Submission Example – QR Code Food Labelling Trial

1. Do you consider the trial parameters proposed are appropriate and fit for purpose?

No. The proposed trial to replace physical labels with QR codes is not fit for purpose because it places an undue burden on consumers. QR codes are not universally accessible—elderly consumers, disabled people, low-income households, and rural communities may not have smartphones, reliable internet, or digital literacy. Food safety information must be immediately visible at the point of purchase; a digital-only system risks accidental allergen exposure, medication-food interactions, and other harms to vulnerable consumers.

Additionally, in some shops or areas, Wi-Fi or mobile data does not reliably load, making QR codes inaccessible in practice.

2. Do you consider the exemption scope proposed is appropriate and fit for purpose?

No. Allowing QR code labelling to replace physical labels is inappropriate. Physical labels provide critical information—ingredients, allergens, country of origin, warning statements, and use-by dates—clearly and immediately. Exempting products from physical labels excludes consumers who cannot access or navigate digital systems, creating inequity and compromising consumer protection.

3. Do you consider the exemption conditions proposed are appropriate and fit for purpose?

No. Current conditions do not adequately safeguard accessibility or food safety. Any trial must ensure physical labels are retained on all products. QR codes should only be supplementary, never the sole source of information. Conditions should include clear in-store signage, an Accessibility Impact Assessment, and a consumer safety monitoring plan.

4. Are there any other matters you think the Minister should take into account before recommending an exemption?

Yes. The Minister should consider:

The U.S.-based Center for Food Safety (CFS) has previously rejected digital-only labelling, recognising it as negative for consumers and the integrity of the food system.

On-package labels are simple, quick, and effective; QR codes, websites, or 0800 numbers are not.

Vulnerable groups—including the elderly, disabled, low-income, and digitally challenged—rely on physical labels to protect their health and safety.

A QR code-only system may reduce costs for retailers but increases risks for consumers and undermines accessibility and equity.

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Additional Information – QR Code Labelling Trial

1. Practical Barriers for Consumers

In many areas, mobile reception or Wi-Fi is unreliable, making QR codes inaccessible.

Small smartphone screens, poor lighting in supermarket aisles, and complex navigation of apps or websites make scanning multiple items slow and error-prone.

Families shopping for dozens of items face an impractical burden to access critical food information.

2. Vulnerable Populations

QR codes disadvantage groups least able to use them:

Elderly consumers who may not own or regularly use smartphones

People with disabilities, including vision impairment or limited dexterity

Low-income households without smartphones or sufficient mobile data

Rural communities with poor connectivity

Many people experience migraines or headaches when using computers or phones all day and deliberately take “digital detox” breaks. Requiring QR code scanning at every purchase is mentally unhealthy and contributes to smartphone overuse and addiction.

These groups rely on clear, physical labels for immediate safety information.

3. Consumer Safety Concerns

Digital-only labelling increases the risk of accidental allergen exposure and medication-food interactions.

Relying on consumers to actively scan each item shifts responsibility for safety from retailers and importers onto individuals.

4. Evidence from Other Jurisdictions

The U.S.-based Center for Food Safety (CFS) has previously rejected digital-only labelling, recognising it as negative for consumer protection and the integrity of the food system.

International standards emphasise that food information must be available at the point of purchase; QR codes alone do not meet this standard.

5. Supplementary Use Only

QR codes may provide additional details such as sourcing, sustainability, or recipes, but should never replace mandatory on-package information.

Clear in-store signage and guidance should be provided if QR codes are implemented to avoid confusion.

6. Impact Assessment Recommendation

Before any QR code trial, an Accessibility Impact Assessment should evaluate:

Elderly and digitally unskilled consumers

Disabled consumers

Low-income households

Rural communities with poor reception

Conclusion

QR codes are not a reliable substitute for physical food labels. They may supplement information but cannot ensure equitable access or immediate visibility of critical safety details. Requiring digital-only access may also have mental health implications and contributes to smartphone overuse. Any trial should prioritise consumer safety, accessibility, inclusion, and mental wellbeing.