Selling Food Online NZ: Keep Product and Allergen Information Clear

Selling food online in New Zealand creates another place where product information can become outdated. A correct label can sit beside an old website description, while a delivery platform shows a different recipe. This guide explains a practical way to keep customer information connected to the food actually supplied.

Start with the food and sales format

Online food sales can involve packaged retail products, meals prepared to order, hampers or food supplied to another business. These are not identical labelling situations. Under Standard 1.2.1 on labels and other food information, packaged retail food generally needs a label unless a stated exception applies. Food that is not required to bear a label still has information duties. Check the product, packaging and sale conditions before choosing the correct route. This guide focuses on retail customer information; food supplied to caterers or other food businesses has separate Code information routes that need their own assessment.

For retail food not required to bear a label, relevant allergen declarations must be displayed with the food or provided to the purchaser on request. Standard 1.2.3 on mandatory declarations determines the relevant declaration and required name. A business should not treat the absence of a printed ingredient panel as permission to guess when a customer asks what is in a meal.

The Commerce Commission’s guidance for businesses selling online also requires accurate representations and reasonable grounds for claims. An old “dairy-free” badge, an incorrect flavour photograph or a missing qualification can change the impression of an offer. This applies to online selling across different channels, including social media.

Build one product-information record for each item

Use a product code that distinguishes flavours, pack sizes and recipes. Link the record to the current manufacturer information or controlled recipe, then identify who may approve changes. A shared product name such as “chocolate slice” is not enough when one variant has different ingredients. The following fields are a suggested business control, rather than a universal prescribed form.

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

Do not copy information from a similar product or rely on an old pack image. A photograph can help customers, but small text may be unreadable on a phone. AFVA recommends accessible text alongside clear images where useful, with the correct variant selected. Check search previews, promotional tiles and quick-order screens as well as the main product page.

For the underlying declaration rules, see FSANZ’s allergen labelling guidance and our New Zealand allergen labelling guide. Required declarations and voluntary precautionary statements serve different purposes. A “may contain” statement does not replace a declaration of an allergen that is present as an ingredient.

Give customer-service staff a reliable enquiry process

An enquiry may arrive through a website form, phone call, social-media message or delivery app. The person replying needs to identify the exact item and the current evidence. Do not let a marketing description become a substitute for an ingredient check. Use these practical steps:

1. Confirm the product, variant and order or supply date. Ask which food ingredient or allergen information is needed; do not collect unnecessary medical details.
2. Check the approved record against the recipe or supplier information. Include sauces, garnishes, toppings and components supplied separately.
3. Distinguish an allergen intentionally present in ingredients from possible cross-contact. Do not promise an allergen-free outcome unless the business has adequate grounds for that exact assurance.
4. If information is uncertain, say what is unconfirmed and refer the question to the responsible person. Do not fill the gap with a reassuring guess.
5. Record the product-information answer and evidence reference where useful, keeping access appropriate and personal information to the minimum needed.

Businesses using MPI’s Simply Safe & Suitable plan should also follow their applicable “Knowing what is in your food” procedures. These address ingredient knowledge, staff communication and checks when an ingredient or supplier changes. The online enquiry process should draw on that working knowledge rather than a separate, outdated marketing list.

Coordinate changes before the new product reaches customers

Choose a person to trigger the review when the recipe, supplier, product specification, label or claim changes. Map every place where the old information appears. A delivery-platform listing and a social-media shop may each require their own update. Tell staff what has changed and how they should answer customers during the transition.

Where old and new stock coexist, determine which version the customer will receive and whether the listing can describe it accurately. If that cannot be controlled, pause the affected offer or make another supported supply arrangement while the issue is resolved. A general “ingredients may change” message is not a replacement for accurate information about the food supplied.

Check the order flow from a customer’s perspective. Open each variant, try a phone-sized screen, inspect the basket and confirm that the enquiry route works. These are recommended release checks. They are particularly useful when a marketplace imports information from a spreadsheet or a website automatically inherits copy from another SKU.

Worked example: two similar products, different information

Hypothetical example: a small bakery sells a plain brownie and a walnut brownie online. A website update copies the plain brownie description into both product pages. The walnut product still has its correct label, but the online listing does not match the product being offered.

The manager checks the two SKU records, corrects the affected description and images, reviews every sales channel and gives the customer-service team the current information. They also examine orders already received against the stock supplied and follow their food safety procedures if any product-information problem requires further action. The record explains what changed, who checked it and the effective date. This example is an information-control exercise, not an allergen incident or recall decision rule.

Before releasing an online food listing, use this short checklist:

• The selected variant matches the approved recipe or supplier specification and the food available for supply.
• Required allergen information can be provided accurately, and applicable label declarations are correct.
• Photos, ingredients, claims and storage information agree; no unsupported badges or inherited wording remain.
• The website, third-party ordering channel and staff reference record have been checked together.
• Customers have a clear route to ask questions, and a responsible person can resolve uncertain information.
• The reviewer, evidence version, date and next change trigger are recorded.

Frequently asked questions

Get your product information reviewed

AFVA provides food label review and practical gap recommendations for New Zealand food businesses, including manufacturers, importers and start-ups. Bring your current label, recipe or supplier specification, online listings and the questions you need resolved. Contact AFVA about your online food-information review so the scope can be agreed. A review is not regulatory approval, and final responsibility remains with the food business.

General information checked on 31 October 2026. Apply the current requirements for your actual product, sale format and registered food safety programme. The example and suggested records are recommendations, not a complete legal or food safety assessment.