A growing number of us now buy some or all of our groceries online — not because it’s fashionable, but because it’s practical.
Busy households, rural families, elderly shoppers, people without transport, parents juggling work and childcare… for many, online grocery delivery has quietly become a lifeline.
Yet there’s a crucial detail missing from the public discussion: when you shop online, you buy without ever seeing the physical label. You can’t turn the product over. You can’t check if the allergen line changed. You can’t confirm the ingredients or the country of origin. You can’t see additives, storage instructions, or warning statements.
And that’s exactly why the physical label still matters.
When the groceries finally arrive at your door, that label is the first moment an online shopper gets to verify what they actually bought.
Now imagine if that label no longer included allergen warnings.
Or the ingredient list.
Or the country of origin.
Or key safety statements.
That is the scenario the Ministry for Primary Industries (MPI) digital labelling trial makes possible.
Do QR Codes Work for Online Grocery Shopping?
MPI’s proposal assumes that a QR code is an effortless substitute for printed information. And yes, QR codes can be scanned at home — but only under ideal conditions. They require:
- a smartphone
- reliable signal or Wi-Fi
- the eyesight and dexterity to scan
- the time to check each product
- a functioning link behind the code
They also assume the code hasn’t been blurred, smudged, creased, damaged in transit, or printed incorrectly.
Food safety shouldn’t depend on whether your phone is charged or whether a product survived the delivery van.
And notably, MPI’s proposal never once mentions online shoppers. Not a single reference.
Why Physical Labels Are Critical for Online Shoppers
Online shopping works today because physical labels are still legally required. When the order arrives, shoppers can confirm:
- if the product matches what was advertised
- whether the imported version was substituted
- if the recipe has changed
- whether allergens were added
- whether the product is safe for the person they’re cooking for
Digital-only labels move all of this information behind a screen, meaning online shoppers — already blind at the point of purchase — lose the only guaranteed moment of clarity they currently have.
How Product Substitutions Increase Labelling Risks
Anyone who uses Click & Collect or delivery knows substitutions are common:
- A New Zealand product swapped for an imported one
- Brand A replaced with Brand B
- Allergen-safe products replaced with versions that aren’t
Right now, the physical label acts as the final safety check. If mandatory information disappears from the pack, shoppers may not realise a substitution carries different allergens, ingredients, or origins until it’s too late.
Why Digital-Only Labels Don’t Work in Shared or Donated Food Situations
Food isn’t always consumed by the person who purchased it. In everyday life, people frequently:
- receive donated food from food banks
- share ingredients in flats, marae, shelters, and hostels
- cook for guests with allergies
- take food to elderly relatives or neighbours
- bring food to school or community events
- use ingredients from someone else’s pantry
Expecting everyone in these situations to scan QR codes for each can, jar, or packet isn’t realistic. And expecting food-bank volunteers or caregivers to scan hundreds of items is even less so.
Safety information that was once read in seconds could suddenly require multiple steps, devices, and working internet connections.
Convenience for importers should not create complexity — or risk — for everyone else.
Why Online Product Images Can’t Replace Physical Labels
Supermarkets frequently upload product images supplied from overseas markets. These photos often show:
- older recipes
- different allergens
- different ingredients
- different additives
- different warnings
- different countries of origin
Sometimes the image doesn’t match the New Zealand product at all.
Today, shoppers rely on the physical label upon delivery to catch these discrepancies. If that label also moves online, the mistake becomes invisible.
How Digital-Only Labels Undermine Recalls and Traceability
Batch numbers, date codes, and manufacturing details are not decorative. They are essential for recalls and traceability. Without consistent physical labels:
- contaminated products are harder to track
- allergen recall notices become less effective
- households cannot confirm whether their item is affected
- imported goods become harder to trace across borders
Digital-only labelling removes key components from the food-safety system. MPI’s proposal does not address this.
Why Online Shopping Makes Physical Labels More Important — Not Less
MPI frames digital labelling as “modernisation.” But for online retail — where shoppers cannot physically inspect the product before buying — physical labels are not outdated. They are essential.
