Proposal to enable a limited trial of digital labelling on certain imported food products

Why we consulted

The Minister for Food Safety sought feedback on a proposal to enable a trial of digital labelling for certain imported food sold in designated retail stores.

Under the proposal, approved retailers would temporarily be exempt from the requirement to bear all information on packaging for certain imported food under section 343 of the Food Act 2014. The aim of the trial would be to see whether it's feasible to shape a future compliance pathway for the use of digital labelling as an adjunct to physical labels.

Before recommending an exemption, the minister must consult stakeholders who may be affected by the exemption.

This consultation opened on 20 November and closed at 11.59pm on 19 December 2025.

Background to the proposal

Food retailers must comply with requirements under the Food Act 2014, including applicable requirements of the Australia New Zealand Food Standards Code. The physical label of prepackaged foods in grocery retail must comply with labelling requirements of the code.

We proposed to enable a limited number of food retailers to trial the use of digital labelling technology. For a limited trial period, the non-compliance of the physical label with requirements of the code would be supplemented by digital means where feasible. There would be no change to expectations of what information must be provided.

Section 343 of the Food Act 2014 allows the Minister for Food Safety to recommend an exemption where he is satisfied that there are sufficient safeguards to minimise any risk to public health. Before recommending an exemption, the minister must take into account:

• the need to protect public health
• the desirability of avoiding unnecessary restrictions on trade
• the desirability of maintaining consistency between the standards in regulations made under section 383 of the Food Act 2014 and any relevant standards, requirements, or recommended practices that apply or are accepted internationally
• the need to give effect to New Zealand’s obligations under a relevant international agreement, convention, protocol, or treaty
• the identifiable costs of the exemption, who bears those costs, and the positive and negative effects on New Zealand consumers and food businesses
• the most effective way of achieving the safety and suitability of food
• any other matters that the minister considers relevant.

Why trial digital labelling? 

While physical labels continue to be the primary risk management tool for protecting public health, digital labelling technology has the potential to provide trust, transparency, and efficiency benefits. It can also better inform and empower consumers.

It also has the potential to increase access to more affordable food. For overseas manufactured and labelled food, the cost of physical re-labelling or over-labelling can in some cases, be a barrier to import. For some products, this cost may still be warranted to manage public health risk. In other cases, the public health risk may be lower, and the costs may not be as warranted, particularly where digital solutions are available.

This trial will support a consideration of the proper role of digital labelling in our food system. It will also support a greater understanding of how to best regulate digital labels: from setting the rules through to monitoring and enforcement. Ensuring food safety and suitability will continue to be paramount throughout the trial. 

Proposed trial parameters

• A limited number of operators and for limited number of sites at a time.
• A period of one year.
• Products imported from a mature food regulatory system¹ and labelled in English that meet the labelling requirements of that system.
• Approved food retailers who can meet trial scope and conditions.

¹Labelling and compositional legislative requirements are in line with Codex, have been in place for more than 5 years, and oversight of compliance is in place.

Proposed exemption scope

General pre-packaged food 

The exemption scope would be limited to pre-packaged food that is otherwise required to bear a physical label and which meets the compositional requirements of the Australia New Zealand Food Standards Code. It would not apply to higher-risk products, including dietary supplements, supplemented foods, alcohol products, or special-purpose food, such as infant formula.

Approved food retailer

Operators must be registered under the Food Act 2014. They must also be approved to participate in the trial.

The food could only be sold from the approved food retailer in New Zealand and not exported.

Proposed exemption conditions

Digital presentation

Consumers must be provided with all feasible information required by the Australia New Zealand Food Standards Code as a digital label.

Reasonable access

Consumers must have reasonable access to the information in digital format at the time of purchase and information after sale.

Consistency with information on-pack

Food information provided digitally must not conflict with information provided on-pack.