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When you’re looking at products to buy, the first thing that might influence your decision is the packaging and labelling. So, it’s common for businesses to try and make their product look as great as possible at the point of sale.
But at what point does this become false or misleading? And how can customers be protected in 2025?
This is why labelling and packaging remains such a heavily regulated area. The main pieces of legislation to look out for are the Fair Trading Act 1986 (FTA) and the Consumer Guarantees Act 1993 (CGA). These laws have continued to be enforced rigorously in 2025 to ensure transparency and protect consumer rights.
It’s crucial that businesses understand their obligations under the FTA and CGA (along with other relevant laws) to avoid penalties and, in severe cases, costly litigation. For additional guidance on legal risks in commercial contracts, see our contract review advice.
Here’s an updated guide to help you navigate labelling and packaging requirements in New Zealand in 2025.
What Does The FTA Say?
The FTA is designed to encourage fair trading in New Zealand, protecting consumers from purchases based on misleading or deceptive information. Two main takeaways from the FTA are:
- You cannot engage in misleading or deceptive conduct (or conduct that is likely to mislead or deceive);
- Consumers should have access to all the relevant information prior to making a purchase.
This law regulates the kind of information you display on your packaging—and even what you choose to omit. Any omission of essential information can influence the customer’s decision-making process and may result in a breach.
Generally speaking, you should be asking yourself: “Is my statement capable of deceiving people? Is it likely to lead them to false conclusions about my product?” If your answer is yes, then you need to update your labels in a way that complies with the FTA.
| Examples A cleaning product that claims to kill 100% of bacteria without any scientific data or accredited testing to support this claim will be deemed misleading and deceptive. If a blanket advertises itself as being made of 100% silk when it is actually only 50% silk, this too is misleading and deceptive. |
What Happens If I Don’t Comply?
We understand that it’s easy to get carried away with how attractive you make your product appear. However, presenting misleading information is a clear breach of the FTA. Non-compliance can result in significant fines—and in serious cases, criminal prosecution. Always ensure your packaging meets the latest legal requirements for businesses in New Zealand.
It is strongly recommended to perform regular audits of your labelling practices. Staying compliant not only protects your business but also serves as a safe harbour defence if any legal claims arise.
Types Of Products
Different types of products carry different labelling obligations. Let’s take a closer look at a few important categories.
Food
For food products, regulation remains incredibly tight given the high risks to public health. The Ministry for Primary Industries continues to enforce requirements that include a precise disclosure of the country of origin and other critical details, which are essential for consumer safety and informed decision-making.
Labelling requirements for food products in 2025 will depend on several factors:
- The food category the item falls under;
- Whether it was grown, produced or manufactured in New Zealand;
- Its packaging format.
The main food categories with distinct labelling requirements include:
- Genetically modified foods;
- Alcoholic beverages;
- Honey and other bee products;
- Fish and other seafood;
- Meats and processed products;
- Products containing hemp seeds;
- Eggs and egg products.
There are many factors to consider when determining whether your products meet the required standards; therefore, it’s highly recommended that businesses selling food consult resources such as the MPI’s labelling guidance and our business setup guides for more advice.
Cosmetics
Cosmetic products also require a detailed list of ingredients to protect consumers, particularly those with sensitive skin or allergies. The Environmental Protection Authority continues to set out strict standards for cosmetic packaging.
The primary requirements for cosmetics include:
- Availability of products at the point of sale with a clearly visible batch code;
- Presentation of information in a readable and user-friendly manner—container design cannot be used as an excuse for obscure text;
- Clear listing of any potential hazards;
- Providing manufacturer contact details;
- Instructions for the safe disposal of the product.
If your business sells cosmetics, make sure to review these labelling requirements regularly. For more insights, our intellectual property resources may also be of assistance.
Chemical Products
Because chemicals present significant risks, the labelling and packaging of chemical products are subject to even stricter regulations. The EPA requires comprehensive safety data sheets and clear, compliant labelling for any hazardous materials. It is essential for businesses dealing with chemicals to be thoroughly conversant with these regulations, and many find our industry regulation guides helpful in understanding their responsibilities.
Ensure your business completes all necessary documentation and training, so you remain fully compliant and can confidently operate under current safety standards in 2025.
I’m A Seller – What Are My Responsibilities?
As a seller, it is your responsibility to verify whether your type of product is subject to specific labelling or packaging requirements. These regulations are designed to protect consumers, ensuring that all claims made on packaging are truthful and transparent.
