Organic. Natural. Sustainable. Independently tested. New Zealand made. Certified.
Walk through a supermarket — or scroll through an online food store — and these words are everywhere.
They are there for a reason.
They influence what we buy.
Sometimes they influence how much we are prepared to pay.
And sometimes they may lead us to believe rather more about a product than the words themselves actually promise.
The New Zealand Commerce Commission has some surprisingly clear advice for businesses making these kinds of claims.
At its heart is a very simple principle: if you make a claim about a product, you need reasonable grounds for making it — and consumers should not be misled by it.
But once we started reading the Commission’s guidance more closely, another question occurred to us.
How often does a claim influence what we buy — without us really understanding what it means?
What Does the Commerce Commission Say About Food Label Claims?
When we think about misleading advertising, we might imagine a false price, an exaggerated discount or a product that simply doesn’t do what the advertisement promises.
But product claims go much further than that.
The Commerce Commission specifically points to characteristics such as “free range” and “organic”, where products are made, and how they are manufactured.
It says consumers often make purchasing decisions based on those claims.
That matters.
Because words such as organic, natural, clean, sustainable and tested don’t merely describe products. They can create expectations about them.
And those expectations may be one of the reasons we choose one product over another.
What Evidence Must Businesses Have for Food Label Claims?
The Commerce Commission calls this substantiation.
A business cannot simply make a claim and go looking for evidence later.
The Commission says businesses must have reasonable grounds for believing a claim is true at the time the claim is made.
It advises businesses to rely on facts, figures and credible sources rather than guesses or unsupported opinions, and to retain the documentation supporting their claims.
That’s important because consumers usually cannot investigate these things themselves.
If a packet tells us something is sustainably sourced, independently tested or produced to a particular standard, how many of us are going to track down the evidence before putting it in the trolley?
The Commerce Commission recognises exactly that problem: consumers may not have the time, resources or ability to determine whether a claim is accurate themselves.
So the responsibility sits with the business making it.
Can Vague Food Label Claims Mislead Consumers?
This may be the more interesting question.
The Commerce Commission specifically warns businesses against vague claims such as “eco-friendly”, “planet friendly” and “sustainably sourced” because consumers may find them difficult to understand and they have the potential to mislead.
That immediately raises questions about many of the words routinely used to sell food.
What does “clean” mean?
What does “pure” tell us?
What standard does “residue tested” refer to?
And when a company says its product exceeds global standards, which standards, in which countries, and for what?
Those questions aren’t pedantic.
Without the answers, two people can read exactly the same claim and walk away believing very different things.
The Commerce Commission has specific guidance about testing claims too.
Businesses can refer to favourable test results in their advertising, but the Commission says those results must not be distorted. Businesses should also be able to provide evidence showing that the results are accurate and relevant.
Perhaps most importantly, it says businesses must not mislead consumers about the “nature, extent or standard” of a test.
That makes a claim such as “independently tested” worth looking at more closely.
Independently tested for what?
Which substances were tested for?
What was the laboratory’s reporting limit?
And what does the claim lead the consumer to believe about the finished product?
The fact that testing occurred may be perfectly true.
But without knowing the nature, extent and standard of that testing, how much does “independently tested” actually tell us?
Can a Food Label Claim Be True but Still Misleading?
One particularly useful example in the Commerce Commission guidance concerns nutritional claims.
A claim can apparently be factually true and still potentially mislead consumers.
The Commission gives the example of promoting a food as having “no added sugar” when fructose or lactose has nevertheless been added.
The words themselves may be defensible.
The impression received by the consumer may be another matter.
That distinction is worth remembering well beyond sugar.
Because consumers don’t purchase individual words.
We purchase products based on what those words collectively lead us to believe.
What Does “Certified Organic” Actually Mean?
This is particularly interesting given our recent investigation into organic food and pesticide residues.
The Commerce Commission says that organic is a labelling term for products produced according to organic production standards.
If a business claims a product is organic, it must be able to substantiate that claim. If it says the product is “certified organic”, it must be able to produce the certificate.
Fair enough.
But there is another side to this that consumers need to understand.
Certification tells you that a product meets the requirements of that certification standard.
It does not necessarily tell you everything you might personally associate with the word organic.
That distinction became particularly important to us when we began looking at pesticide residues.
A consumer may reasonably associate “certified organic” with avoiding synthetic pesticides during production. But that does not automatically mean laboratory testing would find zero pesticide residue in the finished food.
Those are two different propositions.
Understanding the difference doesn’t diminish organic certification.
It simply means consumers should understand what the certification actually guarantees — and what it doesn’t.
What Do Certification Marks and Logos Actually Mean?
Certification marks are powerful.
A logo on a packet can communicate trust, quality or environmental credentials before we’ve read a single word.
The Commerce Commission recognises this too.
Its guidance says businesses should not overstate the environmental benefit represented by certification marks or endorsements.
It also suggests retailers provide information explaining what a displayed certification mark or logo actually means.
We think that’s an excellent idea.
Because how many consumers recognise certification logos without really knowing what has been certified?
A certification might relate to a production method.
An ingredient.
Animal welfare.
Environmental management.
A manufacturing process.
Or compliance with a particular standard.
The logo itself cannot tell you all of that.
What Does “New Zealand Made” Mean on Food Labels?
Food origin is another area where a few words can convey a much bigger impression.
The Commerce Commission says there isn’t a simple formula for deciding whether every product can legitimately be described as “New Zealand made”.
For food, it suggests asking:
Where were the ingredients grown?
