Public consultation is now open on MPI’s proposal to trial digital food labels for certain imported products.
Submissions close 19 December 2025, and if you’ve been following our recent articles, you’ll know the implications go far beyond QR codes.
This isn’t just a tech upgrade. It’s a shift in how information reaches consumers — and how much of it remains visible at all.
A lot of people tell us the MPI’s SurveyMonkey form feels a bit daunting. And while a copy-and-paste template might seem the easiest, MPI tends to treat identical submissions as a single voice. So instead of giving you set wording, we’ve put together simple prompts to help you think through each question and respond in your own words.
Your voice matters more than perfect phrasing. MPI is interested in how you see this proposal and why it matters to you — not a technical report. Use the ideas below as a starting point, keep what resonates, leave what doesn’t, and let your submission sound like you.
1. “Do you consider the trial parameters proposed are appropriate and fit for purpose?”
Things you might reflect on:
- Do the parameters protect consumers — or do they prioritise convenience for importers?
- Does the trial explain how digital information will be verified, monitored, or audited?
- Are the trial parameters clear about who benefits economically — and who might be disadvantaged?
- Do they address how QR-only information affects people without smartphones, weak reception, limited digital skills, or visual impairments?
- Have MPI considered the online shopping blind spot, where shoppers never see a physical label until the item arrives at home?
- Do the trial parameters account for substitution risks in delivery orders (allergy changes, different origins, different additives)?
- Does a one-year trial feel sufficient to test consumer behaviour, retailer performance, accessibility, and enforcement in real life?
You can comment on any of these — or raise your own concerns.
2. “Do you consider the exemption scope proposed is appropriate and fit for purpose?”
Questions that may guide your thinking:
- Should imported foods be allowed to remove mandatory information from the physical label when New Zealand producers must keep it on-pack?
- Does shifting key information online reduce the ability of shoppers to compare NZ-grown products with cheaper imports?
- Could the exemption scope unintentionally encourage import substitution, like what happened when Wattie’s dropped NZ growers?
- Should country-of-origin information ever be allowed to move behind a QR code?
- Does the exemption address the transparency needs of allergy sufferers, caregivers, food-bank recipients, and shared households?
Additional points some New Zealanders may want to consider:
Dietary choices and ethical requirements
Vegans and vegetarians rely heavily on being able to see full ingredient lists at a glance. If ingredients move behind a QR code, it becomes harder to confirm whether a product contains animal-derived additives, gelatine, emulsifiers, milk powders, cochineal, rennet, stabilisers, glazing agents, or hidden animal by-products.
Foreign-language labels
Although MPI’s proposal states that participating products must be “labelled in English,” removing mandatory information from the physical label could still mean more foreign-language packaging overall — with English appearing only in the digital version.
How would this affect people who cannot scan, cannot access mobile data in-store, or do not speak the manufacturer’s language?
Certifications
Vegan certification, plant-based claims, and “made without animal products” information may become less visible if shifted online. Is that acceptable for a dietary group that relies on instant clarity?
Again, speak from your own perspective. There’s no single “right” answer.
3. “Do you consider the exemption conditions proposed are appropriate and fit for purpose?”
Things worth considering:
- MPI says consumers must have “reasonable access” to digital information.
- What does reasonable mean in real life?
- Does it include rural reception issues, dead batteries, older shoppers, people without smartphones?
- Digital information can be changed at any time.
- Should there be version histories, timestamps, or audit trails?
- Should essential safety information (allergens, warnings, storage, ingredients) ever depend on:
- internet access?
- a functioning camera?
- a smartphone?
- a website link that may break or disappear?
- How would trading standards or MPI verify thousands of digital labels that can change daily?
You may want to highlight any risks you personally see.
4. “Are there any other matters the Minister should take into account before recommending an exemption?”
You might consider:
- Traceability and recalls:
How would recall notices work if batch numbers or storage instructions aren’t physically printed? - Equity:
Who is most disadvantaged when information moves online?
(elderly, low-income households, rural communities, online shoppers, food-bank users, shared households, allergy-affected families) - Economic resilience:
Does lowering import compliance costs weaken local growers and producers? - Transparency gaps:
Digital labels don’t include residue testing (glyphosate, AMPA, pesticides), even though QR-based systems overseas already provide this.
Should digital tools be used to expand transparency — not reduce it? - Enforcement:
Does MPI have the capacity to monitor, verify, and regulate online labels that can be altered at any time? - International precedent:
A recent U.S. Court of Appeals ruling found that QR-only GMO disclosures deprived consumers of meaningful access.
Is New Zealand heading down the same path?
Pick any themes that matter to you.
5. Upload section (optional)
MPI allows you to upload a PDF or DOC.
Only submit one if you have something additional you genuinely want to include — such as a personal story, professional expertise, or research you care about.
A Note Before You Submit
You don’t need to be an expert to make a meaningful submission.
You don’t need to write an essay.
MPI simply needs to hear your reasoning, in your own voice, about why transparency should never require Wi-Fi, a smartphone, or a battery with charge.
Digital tools have incredible potential — but only when they expand transparency, not erode it.
Submissions close 11.59 pm, 19 December 2025.
Your voice genuinely counts here.
Disclaimer
This guide is offered for general information only. We’re not legal or regulatory experts — just New Zealanders doing our best to understand a complex proposal. We’ve pulled this guide together carefully, but we’re human, and we can make mistakes. Please use your own judgement, do your own research, and answer in your own words. Your submission should always reflect your own views. Nothing here is intended as professional advice.
