Public Policy: Proposal to enable a limited trial of digital labelling on certain imported food products
Lead agency: Ministry for Primary Industries
Consultation period: Nov 20th – Dec 19th 2025
About the Consultation
MPI has opened a consultation “to see whether it's feasible to shape a future compliance pathway for the use of digital labelling as an adjunct to physical labels.” The proposed trial is narrow – limited to certain imported foods and approved retailers. To be able to undertake a trial, an exemption under the Food Act is required.
‘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.’
Why we believe this matters to industry
We believe that it is critical to consumer acceptance of digital labelling that any implementation of digital labelling in New Zealand should be consistent with the globally-standardised, next generation barcode standards.
Watch webinar with NZ Food and Grocery Council and MPI
If you would like further background on the proposed trial, here is a webinar conducted by the New Zealand Food and Grocery Council, kindly shared with permission by Raewyn Bleakley, Chief Executive:
GS1 New Zealand submission
GS1 New Zealand will be submitting to MPI. Our focus will be on the best way to implement digital labelling in New Zealand to ensure consistency with the global rollout of next generation barcodes that are designed to ‘beep’ at the point-of-sale and ‘scan’ on the mobile phone of a consumer to provide enhanced digital labelling. GS1’s role is to support the use of global standards for digital labels so that there is continuity for business and positive outcomes for consumers. Although the trial’s proposed scope is limited to imported products, our view is that New Zealand businesses should be provided the opportunity to build their capability around the use of digital labelling technology as well.
Our submission will focus on four key principles relevant to the MPI proposed digital label trial:
1. Align with global best practice.
Industry and regulators have been working for almost a decade to develop a standardised way to do digital labelling. Any trial should align with that approach.
It is our strong recommendation that QR codes compliant with ISO/IEC 18975:2024 (GS1 QR with Digital Link standard) should be used.
2. The digital label should be on the physical product (rather than just on the shelf edge in the retail outlet).
3. Digital information should be consistent with the information on the physical label.
4. The digital information should be linked to the unique product identification number.
How to Have Your Say
Interested parties are encouraged to:
- Review the consultation from MPI
- Complete the online survey