behind label claims about vintage, region and variety.
• Check your simulated recall, which must be done at least every 12 months, with its effectiveness measured (the percentage of wine traced and how long it took).
• Check that self-supplied water is tested at least once a year and within a week of any event that could affect its quality.
• Ask whether anything has changed since the last visit in what you make, do or sell, and how you know your contractors operate under the right registered plan.

Plans also had to be brought up to date after the 2022 regulatory redesign: since 1 July 2023, a WSMP that has not moved to the new model, the Code of Practice v3.1 or an updated custom plan gets an “unacceptable” verification outcome.

Deadlines for telling MPI

• Within 24 hours of becoming aware of a critical non-compliance (CNC) or export non-compliance (ENC).
• Within 30 days of changing your day-to-day manager or your verification agency, of changing what you make or do so that the WSMP no longer covers it, or if you think the WSMP is no longer managing risks.
• Within 20 days if you stop using your WSMP.

Common gaps

• A weigh tag with no link to the block’s spray record, so withholding periods cannot be shown.
• Top-ups and small blends that never make it into the batch record.
• Additions made by a contract bottler that you cannot see.
• A recall procedure that has never been tested, or a simulated recall with no measure of effectiveness.
• Records spread across notebooks and spreadsheets that cannot be pulled together within 24 hours.

GrapeFlow can hold these underlying records in one place: blocks and the spray diary, weigh tags at harvest intake, every addition, transfer, blend and analysis lot by lot, and bottling with a recall report that traces a lot up- and downstream. It doesn’t replace your WSMP, isn’t approved by MPI and submits nothing on your behalf — but it makes the tracing test far less painful.