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Digital Labels and the Illusion of Transparency: What Happens When the Truth Lives Online?

New Zealand may soon shift from printed food labels to digital ones — a move presented as modern, efficient, and convenient.

QR-code labels are coming, and public consultation is now open. The language around the proposal is reassuring: “innovation,” “modernisation,” “consumer choice.”


Public consultation closes 19 December 2025.
Have your say here: https://www.mpi.govt.nz/consultations/proposal-to-enable-a-limited-trial-of-digital-labelling-on-certain-imported-food-products/


But step back for a moment.

What actually changes when the label moves online?

And — more importantly — what doesn’t?

Because the more closely we examine this proposal, the more one thing becomes clear: digital labels risk creating the illusion of transparency without ever delivering the substance.

And now, with a recent U.S. Court of Appeals ruling warning that digital-only GMO disclosure deprives consumers of meaningful, on-pack information, it’s worth asking the obvious question:

Are we about to repeat the same mistake?

The Promise of Progress — Or the Perfect Distraction?

The digital labelling trial, championed by the Minister for Food Safety, lets selected imported foods display certain mandatory information online instead of on the pack.

The pitch is familiar:

  • “More modern.”
  • “More efficient.”
  • “More convenient.”

But here’s the uncomfortable truth:

A QR code won’t fix what was missing in the first place.
If the information was limited before, it’ll be limited online too.

And nothing in the trial requires companies to reveal more than the bare minimum — certainly not the data consumers actually care about, like:

  • glyphosate residues
  • AMPA levels
  • pesticide panels
  • heavy metals
  • batch-specific testing
  • harvesting or processing history

A QR code doesn’t magically make food safer.
It just makes the box cleaner.

What Digital Food Labels Change — and What They Don’t

Printed labels have one unique strength that digital labels simply can’t replicate:

they are permanent.

Once the information is printed, it’s locked in. It can’t be mass-edited, blurred, overwritten, or quietly “corrected” without reprinting every single package.

Digital labels?
That’s a different game entirely.

Information can change:

  • tomorrow
  • next month
  • after a recall
  • after a complaint
  • after a journalist starts asking questions

And unless strict rules exist around version histories, time stamps, and audit trails, consumers will have no way to know what changed or why.

In other words:

Digital labels carry a built-in vulnerability:
truth becomes editable.

And the United States just proved why that matters.

In November 2025, the U.S. Court of Appeals ruled against the USDA’s attempt to push GMO disclosure primarily through digital QR codes — because it obstructed consumer access to essential information.

The Court made something very clear:

If a disclosure is important enough to require by law, it must be accessible to everyone — not only to people with smartphones, data plans, and steady reception.

New Zealand is now heading in the exact direction the U.S. court rejected.

Shouldn’t that make us pause?

The Accessibility Problem No One Wants to Admit

MPI’s consultation documents repeat a common reassurance:

“Some information will remain on-pack.”

But needing to insist on this is itself an admission:

Digital labels can fail.

And when they fail, people lose access to:

  • allergen warnings
  • ingredient lists
  • nutrition information
  • storage instructions
  • safety statements

Your phone dies.
The store has no reception.
The website is down.
The QR link breaks.
Your camera won’t scan.

If transparency only works under ideal conditions,
it isn’t transparency.

Who Really Benefits From Digital Food Labels?

Let’s be honest:

Digital labels are a dream come true for industry — not consumers.

They allow:

  • cheaper compliance
  • faster market access
  • instant global regulatory adjustments
  • real-time editing without reprints
  • fewer packaging constraints
  • less on-pack clutter, more marketing space

For consumers?
It’s a net zero — or worse.

Because what consumers actually want isn’t digital convenience.
It’s truth, traceability, and verified data.

And right now, New Zealanders get none of that.

The Transparency Gap: What Digital Labels Still Don’t Tell You

Here’s the heart of the issue — the gap no one in Government has acknowledged:

The biggest missing piece of transparency has nothing to do with QR codes at all.
It’s what’s not required on any label, digital or printed.

Not in the trial.
Not in the Review.
Not in current regulations.

Consumers have:

  • no access to glyphosate results
  • no AMPA numbers
  • no pesticide panels
  • no batch-level testing
  • no independent lab verification
  • no data from farm to shelf

Nothing.

Digital labels won’t change that.
They simply modernise the absence.

