There’s a new food labelling trial coming to New Zealand — and on the surface, it sounds like progress.
Instead of relying solely on printed packaging, selected producers will soon be able to provide key product information online. Shoppers scan a QR code or barcode on the product, and up pops a digital version of the label.
The move is being championed by Food Safety Minister Andrew Hoggard and framed as a way to support innovation, reduce compliance costs, and offer consumers greater convenience.
But while the tech sounds slick, the underlying question remains:
Will digital labels actually improve transparency — or simply relocate the same old blind spots to a different platform?
Digital Labels Trial: Real Convenience or Regulatory Shortcut?
Public consultation on the trial is open until 19 December 2025. If it goes ahead, selected food producers will be invited to register their interest — and many are likely to, given how burdensome current labelling rules are seen to be.
According to the Government’s own regulatory review, more than 65% of submitters said labelling rules impose unnecessary compliance costs. That’s the backdrop to this trial. Easing cost pressures is a valid goal — but reducing compliance costs is not the same as improving transparency.
And that’s where this proposal feels incomplete.
Have your say here: Proposal to enable a limited trial of digital labelling on certain imported food products. [Look for the SurveyMonkey link.]
What the Digital Labels Trial Covers — and What It Doesn’t
At its core, this is a compliance experiment. Producers will be allowed to publish certain mandatory information online rather than on the product packaging itself. The types of info being trialled include:
- ingredient lists
- allergen declarations
- nutrition panels
- storage instructions
It’s primarily aimed at easing market entry for imported or niche products, particularly for smaller players navigating New Zealand’s food labelling system.
On paper, that all sounds reasonable.
And this idea didn’t come out of nowhere. In fact, it featured prominently in the Government’s recent Product Labelling Regulatory Review. Stakeholders explicitly called for the ability to provide this kind of information digitally — especially using QR codes and 2D barcodes to reduce duplication, solve space limitations, and streamline compliance.
But here’s the catch: under current rules, mandatory label information still has to be printed on the product itself. This trial is testing whether that should change — and if so, what digital compliance might look like.
So while it may sound like a harmless modernisation, it’s also a potential regulatory turning point.
And here’s what no one’s addressing:
Will any of this give consumers better access to agrichemical data, chemical residues, or independent testing results?
Because as it stands, the digital label is just the same label… moved to a website. The format changes. The transparency doesn’t.
What Happens When a Label Depends on Your Phone?
Imagine standing in a supermarket. Your phone has no reception. You’ve run out of data. The store’s Wi-Fi doesn’t connect. Your battery’s nearly dead.
And that’s assuming you even have your smartphone with you — which might not be the case when you’ve just dashed in to grab a last-minute ingredient on the way home.
You scan the QR code… and nothing happens.
That’s not a hypothetical. That’s real life. And it’s why MPI has already had to reassure the public that “some information will remain on-pack.”
But that’s not a feature. That’s a flaw. It’s an admission that digital-only labels are vulnerable — and food safety information shouldn’t rely on:
- a working smartphone
- stable reception
- an active data plan
- browser compatibility
- or a company website being up and running
Even the Government’s own Product Labelling Regulatory Review raised red flags. It warned that QR code–based labelling could disadvantage people with limited access to mobile data, low digital literacy, or vision impairments.
So while digital labels might seem like a step forward, they risk excluding exactly the people who need clear, reliable food safety information the most.
We don’t tolerate “offline errors” in aviation safety.
So why would we in food safety?
Digital Labels Can Be Changed — And That’s a Risk
There’s another quiet shift happening here — one that should raise eyebrows.
When something is printed on a packet, it’s permanent. It can’t be silently changed without reprinting the whole box. But digital labels? They can be updated at any time, without any obvious trace.
Version histories can exist. But will they?
And more importantly — will anyone check them?
A digital label makes it easier to quietly edit or reframe uncomfortable information. It lets companies “correct” things after a public backlash. It creates a layer of distance between what was said and what is being shown — and that’s not an upgrade.
For companies that want to look transparent without being transparent, dynamic labels offer a perfect smokescreen.
The Real Problem: What’s Missing From Food Labels Entirely
Let’s be clear: what’s being digitised in this trial is only what’s already required by regulation — the bare minimum.
And here’s what that doesn’t include:
- glyphosate residues
- AMPA levels
- pesticide panels
- heavy metal content
- desiccant residues
- batch-level chemical testing
- water or soil contaminant data
None of this has ever been part of the label — and nothing about this trial changes that.
We’re simply moving the same limited information to a new format. It’s the same window dressing, just hung on a new wall.
More Accessible — But Still Missing What Matters
MPI says this trial is about giving consumers “more accessible information.” But that phrase skips over the real issue.
More accessible what?
Because we already have access to ingredient lists. We already have nutrition panels. We already know whether the label says “may contain traces of nuts.”
What we don’t have — and what we need most — is access to:
- actual residue data
- batch-specific testing
- independent chemical analyses
- transparency around glyphosate and AMPA
- explanations of risk, not just regulatory compliance
That’s the gap. And nothing in this digital label trial suggests it’s about to be filled.
