The Government asked New Zealanders what they wanted from food labels. The answers were clear.
But instead of addressing the concerns, the Ministry for Primary Industry is now trialling a digital fix that risks sidelining the real issues.
Before the Minister for Food Safety announced the digital QR-code labelling trial…
Before the “innovation” messaging…
Before the headlines framed it all as modernisation…
The Government already had a document sitting on its desk.
A long one.
A detailed one.
And one full of admissions that New Zealand’s labelling system isn’t working the way the public assumes it is.
That document was the Product Labelling Regulatory Review – Summary of Engagement Report [PDF, July 2025].
And once you read it, it becomes obvious why the digital labelling trial feels like a shiny detour rather than a real solution.
This article is our assessment of what the Review actually revealed — and why the Government quietly stepped around the hardest issues when designing the QR-code trial.
Have your say:
If you care about what ends up on — or off — New Zealand food labels, now is the moment to speak up.
MPI is accepting public submissions on the digital labelling proposal.
Make a submission here: Proposal to enable a limited trial of digital labelling on certain imported food products [Look for the SurveyMonkey link].
What the Product Labelling Review Revealed About NZ’s Labelling System
This isn’t a small issue. When the people who actually produce, import, and sell our food say the rules are confusing, duplicated, and inconsistently enforced, it means the system isn’t protecting consumers the way we assume it does.
The Review didn’t mince words about one of the system’s biggest flaws. It states:
“Multiple agencies set overlapping labelling requirements and offer unclear guidance, resulting in duplication, confusion, and inefficiency. Enforcement is not always consistent.”
In plain language?
Too many regulators.
Too many conflicting rules.
Too little enforcement.
The Review also noted widespread compliance costs:
“Over 65% of all submitters consider labelling regulations impose unnecessary compliance costs for their business.”
Small businesses were hit hardest. Larger companies worried about international alignment. And across almost every sector, businesses described the system as overcomplicated and inconsistent.
Nothing about that suggests New Zealand needs labels that are harder to find — or buried behind a QR code.
Regulatory Complexity and Weak Enforcement Were Key Themes
According to the feedback captured in the Review:
“Stakeholders note a lack of enforcement against non-compliant businesses, creating an uneven playing field.”
And it gets worse. The Review records:
“Several sectors raised concerns that some imported products including online overseas purchases do not always comply with local regulation… [This] creates an uneven playing field.”
So before the Government announced its digital trial, it already knew:
- imported non-compliant products were slipping through
- enforcement wasn’t consistent
- domestic producers were often carrying the burden
- honest businesses were being undercut
And yet the digital label trial didn’t address enforcement at all.
What NZ Businesses Told the Review About Transparency and Trust
One of the clearest lines in the Review appears under transparency and accessibility:
“Stakeholders want label claims to be transparent and consistent…”
And the list includes:
- health
- environmental sustainability
- nutrition
- allergens
- country of origin
- definitions
In other words, stakeholders wanted accuracy, clarity, and trust.
They didn’t ask for less information on the physical label.
They didn’t ask for information to move online.
They didn’t ask for QR codes to become the new standard.
They asked for transparency.
So why did the trial go in the opposite direction?
What the Review Warned About Digital Labels and Accessibility
When it comes to digital labels, the Review couldn’t be clearer:
“Accessibility is a concern in this area. Not everyone has or wants constant access to a smart phone…”
It also stated:
“Under the Food Standards Code mandatory information must be on a label and there’s no provision for that to be via an electronic label.”
That’s an important point:
Digital labels are not legally allowed to carry mandatory information in New Zealand.
The law requires certain information to remain on the physical package.
So rather than fixing the underlying rules, clarifying requirements, or strengthening enforcement…
the Government is trialling a system that tries to work around existing barriers.
Not fix them.
Not modernise them.
Not improve transparency.
Just… digitise them.
Digital Labels: What the Review Actually Said About QR Codes
When stakeholders praised digital labels, their reasons were mostly operational:
“Digital labelling enables product information to be updated in real-time reducing business administrative burdens…”
And:
“…supports export growth by enabling businesses to flexibly meet overseas regulatory requirements…”
These are business-facing benefits.
Compliance benefits.
Cost-saving benefits.
And there’s nothing wrong with that — unless the consumer transparency gets watered down in the process.
Which brings us to the central issue.
The Transparency Gap the Review Never Touched
But there’s another omission that sits quietly beneath both the Review and the digital trial: nothing in either process touches the biggest transparency gap of all — chemical residues. The Review didn’t ask whether consumers should know about glyphosate, AMPA, or pesticide residues in their food. The trial doesn’t require that information either.
So even as the location of the label changes, the scope of the label stays exactly the same — and the most meaningful safety data remains off the table.
Residues aren’t a footnote in New Zealand’s food system. They’re a recurring public concern, a growing international issue, and the focus of multiple scientific debates. And yet neither the Review nor the trial proposes that consumers should be able to scan a QR code and see anything about residues, contaminants, or independent lab testing.
It’s the transparency gap no one wants to acknowledge — and the digital label trial leaves it exactly where it has always been: invisible.
Why the Digital Labelling Trial Doesn’t Solve the Review’s Findings
Our reading of the Review shows the system has four major weaknesses:
- Enforcement gaps
- Conflicting regulatory requirements
- Uneven playing field for local producers
- Lack of clear, consistent transparency for consumers
But the QR-code trial addresses none of these.
