Country-of-Origin Labelling NZ: Retail Signs and Online Listings

A supermarket sign and an online product listing can refer to the same food but become out of step when a delivery, supplier or supplying store changes. The useful question is not just whether the display names a country. It is whether the information describes the right origin, clearly connects to the item and deals with any special conditions that apply.

This guide focuses on New Zealand retail origin signs and online listings for foods covered by the Consumer Information Standards (Origin of Food) Regulations 2021. It complements our broader guide to food labelling requirements in New Zealand; it is not a complete guide to every packaged-food label or voluntary marketing claim.

Which foods need country-of-origin information?

Regulation 5 covers retail items containing only one type of fruit or vegetable, fish or seafood, or meat, where the food is fresh, or frozen or thawed but otherwise fresh, and no more than minimally processed. Cured pork is a separate covered category. Retail includes internet sales and mail-outs. The current Origin of Food Regulations contain the definitions and conditions.

Check the actual product rather than relying on its shelf location. The Commerce Commission explains that mixed peas and corn are outside the single-type category. Cutting, peeling or filleting does not necessarily take an item outside the rules; those are examples of minimal processing. Preservation methods such as drying or canning can change the fresh-food classification. Cured pork needs its own assessment under regulation 8, rather than being dismissed merely because curing preserves it.

The regulations exclude food supplied, offered or advertised at a fundraising event, and food intended for immediate consumption from a restaurant, cafeteria, takeaway shop, canteen or similar place, or a caterer. This is a defined scope exclusion, not an exemption for everything a business with a café or takeaway counter sells.

Use the Commerce Commission’s country-of-origin food labelling guidance and its detailed country-of-origin FAQs alongside the regulations if the product’s ingredients or processing make its classification uncertain. Other labelling and fair trading requirements may still matter even when this particular standard does not apply.

What does “origin” mean for each food?

The origin basis in regulation 9 differs by food category. A New Zealand supplier, packer or processing address does not by itself answer the required origin question. The following table summarises the ordinary origin information; special replacement options are explained later.

On a small screen, swipe sideways within the table to view all columns.

Origin can involve more than one country. Use the definitions in regulation 9 rather than assuming that the last place a product passed through is its origin. For fish and seafood, a high-seas ocean is different from a country’s fisheries jurisdiction.

Make retail signs clear and connected to the item

Regulation 10 requires clear, legible text in English or Māori that tells the customer how the food relates to the disclosed countries or oceans. The connection to the item must be clear. A neighbouring sign is one permitted approach when the food is supplied, offered or advertised where it is located; individual packaging is not the only option.

The Commission says there is no prescribed font colour, font size or particular phrase. That does not remove the legibility and connection requirements. A flag or map alone is insufficient because text is required. Naming only a region or state, or displaying a New Zealand grower’s address alone, also does not provide the required country information.

Practical recommendation: Make the product identity, relevant origin basis and country or ocean easy to read together. Check the sign from the customer’s normal viewing position, including where adjacent products have different origins. When a display mixes stock, confirm what the disclosure needs to describe before retaining the old sign.

A sign template can organise information, but it cannot decide which origin rule applies. Agree who checks incoming origin information and who changes the display when the relevant stock changes.

Online offers need origin information too

When covered food is offered or advertised away from its location, regulation 10 requires the information to be part of the offer or advertisement. A website listing needs its own check; an in-store sign does not supply the missing information on an online offer. If the same food is also offered in a store, the in-store disclosure still needs to meet the applicable requirements.

When origin may change before delivery

Regulation 12 applies when the seller has reason to believe that the origin of the item supplied will differ from the origin when it was offered or advertised away from the food. In that situation, the disclosure must also make clear that the origin information may change by the time of supply. The additional statement is a conditional requirement; it is not a replacement for the otherwise applicable origin information.

When the supplying store makes a difference

Regulation 13 applies to off-site offers or advertisements for covered items of the same type when their origins differ between the seller’s stores. The required replacement is a combined list of the countries or oceans from all those items across all the stores, together with a statement making clear that not all listed countries may be relevant to an item at a particular store.

The regulation defines a store as a place of business from which the item is supplied. A general online listing therefore needs a check against the actual supplying locations. This multi-store rule should not be treated as permission to list every country a supplier might use without checking the stated conditions and the complete disclosure.

