Coeliac New Zealand plays a vital role in advocating for people with coeliac disease by representing their needs at a national level and working to improve awareness, diagnosis, and support. Through ongoing engagement with government agencies, healthcare professionals, and the food industry, the organisation helps to ensure safer food labelling, better access to gluten-free options, and improved standards of care.

One example of this advocacy is that Coeliac New Zealand has recently submitted on the proposed trial of digital labelling for imported food products.

Summary of our submission

Coeliac NZ recognises the potential value of exploring modern labelling technologies, including improved transparency, reduced costs, and more streamlined access to product information. However, for people living with coeliac disease - and for others who manage medically necessary dietary restrictions - food labelling is not a convenience. It is a matter of health, safety, equity, and human rights. Coeliac NZ exists to support people with coeliac disease, and their needs remain central to our position. Importantly, the implications of this proposal extend well beyond coeliac disease. All individuals with food allergies and intolerances rely on clear, consistent, and reliable labelling to make safe food choices. The ability to trust food labels at the point of purchase is fundamental to public health.

Digital innovation in food regulation has potential benefits, but it must never come at the expense of consumer safety. This is not a niche concern; it is a core public health responsibility. Our submission outlined where Coeliac NZ supports innovation and where we believe safeguards must remain non-negotiable.

Where We See Value in Innovation

• Digital labelling as a complement, not a replacement. Coeliac NZ supports trials that explore digital labelling as an additional tool to enhance consumer access to information. Used appropriately, digital platforms may reduce unnecessary relabelling costs for imported speciality products and improve affordability and product choice.
• Embracing change and technology. We acknowledge that innovation can expand access to a wider range of food products, particularly imports. Coeliac NZ supports technological advancement when it is implemented safely, inclusively, and without undermining existing protections.
• Transparency, efficiency, and traceability. Digital labelling could allow for faster updates, reduced duplication, and improved traceability across supply chains—provided that digital information mirrors physical allergen declarations exactly and without delay.
• Evidence-based exploration. We welcome carefully designed trials that generate robust data on consumer experience, regulatory oversight, and enforcement. Any such trial must include independent evaluation and meaningful input from patient and consumer advocacy groups.

Where We Hold Firm

• Digital-only labelling is unacceptable. For people with coeliac disease, immediate and reliable access to allergen information at the point of purchase is critical. Even trace amounts of gluten can cause serious harm. Removing physical allergen declarations introduces unacceptable risk and undermines food safety.
• Retailer exemptions increase risk. While the trial parameters appear structured, exempting approved retailers from physical labelling requirements creates a significant safety gap. Coeliac NZ strongly recommends that both physical and digital labelling be mandatory throughout any trial period.
• Equity and accessibility cannot be optional. Digital-only labelling assumes universal access to smartphones, digital literacy, and reliable internet connectivity. These conditions are not guaranteed, particularly for elderly, rural, low-income, or disabled consumers. Requiring QR code scanning to verify food safety excludes vulnerable groups and undermines inclusive food regulation. Safe food access must never depend on technology ownership or digital skills.
• Erosion of trust and transparency. Consumers already face systemic challenges in accessing safe food. Shifting allergen information to digital platforms risks confusion, misplaced QR codes, inconsistent updates, and reduced confidence in food safety systems.
• Gaps in legal enforceability. Current food safety legislation is designed around physical labels. Digital-only allergen declarations may be more difficult to verify, trace, or enforce, weakening consumer protection and regulatory accountability.

Coeliac New Zealand Recommendations

To ensure consumer safety and equity, Coeliac NZ recommends that any trial of digital labelling include the following safeguards:

1. Physical allergen labelling remains mandatory
   All products, including those in trials, must retain clear, legible, and accurate allergen declarations on packaging.

2. Digital labels must exactly replicate physical labels
   Digital information must mirror physical allergen statements and gluten-free status verbatim, with no discrepancies or delays.

3. Exclusion of high-risk product categories
   Products making gluten-free claims or those commonly consumed by people with coeliac disease should be excluded from any digital-only labelling trial.

4. Independent testing of imported gluten-free products
   All imported products labelled gluten-free should undergo independent testing in New Zealand to confirm compliance with FSANZ standards (nil detected).

5. Clear consumer education and opt-out mechanisms
   Consumers must be clearly informed when digital labelling is used and be able to choose physically labelled alternatives.

6. Independent evaluation with patient group input
   Trial outcomes must be assessed in consultation with health advocacy organisations, including CNZ, with transparent reporting on safety, accessibility, and consumer impact.

7. Equity as a guiding regulatory principle
   Trial designs must demonstrate that consumers without smartphones, internet access, or digital literacy can still access allergen information immediately and reliably.

Lived Experience: Why Physical Labels Matter

One of Coeliac NZ’s board members, a woman in her twenties, highlights the real-world implications: “As someone who is not always able to access my phone, I find the prospect of being left in the dark about ingredients deeply concerning. This risk will disproportionately affect older or lower-income members of the coeliac and wider allergy community. Further, if recipes change while SKU numbers remain the same, digital information may not accurately reflect the batch on shelf, compounding safety risks.”

Conclusion

Coeliac New Zealand supports innovation that enhances transparency, affordability, and consumer choice - but not at the expense of safety, accessibility, or equity. For people with coeliac disease, physical allergen labelling is a matter of health and human rights. Digital labelling may provide value as a supplementary tool, but mandatory on-pack allergen declarations must remain the cornerstone of food safety regulation. We urge MPI to ensure that any digital labelling trial is designed with robust safeguards, independent oversight, and meaningful engagement with patient communities. Safe and equitable access to food must remain the primary driver of regulatory change.

Advocacy efforts like these empower everyone living with coeliac disease by giving them a collective voice through Coeliac New Zealand. Please continue to support the organisation that represents you, so that people living with coeliac disease can benefit from a more inclusive, informed, and supportive environment that enables them to manage their condition safely and confidently. You can support our efforts to support you by becoming a member: Join Today! or make a Donation.