Instead, it introduces:
- internet reliance
- accessibility concerns
- app- or device-dependence
- increased distance between consumers and information
- the risk of information being changed after purchase
- an easy pathway for claims to become more vague, not clearer
This is where the Gmail analogy fits perfectly.
People accept huge privacy trade-offs because Gmail is “convenient.”
We risk accepting weaker transparency because QR labels are “convenient.”
Convenience almost always wins — right until it shouldn’t.
The Supermarket Competition Myth — And What It Means for Standards
And that brings us to one of the strangest parts of the Government’s messaging around the digital labelling trial: the claim that this is somehow linked to “increasing supermarket competition.” On the surface it sounds positive — more retailers, more choice, more pressure to keep prices down. But the connection between digital labels and supermarket competition is never clearly explained, because there isn’t a clear connection to begin with.
The implication is simple: more players equals lower prices.
But here’s the uncomfortable economic reality:
More supermarket chains won’t magically deliver lower prices unless they start importing cheaper products.
If every retailer is still sourcing from the same New Zealand producers, the only way to “stay competitive” is to push those producers even harder — and that pressure almost always lands in the same place:
- reduced margins
- reduced standards
- and in some cases, reduced food quality
That’s the part no one talks about.
When competition becomes a race to the bottom, producers feel the squeeze long before consumers see any savings. And the digital labelling trial slots neatly into that narrative: make compliance faster, make products more “flexible,” make imports easier to manage — all without addressing the structural problems the Review actually highlighted.
But consumers don’t need more flexible labels.
They need trustworthy ones.
Convenience vs. Transparency: The Real Risk of QR-Code Labelling
The Review makes it clear that what consumers and suppliers want is:
- consistent standards
- clearer rules
- real enforcement
- transparent claims
- reliable definitions
- honest information
- accessibility
The digital trial offers none of these.
It offers a barcode that takes you to a webpage.
That’s not transparency.
That’s relocation.
Where This Leaves Consumers and Producers in New Zealand
The Government’s own Review spelled out the problems clearly.
It captured the frustrations of manufacturers, importers, exporters, retailers, and suppliers.
It documented the inconsistencies, enforcement failures, duplication, and cost burdens.
And instead of tackling those issues…
we got QR codes.
Not because the Review said consumers needed them.
Not because it strengthens trust.
Not because it improves transparency.
But because it is easier than fixing the structural problems the Review identified.
Technology shouldn’t become a shortcut around accountability.
And food safety shouldn’t require Wi-Fi.
If you want to understand what the digital trial still won’t reveal, read our companion piece, Part 2, in the next section.
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 — But Will They Reveal Anything That Matters?
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: (You are here.)
What the Government’s own Review reveals about regulatory gaps, weak enforcement, and the transparency issues the digital trial doesn’t even touch.
Want Labels That Mean Something?
So do we. That’s why we’re testing food for glyphosate residues, publishing the results, and challenging the systems that allow unsafe substances to stay hidden behind vague labels.
100% of donations go to testing — not admin, not overheads.
Support our work here
Because if we don’t demand real information — we’ll be left scanning barcodes that say nothing.
Resources & References
If this Review taught us anything, it’s that the real story isn’t hidden — it’s just scattered.
The links below pull together the policy threads, the industry incentives, and the transparency gaps shaping New Zealand’s food labelling future.
Summary of Engagement Report – Product Labelling Regulatory Review
The official Ministry for Regulation document that outlines stakeholder feedback on New Zealand’s labelling system — from enforcement gaps to digital accessibility concerns. This article is based on the findings in this report.
Digital Labels Are Coming to New Zealand — But Will They Reveal Anything That Matters?
Our companion article examining the Government’s digital label trial and why it risks shifting transparency online instead of strengthening it.
Digital Trial to Boost Supermarket Competition
NZ Government / Beehive.govt.nz
The official announcement from Food Safety Minister Andrew Hoggard linking digital labels with supermarket competition — one of the central issues explored in this article.
Have Your Say: MPI Public Consultation (Closes 19 December 2025)
Current public consultation on allowing limited use of digital labels for certain imported foods. Useful for understanding how policy may change — and what the public can push back on.
GS1 NZ: Review on Product Labelling
Industry overview of labelling expectations, including digital options such as 2D barcodes and SmartFacts. Helps explain why digital labels appeal to manufacturers and retailers.
CleanScan: Transparency Through Technology
A QR-code based system used overseas to provide verified residue testing and farming-practice details. Shows what genuine transparency could look like if NZ chose a stronger model.
Detox Project: CleanScan Certification
Explains the certification requirements behind CleanScan — including independent lab testing — and why digital tools don’t have to compromise transparency.
Scan for the Truth: Why NZ Needs Real Food Transparency and QR-Code Lab Results
Our exploration of how QR codes could work for New Zealand — not as a replacement for physical labels, but as a tool to give consumers access to data that matters.
The Glyphosate-Free Clean Label Shift
Background on how “glyphosate-free” is becoming part of the global clean label movement. Helps frame why transparency isn’t just a technical issue — it’s a consumer expectation.
If the Government truly wants to modernise food labelling, it has a choice:
digitise the system as it is, or fix the problems the Review has already exposed.
These resources can help you see which direction we’re headed — and which one we should demand.
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 BrianAJackson.