And:
Were they transformed somewhere else into another food ingredient before reaching New Zealand?
Those are particularly relevant questions for processed foods.
Something can be manufactured, baked or packaged in New Zealand while containing ingredients grown overseas.
Again, neither fact necessarily makes the product better or worse.
But they are not the same thing.
And consumers deserve to understand the distinction.
What Questions Should Consumers Ask About Food Label Claims?
There is a recurring theme in the Commerce Commission’s guidance.
Be specific.
Businesses should be specific about environmental benefits.
They should have evidence for claims.
They should explain certification marks.
They should avoid vague language that consumers may misunderstand.
Perhaps consumers can turn that advice around.
When we see a claim on a packet, we can ask:
- What exactly does that mean?
- What evidence supports it?
- What was tested — and what wasn’t?
- What does that certification actually certify?
- Does the claim describe the finished product, an ingredient or the production process?
- Am I being told something explicitly — or am I filling in the gaps myself?
There is another possibility.
Rather than asking consumers simply to trust claims such as “independently tested”, food producers could make the testing itself part of the product.
Test every batch. Publish the results. Tell consumers what was tested for, which laboratory did the testing and what reporting limits were used.
The technology to do this is hardly complicated. A QR code on a packet or product page could take consumers directly to the laboratory results for that batch.
For producers confident in their products, that could become a genuine point of difference.
We’ve written before about the shift from trust to testing and the opportunity for food producers prepared to back their claims with data. Perhaps the next step is even simpler:
Don’t just tell us you’ve tested it. Show us.
None of this means assuming businesses are trying to deceive us.
But marketing exists to influence purchasing decisions.
And the Commerce Commission’s own guidance recognises that consumers often don’t have the time, resources or ability to independently verify the claims put in front of them.
That makes clarity important.
Read the Label — Then Question the Claim
Our recent food testing has taught us something we hadn’t entirely expected.
Sometimes the most interesting discovery isn’t what’s detected in the laboratory.
It’s what we assumed the label meant before we sent the product to the laboratory.
“Organic” has a defined meaning.
“Certified” should have evidence behind it.
“Independently tested” tells us that testing occurred — but without further information it doesn’t necessarily tell us what was tested, how sensitive that testing was, or what result would be considered acceptable.
And vague words can leave a considerable amount of room for interpretation.
Perhaps the better question when we pick up a product isn’t simply:
“Is this claim true?”
It might be:
“What, exactly, is this claim asking me to believe?”
That is a much harder question.
And perhaps a much more useful one.
Further Reading
A food label can tell us a great deal — but sometimes the more interesting questions begin with what it doesn’t tell us.
What does “pesticide-free” mean when laboratory tests have different detection limits? Does moving a label online create greater transparency? And how can consumers make an informed choice when information such as pesticide residue testing isn’t normally disclosed at all?
These related investigations take those questions further.
What Does “Pesticide-Free” Actually Mean? Why “Not Detected” Doesn’t Mean Zero
No More Glyphosate NZ
“Pesticide-free”, “residue-free” and “independently tested” can sound reassuring — but what do they actually mean? We look at laboratory reporting limits, organic certification and why “not detected” doesn’t necessarily mean zero.
Can You Trust Food Labels?
No More Glyphosate NZ
How much can we really learn from the information printed on food packaging? We look beyond the label at the gaps between what consumers are told, what they may assume, and what remains undisclosed.
Digital Labels Are Coming to New Zealand — But Will They Reveal Anything That Matters?
No More Glyphosate NZ
Moving food information from the packet to a QR code may sound like greater transparency. But if the information consumers want was never required in the first place, does digitising the label actually tell us anything more?
Informed Choice or Blind Trust? Why Glyphosate Testing Matters
No More Glyphosate NZ
Food labels don’t disclose glyphosate residue levels, and manufacturers rarely publish their testing data. We explore why independent testing matters — not to tell consumers what to buy, but to give them information on which to make their own choices.
From Trust to Testing: Why Glyphosate-Free Is Becoming the New Standard
No More Glyphosate NZ
What if food producers didn’t simply ask consumers to trust their claims, but published the evidence behind them? We look at the growing shift towards verified “clean label” products — and why transparent testing could become a powerful point of difference for food producers.
What Do New Zealand Regulators Say?
Want to go beyond our interpretation? These are some of the official New Zealand sources behind the rules and guidance discussed in this article — including what businesses must be able to prove, how consumers can be misled by the overall impression of a claim, and what “organic” actually means in New Zealand.
Commerce Commission — Making Accurate Claims
Commerce Commission
The Commerce Commission’s guidance for businesses on substantiating advertising and product claims, including claims about organic products, environmental benefits, certification marks, health and nutrition, and where products come from.
Commerce Commission — Trusting Origin, Environment and Health Claims
Commerce Commission
Written for consumers rather than businesses, this guidance makes an important distinction: a claim must be capable of being proved whether it is stated explicitly or merely implied. It also looks at how words, symbols and imagery can create a misleading impression about a product.
Ministry for Primary Industries — Organic Product Requirements in New Zealand
Ministry for Primary Industries
What does “organic” officially mean in New Zealand? MPI explains organic production requirements, certification and food safety — including the important distinction between organic production standards and food safety standards.
Labels matter. Claims matter. Certification matters.
But perhaps genuine transparency begins when we stop asking simply “What does the label say?” and start asking:
“What would I need to know to make a genuinely informed choice?”
Image Source & Attribution
The feature image on this page was created using AI-assisted image generation from an original concept developed by No More Glyphosate NZ and refined for publication in Canva.
