Most people haven’t heard about MPI’s new “digital labelling trial.” And honestly? That’s probably the point.
Food labelling is one of those everyday systems we barely think about — until something changes. We pick up a jar or a box and trust that what we need to know is printed clearly on the pack. Ingredients, allergens, where the food comes from… it’s meant to be simple. It’s meant to be reliable. And it’s meant to stay within arm’s reach, not hide behind a QR code.
So when the Ministry for Primary Industries (MPI) quietly announced a “digital labelling trial,” framed as a harmless one-year test using QR codes to “improve transparency” and “lower grocery prices,” it sounded benign enough. But the moment you look a little deeper, you begin to see something else emerging. Not a tidy little experiment. Not a one-off pilot. Something bigger. Something that could reshape how New Zealanders interact with food labels for years to come.
Which brings us to the question almost no one in government appears willing to ask out loud: what happens when key information disappears from the physical label and is placed behind a QR code instead?
Is MPI’s Digital Labelling Trial Really Just a Trial — or a Permanent Shift?
MPI presents this as a feasibility study. A test run. Nothing binding. Nothing major.
Yet the language accompanying the proposal hints at something far more long-term. References to “digital pathways for future compliance,” “reducing barriers for imported products,” and “lowering costs for retailers and consumers” do not sound like the vocabulary of a limited experiment. They sound like early-stage planning for a larger regulatory shift.
And we’ve already seen how quickly cost-saving measures reshape New Zealand’s food landscape. When Wattie’s dropped local growers in favour of cheaper imports this year, it wasn’t a one-off event — it was evidence of an economic trend that prioritises lower-cost imports over local production. Digital labelling fits neatly into this pattern by lowering compliance costs and making imported food even easier and cheaper to bring into the country.
This isn’t directly about glyphosate — but it cuts to the heart of why we exist: transparency. If information starts shifting off the physical packaging now, we lose ground in the broader fight for honest chemical disclosure tomorrow.
Do Shoppers Actually Scan QR Codes in Supermarkets?
Some people do. Many don’t. And a surprising number simply can’t.
- elderly shoppers
- people in rural areas with patchy reception
- shoppers without smartphones
- tourists unfamiliar with the system
- people with limited eyesight
- busy parents who simply don’t have time to scan multiple products
Yet MPI’s proposal assumes a supermarket full of shoppers ready to pull out their phones, navigate digital menus, and read ingredient lists online — every single time.
Is that equitable?
Is it accessible?
Or is it shifting responsibility away from businesses and regulators and onto the shopper?
Why Digital Labels Create Risks for Allergy Sufferers
Imagine standing in an aisle with a child who has a peanut allergy. You shouldn’t have to hope the supermarket has good reception, or your phone is charged, or that the website behind a QR code is still functioning. You need certainty, and you need it now. “Contains peanuts” should be visible on the physical label. Clear. Immediate. Unconditional.
Digital labelling undermines that clarity the moment a phone battery dies or a QR code leads nowhere.
The Enforcement Gap: How Would Digital Food Labels Be Regulated?
This is where the entire proposal becomes almost unworkable. How does a trading standards officer verify thousands of digital labels?
Do they scan every QR code?
Every time a product batch changes?
Every time a website updates?
There is no practical enforcement model, and MPI hasn’t offered one.
If physical labels — fixed, static, and printed — are already difficult to police, how are we supposed to regulate a system where key information lives online, can change at any time, and may not even be archived?
Digital labels are not simply inconvenient; they are almost impossible to monitor.
Why MPI Is Pushing Digital Labelling — and Who Benefits
MPI says digital labelling will lower prices, reduce trade barriers, and improve efficiency. But lower prices only appear under one scenario: when retailers replace New Zealand-grown products with cheaper imports.
Digital labels make this easier by reducing the costs associated with relabelling, streamlining compliance, and allowing ingredient or origin changes with minimal consumer visibility.
That raises a reasonable question: is this trial truly about transparency for consumers — or convenience for importers?
What Digital-Only Food Labelling Means for NZ Consumers
Consider the kind of supermarket this sets us up for:
- Products with minimal on-pack information
- Allergy warnings hidden behind links that may or may not work
- Origins that change quietly without consumer knowledge
- Labels you can only interpret if you have a smartphone and reliable data
Is that progress?
Or is it a slow, quiet erosion of consumer rights presented as modernisation?
What Safeguards Are Needed for a Safe Digital Labelling Trial
If the trial goes ahead, it needs tight limitations and real safeguards. Physical labels should remain mandatory, QR codes should supplement rather than replace, and only a small, controlled range of products should be included. High-risk foods should be explicitly excluded. Digital pages must be static, archived, and transparent about changes. And independent oversight is essential.
Without firm protections in place, the trial risks becoming more than a test run. It becomes a quiet Trojan horse for dismantling the physical labelling system New Zealanders rely on every day.
