Food Labelling Requirements NZ: 2026 Checklist

Food labelling requirements in NZ depend on the food, how it is packaged and sold, and any claims made. This guide helps manufacturers, importers, food brands and other businesses organise a packaged retail label review. It is a starting checklist, not a universal label specification for every food category.

The useful question is whether the label matches the actual formulation, product and sales arrangement. A polished design cannot resolve an incomplete ingredient specification, an unsupported shelf-life date or a claim without evidence. Check the technical content before printing, then review the complete final artwork.

Which foods need a label in New Zealand?

The Australia New Zealand Food Standards Code sets the relevant food information rules, alongside applicable New Zealand legislation and product-specific requirements. MPI’s retail food labelling guidance provides a practical starting point. Do not apply Australia-only requirements to a New Zealand label without checking their jurisdiction.

Some retail foods are exempt from bearing a full label. Examples include food that is unpackaged, made and packaged at the premises where it is sold, or packaged in the purchaser’s presence. Other conditional exemptions include food displayed in an assisted-service cabinet, certain fundraising sales and food delivered ready for immediate consumption at the purchaser’s express order. The last example does not include vending-machine sales.

The exemption for certain whole or cut fresh fruit and vegetables excludes seed sprouts and similar products; the packaging must not obscure the food’s nature or quality. Check the exact conditions in Standard 1.2.1 on labels and information requirements rather than assuming all fresh produce, home-made food or online orders are exempt.

Food labelling requirements NZ: packaged retail checklist

Use these cards to identify the questions for your product. They describe commonly relevant checks; the word “applicable” matters. Some products, packages and sales formats have exceptions, while special-purpose foods may need additional information.

Check the food name, supplier and batch identity

The label needs to identify the food’s true nature, using a prescribed name where required. A creative brand name does not necessarily perform that function. Avoid making a definite naming or composition decision from a product’s front panel alone.

For applicable packaged foods, check the supplier’s name and physical business address in New Zealand or Australia, together with lot identification. There are specific exceptions, so confirm the position for the actual food and pack. As a practical traceability control, connect the lot code with the product, ingredients, production and distribution records.

Prepare the ingredient list and percentage declarations

Ingredients are generally listed in descending order of their ingoing weight at manufacture. Use the actual recipe and current supplier information. A marketing name such as a seasoning or premix name may conceal ingredients that need assessment. Additives generally use the relevant class name followed by the prescribed name or code number, subject to the applicable rules.

A compound ingredient contains more than one ingredient. Standard 1.2.4 on ingredient statements contains the declaration rules and exceptions. Its limited under-5% compound-ingredient exception does not remove required allergen or genetically modified food declarations, or declarations for additives performing a technological function in the final food. Do not treat “less than 5%” as permission to ignore the supplier specification.

Percentage labelling can be required for characterising ingredients or components. Names, words and pictures can be relevant, but the definition and exceptions matter; an ingredient image does not invariably trigger a percentage declaration. Assess the product against Standard 1.2.10 on characterising ingredients.

Use the correct allergen names and Contains statement

Plain English Allergen Labelling (PEAL) is the current format where it applies. The legacy sale period ended in February 2026. Review the actual formulation, compound ingredients, additives and processing aids, including the product-specific declaration exceptions. Use FSANZ’s current allergen guidance and the Code’s required names.

• Ingredients statement: required allergen names must be bold, stand out and be no smaller than the other listed ingredients. Repeat the required name for each ingredient containing the allergen; declaring it once for the whole list is not sufficient. For a declared allergenic processing aid, include the words “processing aid” with the required name.
• Contains summary: where required, use only “Contains” followed by the required names. Place it directly next to, but distinctly separated from, the ingredients statement, in the same field of view. Use bold and the same typeface and size as the required allergen names in the ingredients.
• Wheat and gluten: subject to specified exemptions, wheat requires declaration even when gluten is absent. Gluten-containing wheat requires wheat in the ingredients and both wheat and gluten in the summary. For gluten-containing barley, oats or rye, the cereal name appears in the ingredients and gluten is the required summary term.
• Soy: the ingredients can use soy, soya or soybean, but the required summary name is soy.
• Other required names: assess fish, crustacean, mollusc, egg, milk, lupin, peanut and sesame; individually name the required tree nuts. Added sulphites at 10 mg/kg or more require declaration. Check the precise form and exemptions rather than treating a shortened checklist as the legal specification.

Foods exempt from an ingredients statement can still require allergen declarations by the applicable method. A voluntary “may contain” statement does not replace required declarations or appropriate cross-contact controls. Our New Zealand allergen labelling guide provides the narrower overview; confirm a product’s exact declarations against the current Code.

Check nutrition information and claims together

Many packaged foods require a nutrition information panel (NIP). The standard panel generally gives energy, protein, fat, saturated fat, carbohydrate, sugars and sodium per serving and per 100 g or 100 mL, as well as serving size and servings per package. Additional nutrients or information can be required for particular claims or products.

There are product exemptions and a separate small-package pathway. A claim can change what nutrition information is needed, but it does not invariably mean that every small package needs a full NIP. Check Standard 1.2.8, including its small-package provisions for the actual food and claim.

Calculations should reflect the current recipe, ingredient data, processing yield and serving assumptions. The FSANZ Nutrition Panel Calculator is a tool, not a compliance certificate. Consider whether appropriate laboratory analysis or other evidence is needed for the product or claim.