Real Transparency Means Showing Us the Data

If digital labels were being used for real reform, we would be talking about requiring:

  • independently verified residue testing
  • pesticide and heavy-metal disclosure
  • AMPA levels
  • batch specificity
  • lab accreditation
  • detection limits
  • historical data that can’t be deleted
  • immutable version histories

This isn’t science fiction — CleanScan is already doing it overseas.
QR codes can deliver real transparency.

But only if we require it.

What New Zealand’s Digital Labelling Trial Really Means

We’re at a crossroads — even if MPI hasn’t framed it that way.

Option 1: A genuine transparency overhaul
Use digital labels to reveal the data that matters: real residue testing, batch histories, risks, and independent verification.

Option 2: A compliance shortcut
Use digital labels to reduce printing costs, streamline imports, and make food appear modern while nothing meaningful improves.

Right now, we’re heading toward Option 2.

And once the industry gets comfortable with digital labels, it won’t be easy to reverse the shift.

Why Public Feedback Matters Before NZ Adopts Digital Labels

The U.S. Court of Appeals ruling should be a warning:

You can’t hide essential information behind a QR code.
Not legally.
Not ethically.
Not in the public interest.

If New Zealand doesn’t want to repeat the same mistake,
now is the moment to speak up.

Public consultation closes 19 December 2025.
Have your say here:
https://www.mpi.govt.nz/consultations/proposal-to-enable-a-limited-trial-of-digital-labelling-on-certain-imported-food-products/

Digital progress is fine.
Digital distraction is not.

New Zealand doesn’t need labels that look modern.
It needs labels that tell the truth.

If companies can provide allergen information,
they can provide residue information.

If they can publish ingredients,
they can publish AMPA results.

If they can print QR codes,
they can link them to something meaningful.

The technology is already here.
The precedent from the United States is already set.
The public appetite for transparency is growing.

The only question is whether New Zealand’s digital labels
will reveal anything that actually matters.


Resources and References

Have Your Say: MPI Public Consultation (Closes 19 December 2025)
Public input is now open on MPI’s proposal to allow limited use of digital labels on certain imported foods.

Digital trial to boost supermarket competition
Ministry for Primary Industries (MPI)
A media release announcing that the New Zealand Government is consulting on a trial of digital food‑labelling (on‑shelf QR codes, online info) for certain packaged foods, signalling a shift toward digital transparency mechanisms. 

Summary of Engagement Report – Product Labelling Regulatory Review
This official report summarises early feedback from stakeholders during New Zealand’s product labelling review process.

GS1 NZ: Review on Product Labelling
An industry-led review of labelling trends and expectations, including digital options. Helpful for understanding how NZ businesses may respond to the trial.

CleanScan: Transparency Through Technology
Clean the Sky
A food labelling initiative using QR codes to reveal verified residue testing and farming practices — a working model of what transparency could look like.

Detox Project: CleanScan Certification
Details the certification process for CleanScan, including lab test thresholds and what’s required for compliance.

Banza’s CleanScan labels provide access to glyphosate & pesticide tests
TrendHunter / CleanTheSky
This article describes how Banza (US chickpea‑pasta brand) uses the CleanScan QR‐code label system to publish batch‑specific lab results (glyphosate + 400+ pesticides) — a practical example of the transparency model your article advocates.

The Clean Label Movement
Agribusiness Academy
A global overview of how brands are using simplicity, traceability, and transparency as competitive advantages.

Related Articles on NoMoreGlyphosate.nz

Scan for the Truth: Why NZ Needs Real Food Transparency and QR-Code Lab Results
Explores how QR codes could deliver real transparency — if they were used to show residue testing and batch-specific data.

Digital Labels Are Coming to NZ — But Will They Reveal Anything That Matters?
A close look at MPI’s digital label trial and the risks of shifting transparency online instead of strengthening it.

NZ Product Labelling Review: The Problems the Digital QR Trial Ignores
What the Government’s own Review reveals about regulatory gaps, weak enforcement, and the transparency issues the digital trial doesn’t even touch.


Image Source & Attribution

The feature image on this page was created using canva.com 

No More Glyphosate NZ
No More Glyphosate NZ
No More Glyphosate NZ is an independent, community-funded project focused on transparency around glyphosate use, residues, and regulation in New Zealand. We investigate how pesticides, food production, and policy decisions affect public health and consumer clarity — so New Zealanders can make informed choices in a system that often hides the detail.
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