What NZ Consumers Can Do About the Digital Labelling Proposal
If this trial proceeds in its current form, the way New Zealand shops for food could change permanently. Your ability to check ingredients, allergens, and origins without a device is on the line.
If you believe essential information should stay on the packaging — not behind a QR code — now is the time to speak up. Public submissions close on 19 December. You don’t need to write an essay. A few clear sentences are enough.
Use this link to learn more about MPI’s Proposal to enable a limited trial of digital labelling on certain imported food products and to have your say.
New Zealanders deserve a food system built on clarity, not codes. Your voice can help ensure we don’t lose that clarity in the name of “innovation.”
Share this article.
Tell a friend.
Ask your local MP why food transparency is being quietly traded away.
Related Reading: Labels Without Truth Mini-Series
If you’re following New Zealand’s wider shift toward QR-code “transparency,” you might also be interested in our Labels Without Truth mini-series — a three-part investigation into how digital labelling, weak enforcement, and disappearing information are reshaping what we think we know about our food.
Part 1 — Scan for the Truth: Why NZ Needs Real Food Transparency
https://nomoreglyphosate.nz/scan-for-the-truth-food-transparency-nz/
Part 2 — Digital Labels Are Coming to NZ — But Will They Reveal Anything That Matters?
https://nomoreglyphosate.nz/digital-food-labels-nz-trial-transparency/
Part 3 — NZ Product Labelling Review
https://nomoreglyphosate.nz/nz-product-labelling-review-digital-labels/
Each piece explores a different angle — from QR-code lab results to MPI’s digital labelling trial — and together they paint a bigger picture of where New Zealand’s food transparency may be heading.
Resources & References
Before we rush into a future where the most important details about our food live behind a QR code, it’s worth stepping back and looking at the evidence. The resources below highlight what’s at stake — from allergen safety to consumer rights, from enforcement gaps to the simple fact that most people still rely on physical labels to protect their families.
Proposal to Enable a Limited Trial of Digital Labelling on Certain Imported Food Products – MPI
MPI’s official consultation document outlining the scope, conditions, and justification for the digital-labelling trial.
https://www.mpi.govt.nz/consultations/proposal-to-enable-a-limited-trial-of-digital-labelling-on-certain-imported-food-products
Scan for the Truth: Food Transparency in New Zealand
Our overview of why digital labels threaten transparency, accessibility, and trust in the food system.
https://nomoreglyphosate.nz/scan-for-the-truth-food-transparency-nz/
Digital Food Labels NZ: Transparency or Tech Trick?
Explores how QR codes reduce clarity for consumers and create new barriers for anyone without a smartphone or reliable reception.
https://nomoreglyphosate.nz/digital-food-labels-nz-trial-transparency/
NZ Product Labelling Regulatory Review – Digital Labels
A deeper look at longstanding gaps in New Zealand’s labelling framework, and why digital labels won’t fix enforcement or transparency issues.
https://nomoreglyphosate.nz/nz-product-labelling-review-digital-labels/
Allergen Declarations, Warnings, and Advisory Statements – MPI
Explains New Zealand’s mandatory allergen labelling requirements and why clear, physical labels are critical for consumer safety.
https://www.mpi.govt.nz/food-business/labelling-composition-food-drinks/allergen-declarations-warnings-and-advisory-statements-on-food-labels/
Evaluating the Use of QR Codes on Food Products
A peer-reviewed study examining how consumers interact with QR-code food labels, highlighting low usage rates and accessibility issues.
https://www.mdpi.com/2071-1050/14/8/4437
Allergen Labelling: Current Practice and Public-Health Concerns
A review of allergen labelling challenges, demonstrating why easy-to-read physical labels remain essential for health protection.
https://pmc.ncbi.nlm.nih.gov/articles/PMC8048984/
A Discussion of Labels as a Vector for Food Information – University of Otago
Explores how consumers use labels, common barriers to understanding, and the risks of shifting mandatory information off-pack.
https://www.otago.ac.nz/__data/assets/pdf_file/0018/321552/a-discussion-of-labels-as-a-vector-for-food-information-640011.pdf
Food Labels and Public Health – CPD Online
A clear overview of how food labels support consumer safety, including nutrition, allergen, and ingredient information.
https://cpdonline.co.uk/knowledge-base/food-hygiene/food-labels-health-safety/
How to Make a Submission That Gets Noticed – No More Glyphosate NZ
A practical guide to help readers make an effective submission on the digital labelling trial before 19 December.
https://nomoreglyphosate.nz/how-to-make-a-submission-that-gets-noticed/
Taken together, these sources reveal a pattern that’s hard to ignore: digital labelling doesn’t strengthen transparency — it shifts it out of reach. And once essential information disappears from the pack, getting it back will be almost impossible. The time to question this direction is now, while we still have a say.
Image Source & Attribution
We’re grateful to the talented photographers and designers whose work enhances our content. The feature image on this page is by the_lightwriter.
