3 major areas of digital labelling progress with the government – what GS1 NZ is doing on behalf of members

Things are certainly ‘heating up ‘when it comes to public policy work involving digital labelling in 2025, and this is set to continue into 2026!

Digital labelling presents a major opportunity for GS1 members. This will be further strengthened if the government adopts global standards for digital labelling and creates a regulatory environment to support its adoption. ‘Digital Labelling’ is the use of digital technology to provide product and logistics information to complement physical labels – a great example is the GS1 QR Code and associated GS1 standards which are rolling out globally. As the global standards organisation enabling trusted identification and data sharing, GS1’s role is to advocate for the use of GS1’s global standards to support our members and simplify the trading environment. We regularly advocate on your behalf with government for the adoption of GS1 standards and for their implementation.

Here is an overview of the three major areas of public policy work and what GS1 New Zealand is contributing on behalf of members.

Three areas of focus for the government

The government has three key areas of digital labelling public policy work currently underway which are distinct from each other. GS1 New Zealand is working with the government on each of these areas of public policy work to advise on digital labelling:

1. Product Labelling Regulatory Review
2. Proposed Trial of Digital Labelling
3. FSANZ online labelling review

1. Product Labelling Regulatory Review – Ministry for Regulation

The Ministry for Regulation is conducting a review into product labelling, as previously shared in SCAN 2.0. Phase one concluded earlier this year, with digital labelling being included clearly in the terms of reference for the Review. In phase two, recommendations are going to Ministers by the end of 2025 and the outcomes of the Review are scheduled to be released in February 2026.

The review aims to ‘assess New Zealand’s alignment with international product labelling standards and guidelines and identify regulatory barriers that unnecessarily restrict interoperability with global markets.’

GS1 NZ is working with the Ministry on behalf of members

GS1 New Zealand’s main interest in the Review is in digital labelling. We are communicating to policy makers that an enabling regulatory environment is required and that globally-accepted standards for digital labelling implementation should be adopted. The team at GS1 NZ has been working closely with the Ministry for Regulation throughout the Review including direct ministerial engagement, consultation meetings with Ministry officials, submissions and coordinating two joint statements with key industry players and industry bodies outlining recommendations to government which have been distributed to officials and key Ministers.

The outcomes of the Review will be known in February – we will be sharing the outcomes of the Review here in SCAN 2.0, and on our website. If you have any questions about the Review you are welcome to contact our team.

2. Proposed Trial of Digital Labelling – Ministry for Primary Industries (MPI)

MPI is currently proposing a trial of digital labelling as a way of streamlining access for a new supermarket player to the NZ market and is seeking feedback on their proposal, viz:

‘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.’

GS1 NZ is submitting to MPI on behalf of members

While we welcome the adoption of digital labelling, GS1 NZ is clear that international standards for digital labelling should be used in any trial of digital labelling. This view was shared by GS1 NZ with media in November. The team at GS1 NZ has been engaging with MPI officials directly and will be submitting to the Ministry in the consultation process.

Our submission will focus on four key principles:

1. Align with global best practice.   
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.  

You can read more about our submission and these four principles here. 

3. FSANZ Online Labelling Review

FSANZ (Food Standards Australia and New Zealand) is a joint initiative between Australia and New Zealand under a food treaty. The Food Ministers’ Meeting met on 14 November 2025 in Melbourne to consider food regulation and policy matters and an outcome was a principles-based review of the System’s approach to labelling, viz:

‘Ministers acknowledged the growing relevance of digital labelling in the Food Regulation System (the System) and agreed to initiate a principles-based review of the System’s approach to labelling. FSANZ, in collaboration with the Food Regulation Standing Committee (FRSC), will lead this work, with a framework to be developed in 2026.’

GS1 NZ is submitting to the FSANZ consultation

GS1 NZ's CEO has been engaged directly by the team at FSANZ and GS1 NZ is also submitting to two specific consultations.

One FSANZ workstream is on digital labelling (with similar content and focus to what has been outlined above).

The second FSANZ workstream is on what information should be available to consumers when they are purchasing ‘at a distance’ from the physical product (ie., on an e-commerce website or cellphone). Our focus is on the ‘digital twin’, that is how an accurate match can be achieved between a product’s physical packaging and its online presence. Our submission has drawn heavily from experience from brand owners and retailers in Europe from the implementation of a key European regulation EU 1169:2011 which requires key information to be available and accurate at a distance on food & certain alcoholic beverage products. Here in NZ GS1 NZ supports businesses to share their product master data digitally – this includes many different data points associated with each product (product as well as its label/packaging). Best practice for online presentation – both for consumer and brand owner benefit – is to provide all label information, including accurate images so that the consumer can view for themselves all information on the packaging.