Consumers are increasingly shopping for food online.

The COVID-19 pandemic drastically reshaped consumer behaviour including increasing online food purchases.

In 2024, New Zealand’s annual grocery report (Commerce Commission New Zealand, 2024) highlighted that in 2019 online sales accounted for 2.91% of total sales from New Zealand’s regulated grocery retailers (major supermarket chains). This increased to 6.76% in 2022 and in 2023 accounted for 6.15% of their total sales.

The Australian Bureau of Statistics reported that online food shopping in Australia rose from $1,393 million in February 2020 to $2,088 million in February 2021 and in February 2025 totalled $3,181 million (Australian Bureau of Statistics, 2025). In submissions to the Australian Competition and Consumer Commission’s  Supermarkets Inquiry, Coles reported that online sales had increased from 4% of overall sales in the 2019-20 financial year to 9.1% of overall sales in the first half of the 2023-24 financial year (Coles, 2024). Woolworths reported that 15% of their overall sales are made online, and this is the fastest growing part of their business (Woolworths Group, 2024).

A 2024 trans-Tasman online survey found that 78% of New Zealand and 83% of Australian customers shop online every month. Of these, 42% and 49% respectively buy groceries online (Interactive Advertising Bureau, 2024). A 2023 New Zealand online survey found that 13% of New Zealand households purchase food from online supermarkets in a typical week, and 30% of households purchased food from online supermarkets in the last 12 months (New Zealand Food Safety, 2024). A 2022 Australian online survey found that 47.9% of consumers reported shopping online for food at least sometimes, with 11.5% mainly buying groceries online (Appinio and Spryker, 2022).

There are no explicit requirements to provide information for prepackaged food sold online.

The Food Standards Code regulates the labelling and information requirements for food for retail sale in Australia and New Zealand (Food Standards Australia New Zealand, 2025). This includes which foods are required to bear a label and the information required on this label. The Food Standards Code does not outline the information that should be provided online by sellers when food required to bear a label is offered for retail sale online.

Under the Food Standards Code, when a food for retail sale is required to bear a label, the following information must be provided legibly and in English as part of or attached to the package:

• Name that gives an accurate description of the food
• Name and physical address of the New Zealand or Australian supplier
• Ingredients list
• Nutrition information panel
• Information on characterising ingredients where applicable
• A date mark for foods with a shelf life of less than 2 years
• A lot/batch identification
• Any specific food storage instructions/directions for use, if applicable
• Allergen declaration, if applicable
• Warning and advisory statements, if applicable
• Statements that the food has been irradiated, genetically modified or contains cell cultured or cell-cultivated ingredients, if applicable.

There are additional labelling requirements for certain foods such as alcohol and special purpose foods. Food Ministers also encourage the use of the Health Star Rating on food labels (Health Star Rating unit, 2025).

Current labelling permissions extend to advertising of food irrespective of where that advertising is. Standard 1.2.1-23 of the Food Standards Code states that ‘if this Code prohibits a label on or relating to food from including a statement, information, a design or a representation, an advertisement for that food must not include that statement, information, design or representation’. This however does not address what information is expected to be provided for food sold online.

There are no policy guidelines on information requirements for food sold online

The trans-Tasman Food Regulation website currently has five policy guidelines or statements on food labelling. None of them relate to information for prepackaged food sold online.

The most relevant policy guideline is on food labelling to support consumers to make informed healthy choices (Australia and New Zealand Ministerial Forum on Food Regulation, 2020). It focusses on nutrition labelling aspects on the physical label but should also be considered for regulations on off label information. It outlines Ministers’ expectations that food labels provide adequate information to enable consumers to make safe and informed food choices to support healthy dietary patterns recommended in the Dietary Guidelines.

There is inconsistency in information provided when food is sold online  

Some small retailers and most major grocery retailers in Australia (Woolworths and Coles) and New Zealand (New World, Woolworths and Pak’n’save), offer online shopping. Groceries can also be purchased through third-party applications such as Milkrun, Uber Eats, and Doordash.

A 2022 study investigating more than 22,000 products sold online by major Australian supermarket retailers found that only around 50% of products displayed mandatory labelling information such as the Nutrition Information Panel and allergen declarations, while 34% of products displayed an ingredients list (Maganja D, 2023).

A 2023 study of more than 8000 alcohol products sold online by the two largest alcohol retailers in Australia found that only 0.1% had the mandatory pregnancy warning label visible on the main sales page (Pettigrew S, 2024).

FRSC recently published a background paper to inform this project (Food Regulation Standing Committee, 2025). It summarised a very small stocktake of the information provided for selected food sold online by major grocery retailers in Australia and New Zealand.  The stocktake examined only four products at each retailer. It found that most of the mandatory label information was provided on the product page except for date marking information and lot identification (this is expected as these vary by individual product). There were some inconsistencies identified in the information provided such as supplier information and storage instructions, and in one instance the nutrition information panel was not provided.

Codex Alimentarius released relevant guidelines in 2024

The 2024 Codex Alimentarius Guideline on the Provision of Food Information for Pre-packaged Foods to be Offered via E-commerce outlines that information required on the physical label of prepackaged food shall also be provided on the product information e-page prior to the point of sale (Codex Alimentarius, 2024). The purpose of this guideline is to ensure consumers buying pre-packaged foods online have the information needed to make safe and informed choices, similar to the information they would find on the physical lable of the food. 

The Codex guideline makes an exception for lot identification and date marking as these relate to an individual product and cannot be practically provided on a generic product information e-page. This information still needs to be provided on the physical label, along with all required label information, when the product is delivered to the consumer. There is an option to provide a voluntary statement informing the consumer about the relationship between the date mark and the shipping date or point of delivery.

The guideline requires a statement on the product information e-page indicating that the consumer should check the label information on the physical product before consuming. The information provided on the product information e-page should be legible, in a language suitable to the consumer and be accessible to the consumer without a charge.

The guideline states that labelling exemptions for small units do not apply to these products when they are sold online unless allowed in specific circumstances by competent authorities. This is because the space limitations of a small package don’t apply when information is provided online.

Information requirements for food sold online in other select jurisdictions.

Table 1 outlines regulations for information requirements for food sold online in the European Union, the United Kingdom, Canada and the United States of America.

Table 1: Other countries regulations for information for food sold online