Without them, online shopping becomes:
- harder to verify
- easier to mislabel
- easier to substitute incorrectly
- riskier for allergies
- more open to counterfeits
- less transparent overall
Digital labels can offer value — especially as supplements. But replacing physical labels in a system where half the population never sees the product before purchase introduces unnecessary risk for consumers.
Digital Labels Aren’t the Problem — Removing Physical Labels Is
Done well, digital labels could provide more detail than we currently have: expanded origin information, sustainability metrics, even pesticide residue data.
But removing information from the physical label of imported food is not modernisation. It is erosion — and the people who stand to lose the most are those already navigating the system with the least visibility: online shoppers, food-bank recipients, shared households, and families managing allergies.
MPI may not have considered these groups. But the public can — and should.
New Zealanders deserve clarity, not hidden information. Transparency, not uncertainty. Safety, not assumptions.
Digital tools can enhance our food system — but only if physical labels remain strong, complete, and mandatory.
What You Can Do Before 19 December
MPI’s digital labelling proposal may appear harmless at first glance, but for online shoppers and anyone relying on accurate physical labels, it undermines the only moment of certainty they currently have.
If you believe New Zealanders deserve reliable, visible, trustworthy information on the packaging— not hidden behind QR codes or missing entirely — now is the time to speak up.
Submissions close 11.59 pm, 19 December 2025.
Every voice helps push back against a system that benefits importers more than consumers.
Make your submission here:
Proposal to enable a limited trial of digital labelling on certain imported food products
And if this article helped clarify the risks, please share it.
Awareness is the first step toward better food safety for everyone.
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
If we want better decisions from our regulators, we need clearer information in our own hands.
The resources below aren’t here to overwhelm you — they’re here to offer context. They show how much of our current food labelling system already depends on trust, how easily that trust can slip, and why removing information from physical labels is not the small change MPI makes it sound like.
Each source brings its own piece of the puzzle. Together, they show why transparency needs strengthening, not shrinking.
MPI — Digital Labelling Trial Consultation
The official government consultation outlining the proposed exemption for imported foods.
https://www.mpi.govt.nz/consultations/proposal-to-enable-a-limited-trial-of-digital-labelling-on-certain-imported-food-products/
Consumer NZ – “Country-of-origin labelling finally passed”
A documented case of strong public support for clear origin labelling. Their research showed many shoppers look for—but often don’t find—origin labels on fresh produce. This supports the argument that physical labels still matter.
https://www.consumer.org.nz/articles/country-of-origin-labelling-finally-passed
NoMoreGlyphosate.nz — Scan for the Truth: Why NZ Needs Real Food Transparency
Explores how countries overseas are using QR codes to give shoppers instant access to real lab testing — pesticide residues, contaminants, origins, and more — and asks why New Zealand isn’t offering the same level of honesty.
https://nomoreglyphosate.nz/scan-for-the-truth-food-transparency-nz/
NoMoreGlyphosate.nz — Digital Food Labels in NZ: Transparency or Distraction?
Breaks down New Zealand’s broader shift toward digital labels and asks whether they improve transparency or simply shift blind spots online.
https://nomoreglyphosate.nz/digital-food-labels-nz-transparency/
FSANZ — Plain English Allergen Labelling Requirements
Explains the mandatory on-pack allergen statements New Zealand relies on — statements that digital-only labelling risks obscuring.
https://www.foodstandards.gov.au/peal
RNZ— Wattie’s Drops Growers for Cheaper Imports
A real-world example of how economic pressure is already favouring imported food over New Zealand-grown produce — raising the stakes of weakened labelling rules.
https://www.rnz.co.nz/news/country/579432/cheap-fruit-and-vegetable-imports-put-pressure-on-new-zealand-production
Clear labelling shouldn’t be something we have to fight for — but here we are.
As digital systems expand and more imported food enters our supply chain, the burden keeps shifting back onto consumers to “check the fine print” even when the fine print is disappearing. These resources remind us that transparency is not a luxury. It’s a safeguard.
And if we don’t insist on keeping it now, we may not get another chance.
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