Digital Labelling: Transparency Tool or Cosmetic Fix?
This trial could go one of two ways.
Option 1: Real Transparency
Some companies step up. They use the QR code not just to meet the minimum but to publish:
- independent lab tests
- full residue profiles
- batch numbers and harvest dates
- explanations of farming methods
- verification from third-party labs
This is what CleanScan has pioneered overseas — and it’s outlined in full in our companion article:
From Labels to Lab Tests: Why New Zealand Brands Should Let Us Scan for the Truth
Option 2: Cosmetic Compliance
QR codes become a compliance shortcut — a way to reduce printing costs, avoid physical recalls, and edit product information on the fly. Meanwhile, nothing meaningful improves. The consumer gets a cleaner-looking experience, with none of the actual transparency.
It all depends on whether brands treat this as a trust-building tool… or a convenient façade.
What Real Transparency Would Look Like on a Digital Label
If we’re going to digitise labels, let’s use that opportunity wisely.
A responsible digital label could — and should — include:
- glyphosate and AMPA test results
- multi-pesticide residue panels
- clear detection limits and lab accreditation
- batch-specific data, time-stamped and archived
- historical test results that remain publicly viewable
- explanations of what the numbers mean — and why they matter
This isn’t impossible. It’s not even expensive.
The technology is already here. The QR codes are already being printed.
The only thing missing is the will to use them for good.
Where This Trial Might Take Us — and Why It Matters
This trial could reshape how food information is delivered in New Zealand. But if we’re not careful, it could also normalise a model where “transparency” becomes a moving target — subject to bandwidth, battery life, and brand spin.
Because once we shift labels online, the next decisions become political:
- What information must be included?
- Who gets to decide what stays visible?
- What counts as “sufficient transparency”?
- Can data be overwritten — or deleted entirely?
If those questions aren’t answered with public interest at the centre, the outcome will reflect industry convenience — not consumer safety.
We’re Not Against Tech — We’re Against Empty Promises
We support digital tools that improve real transparency. But we don’t support vague initiatives that modernise the format while ignoring the content.
Digital labels must never replace critical on-pack information.
Food safety info — especially allergens and warnings — should not require a working phone.
Digital labels must include a clear, verifiable edit history.
If something changes, consumers deserve to know what, when, and why.
Chemical residue testing belongs on the label — digital or not.
QR codes should connect consumers to test results, not just slogans.
Historical data must remain visible.
No disappearing batches. No tidy PR clean-ups. No revisionist labelling.
If companies want trust — they need to earn it.
And the fastest way to earn it is to show us the data.
Let’s Use This Technology for What It Was Built For
We’re not against QR codes.
We’re against QR codes being used as a way to avoid hard truths.
If companies can show us their ingredients,
they can show us their glyphosate levels.
If they can publish allergen data,
they can publish AMPA and pesticide results.
If they’re already printing the codes,
they can link them to something that actually matters.
The infrastructure is here.
The public expectation is rising.
And the credibility gap is growing.
Let’s not waste this moment.
Part of Labels Without Truth: A Three-Part Investigation
This article is part of Labels Without Truth: A Three-Part Investigation, our three-piece deep dive into New Zealand’s food labelling system, the rise of QR-code “transparency,” and the growing public demand for real, verifiable information.
Part 1: Scan for the Truth: Why NZ Needs Real Food Transparency and QR-Code Lab Results
How CleanScan-style lab reporting overseas is redefining trust — and why New Zealand brands could (and should) lead the way.
Part 2: Digital Labels Are Coming to NZ (You are here.)
MPI’s digital labelling trial promises convenience, but does it actually deliver transparency — or just move blind spots online?
Part 3: 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.
Resources & References
Digital innovation isn’t inherently good or bad — it depends on how it’s used. Below are key resources that expand on the issues raised in this article, from government proposals and Clean Label initiatives to industry critiques and public consultation links. These provide vital context for understanding where New Zealand’s digital food labelling trial might be headed — and what’s at stake.
Scan for the Truth: Why NZ Needs Real Food Transparency and QR‑Code Lab Results
A companion article that explores how digital labels could go beyond the basics to include independent chemical testing and batch-specific data.
Digital Trial to Boost Supermarket Competition
NZ Government / Beehive.govt.nz
Official announcement from Food Safety Minister Andrew Hoggard about the proposed digital food label trial.
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.
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.
The Glyphosate-Free Clean Label Shift
An in-depth look at how “glyphosate-free” is becoming part of the clean label movement — and how that intersects with QR-code labelling.
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.
The Clean Label Movement — Agribusiness Academy
A global overview of how brands are using simplicity, traceability, and transparency as competitive advantages.
Summary of Engagement Report – Product Labelling Regulatory Review
This official report summarises early feedback from stakeholders during New Zealand’s product labelling review process.
The trial may be framed as a step forward — but that depends on where it actually leads. These resources can help inform your perspective, sharpen your questions, and strengthen your voice in the conversation.
Let’s make sure digital progress doesn’t come at the cost of real-world transparency.
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