Below is a straightforward breakdown of steps you should take to ensure compliance with the FTA and other relevant legislation:
Country of Origin Claims
A Country of Origin claim informs consumers where the product was made. Certain products, particularly food items, are required to disclose their country of origin. Always verify if your product needs such a declaration – for instance, when selling a specific food product.
For example, you might see an olive oil labelled ‘Made in Italy’. However, the claim need not be strictly in text; even a map or a graphic indicating a country can imply origin. If consumers are led to reasonably conclude an incorrect country of manufacture, this constitutes a breach of the FTA.
It is good business practice to regularly review your compliance with these regulations. This diligence not only safeguards your reputation but also provides a safe harbour if a legal challenge arises. For further reading on compliance, check out our article on what is a contract.
Pre-packaged Goods
Pre-packaged goods must comply with national trade measurement laws, which regulate details including:
- The positioning, size, and format of measurement information;
- The name and address of the packer.
Sellers and manufacturers have specific obligations under these laws, such as maintaining effective quality control systems and ensuring that packaged quantities meet the relevant standards. For more information on trade compliance, you might visit our guides section.
Labelling Requirements
Labelling requirements can be very specific – even dictating the position of measurement markings and the units used. It’s vital to ensure your labels are fully compliant to avoid enforcement actions.
For example, a common error is allowing graphics to overlap measurement markings. These markings must remain clearly visible, ideally at least 2mm away from the edge or any neighbouring images. Regularly review your labelling practices and if in doubt, consult our legal essentials for businesses resource for updated advice.
What If I’m Under A White Label Agreement?
A White Label Agreement occurs when one business sells goods or services under another business’s brand. This model is common between resellers and manufacturers. For example, if you’re selling food products like vegan donuts made by another company, the product may carry the manufacturer’s branding even though it is sold under your business name.
| Example Suppose Amie sells a range of sweets online and arranges to resell vegan donuts made by Phillip. Although consumers purchase the donuts from Amie’s online store, Phillip’s logo remains visible on the packaging. This arrangement is a classic White Label Agreement. |
How Does This Relate To Packaging Laws?
White Label Agreements must address packaging specifics since two separate businesses are involved in the sale of one product. Therefore, both parties need to agree on the final packaging and labelling content before the product reaches consumers.
Key discussion points might include:
- Details of the ingredients used;
- The mass or volume of each component;
- The layout and presentation of this information on the packaging;
- How each brand or logo is integrated into the design.
Additionally, it is essential for both parties to consider country of origin claims, pre-packaged goods requirements, and all labelling obligations. For more detailed insight, refer to our business set-up and compliance guides.
Importing and Exporting Goods – What Do I Need To Know?
Non-compliance with product labelling requirements can lead to serious consequences at the border. The New Zealand Customs Service has the authority to seize products that have inaccurate or misleading descriptions.
You cannot import or export goods that feature false trade descriptions that misstate details such as size, weight, quality, or ingredients. Always verify that your product’s details are precise and in line with both domestic and international regulations.
If you’re exporting, note that while there are no unique labelling requirements for goods destined for overseas markets, your product must still have an accurate trade description. Furthermore, it is your responsibility to confirm that your destination country does not impose additional labelling obligations, which can occasionally delay import clearance.
Additional Considerations for 2025
As we move into 2025, technological advancements are continually influencing how products are marketed and sold. Digital labelling—via QR codes or augmented reality features—has become more common, and these digital elements must also comply with relevant legal standards. Moreover, environmental sustainability and transparent recycling instructions are increasingly becoming statutory requirements. We recommend regularly consulting our legal tips info sheets to stay updated on these evolving standards.
Need Help?
The world of labelling and packaging laws can be overwhelming, as it is so heavily regulated. After all, the products you provide to consumers must be safe and accurately represented.
Nonetheless, we understand that businesses may occasionally overlook critical requirements. To avoid costly mishaps, ensure you carefully review all relevant regulations and checklists. For more comprehensive advice, consider our business setup guides.
If you’re still unsure, our team of experienced legal professionals is here to help. Whether you’re starting a new venture and need detailed advice on packaging laws or you’re entering a White Label Agreement, we’re more than happy to assist.
For a free, no-obligations consultation, please contact us at 0800 002 184 or email [email protected]. Our Sprintlaw team is ready to help guide you through the legal intricacies of modern labelling and packaging regulations.
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