The accepted-offer exception is narrow

Under regulation 16, information need not be disclosed again at supply if the offer was accepted away from the item’s location and the item is supplied in accordance with that accepted offer. The exception does not remove the disclosure required in the original online offer, excuse a separate in-store offer or settle other applicable packaging requirements.

Frequent origin changes have specific replacement options

The general frequent-change option

Regulation 14 applies to covered items of the same type over a period when their origins change often enough that changing the disclosed information would be unreasonable. If that condition is met, the seller may choose a combined country or ocean list from all those items instead of each item’s individual origin information. The disclosure must also make clear that not all listed countries may be relevant to a particular item.

This is an optional, conditional approach. The test is not simply that maintaining accurate listings takes effort. Before using it, identify the relevant items, the period and the origin information being combined. Keeping that basis with the approved wording is a practical way to make later checks easier; it is not a prescribed record format.

The additional meat and cured-pork option

Regulation 15 applies only to meat or cured-pork items of the same type that meet regulation 14’s frequent-change condition. It permits a replacement based either on the combined slaughter countries for all those items, including a single country if the slaughter information is the same, or on a combination of raising information for some animals and slaughter information for the rest.

The qualifications matter. If more than one country is listed, the disclosure must make clear that not all may relate to a particular item. For each country drawn from slaughter information, it must make clear that the animals may not have been raised there. Regulations 12 and 13 continue to apply to this chosen information as specified by regulation 15(3).

Ordinary meat origin remains the country or countries where the animals were raised. Do not change a label to a slaughter-country statement merely because that information is easier to obtain. Confirm that the optional rule actually applies and that all its accompanying statements are included.

A practical checklist for signs and online listings

The following workflow is an AFVA recommendation for organising a review. It does not add a universal form, checking frequency or record-retention period to the regulations.

1. Identify the exact item. Record its product reference, ingredients, processing and sales channel so the coverage assessment concerns what is actually sold.
2. Confirm the origin basis. Separate growing, raising, catch or harvest information from packing, processing and supplier addresses.
3. Check the supplier information. Identify which items or deliveries it concerns. Resolve missing or contradictory information before relying on a disclosure.
4. Assess the special conditions. Check expected changes before supply, differences between supplying stores and any proposed frequent-change replacement.
5. Review the whole disclosure. Check the countries or oceans, the relationship to the food, required accompanying statements, language, legibility and item connection.
6. Check every affected channel. Compare the current shelf sign, packaging where relevant, online listing and any off-site advertisement.
7. Assign the next update. Name the person responsible for checking changed supplier information and replacing affected wording.
8. Keep a useful review trail. Retain the information relied on, the approved wording and the relevant product, store and date references according to the business’s arrangements and applicable requirements.

Start with one current product and follow it from the supplier information to the customer-facing listing. A written sign-off can help the team explain the decision, but it is not proof that an incorrect disclosure meets the law.

Common country-of-origin mistakes to avoid

• Confusing origin with processing location. Check the defined growing, raising, catch or harvest basis.
• Assuming every food follows this standard. Check the single-type, processing and cured-pork definitions and the sales context.
• Relying on a flag, address or region alone. The required information needs clear text and the correct country or ocean relationship.
• Updating the shelf but leaving the website unchanged. Check each relevant offer or advertisement.
• Using a broad list without its qualifying statement. Multi-store and frequent-change rules have different conditions and required explanations.
• Treating online supply as a blanket exemption. The accepted-offer exception is conditional and does not remove the original offer’s disclosure.

How AFVA can support a labelling review

Access Food Verification & Auditing Limited offers practical food labelling review services, including country-of-origin labelling, possible compliance gaps and recommendations before printing, importing, selling or updating products. A review is a support service; it does not transfer the business’s responsibility for its disclosures.

For an initial enquiry, provide the current wording, product details, supplier-origin information, sales channels and the supplying locations. Explain whether you are considering ordinary origin information or a specific conditional replacement. Read about AFVA’s food labelling review service to discuss the appropriate scope. Seek independent legal advice where the application of the regulations remains uncertain.

Check one product across the shelf and the website

Choose one covered retail item. Confirm its origin basis, check the supporting information and compare the actual sign with the live online offer. Then check whether changing origins or different supplying stores require additional or replacement wording.

General information only, researched on 12 October 2026. Apply the current regulations to the actual product, processing and sales circumstances. The examples and checklist are recommendations, not legal advice or regulatory approval. Other labelling and fair trading obligations may also apply.