Nutrition content and health claims have specific conditions under Standard 1.2.7 and related schedules. FSANZ’s nutrition and health claims guidance explains the framework. Assess claims such as “high protein” or “no added sugar” against the applicable conditions, and assess health claims and their evidence separately. Check the words, symbols and overall impression; a design preference is not substantiation.

Choose the correct date mark and storage instructions

A use-by date is required where the food needs to be consumed before a date for health or safety reasons. Food must not be sold after its use-by date. A best-before date generally concerns quality; sale after it is permitted only if the food remains fit for consumption. See FSANZ’s date-marking guidance.

Best-before marking has exceptions, including a shelf life of two years or more, with specific qualifications such as infant formula. Bread with a shelf life under seven days can use the permitted baked-on or baked-for alternative. Do not turn these exceptions into a rule that all long-life food or all small packages are exempt from every date requirement.

The date format also matters. Under Standard 1.2.5 on date marking, dates not more than three months after the date the mark is applied include at least the day and month; dates more than three months after that point include the month and year. Numeric dates must be unambiguous and accompanied by the applicable wording.

Provide the storage conditions needed for the stated shelf life and any use or storage directions needed for health or safety. Review the date with the formulation, process, pack, distribution and intended use. AFVA’s shelf-life planning and laboratory coordination support can help organise evidence; laboratory analysis, where needed, is performed externally.

Check net quantity and the applicable origin rules

Net quantity and presentation

Food quantity is generally stated as the appropriate net weight, volume or number, subject to the applicable exceptions. Check that the declared quantity, measurement and units are correct for the product.

For weight or volume markings, the general presentation rule includes a prominent position close to the product name or description, clear contrast and letters and figures at least 2 mm high. A smaller clear, legible marking is permitted where the size of the goods or package prevents that minimum. Quantity exceptions and count-based declarations have their own provisions. See regulations 79 and 79A of the Weights and Measures Regulations. This is not a universal 2 mm rule for all food-label text.

Origin disclosure and origin claims

New Zealand does not require an origin statement on every packaged food. The compulsory disclosure rules cover defined categories of single-type, no-more-than-minimally-processed fresh, thawed or frozen fruit, vegetables, meat, finfish and shellfish, together with specific cured-pork rules. Conditions and exceptions matter. Disclosure can also be required in relevant online offers or advertising.

Use the Commerce Commission’s country-of-origin FAQs to check the product and sales format. A supplier’s New Zealand address does not establish the food’s origin. Voluntary origin claims must be accurate and not misleading. The AFVA guide to origin information for retail and online sales explains the practical preparation task. Other product-specific origin rules should be checked separately.

Review imported labels and over-labels before sale

An overseas label is usable only if it meets the requirements applying to sale in New Zealand. Review supplier details, English information, ingredients, allergens, nutrition, dates, storage and claims against the actual product. Also check the product’s permitted ingredients and any relevant border or food requirements; relabelling does not make an otherwise prohibited product admissible.

MPI allows appropriate English over-labels to correct information before sale. They must be legible and firmly attached. Completely cover incorrect original information; anything left visible, including another language, must not contradict the replacement. Review the entire pack, not just the sticker.

Use a practical final-artwork review process

AFVA recommends the following sequence to make the review traceable. It is a preparation framework, not a new statutory approval process.

1. Define the product and market. Identify the formulation version, pack size, intended use and sales arrangements, including relevant exemptions and special rules.
2. Collect the evidence. Bring together current ingredient and supplier specifications, allergens, nutrition basis, date-mark evidence and proposed claims.
3. Review the complete label. Check every panel, over-label and visible original statement at its intended size. Confirm readability, contrast and any specific type-size or positioning rules.
4. Resolve comments before printing. Give each issue an owner. Check the corrected artwork against the reviewed product information, rather than assuming a design revision closes every comment.
5. Control the released version. Retain the specification, review comments and final artwork together. Check the actual first pack against the approved business version.
6. Reassess changes. Revisit affected conclusions after ingredient, supplier, process, pack, serving-size or claim changes. Do not reuse an earlier review without checking its scope.

Common mistakes include copying another product’s nutrition values, overlooking ingredients inside premixes, using an unsupported date, assuming small packages have no information duties, and reviewing only the front panel. Use the food label review information-pack guide to prepare a focused handover.

How AFVA can help with a food label review

Access Food Verification & Auditing Limited reviews food labels for the New Zealand market and provides practical gap comments and recommendations. The scope can include ingredients, allergens, nutrition information, dates, storage, percentage declarations, claims, imported labels and artwork. Confirm the agreed scope for your product and the evidence available.

A consultancy review is not MPI approval and does not transfer the food business’s responsibility for safety, suitability or compliance. Evaluation, verification and laboratory analysis are separate functions, subject to their applicable scope and independence requirements.

Prepare the evidence before releasing artwork

Start with the actual product, identify the applicable rules and resolve gaps while the design can still be changed. A controlled recipe, evidence file and final-artwork check make the label review more useful than checking isolated statements after packaging has been printed.

Researched and reviewed on 17 October 2026. General information only: Requirements depend on the complete food activities, products, processes, locations and sales model. This guide does not replace a product-specific assessment or current official requirements.