Scanner Price Accuracy in New Zealand: What the Fair Trading Act Means for Every Retailer's Shelf Edge

Under the Fair Trading Act, a shelf price is expected to match what a customer is charged at the till, and the Commerce Commission estimates pricing errors cost New Zealanders tens of millions of dollars a year. Penalties for breaches have recently increased substantially. Most discrepancies aren't deliberate, they happen because a shelf tag lags behind a system price change. This post covers what the law actually says, and what closes that gap.

Table of Contents:

  • What the Fair Trading Act actually requires
  • How much pricing errors are actually costing New Zealand
  • Penalties have increased significantly
  • How price discrepancies actually happen at the shelf edge
  • Unit pricing rules retailers need to know
  • How digital price tags close the gap
  • A practical compliance checklist
  • Where to find official guidance
  • FAQs
A shelf price and a checkout price are supposed to be the same number. Most of the time they are. But every retailer running a physical store knows how easily a paper tag can lag behind a system price change, and under New Zealand’s Fair Trading Act, that gap is a real compliance question, not just a customer service one. Here’s what the law and the Commerce Commission actually say, based on their own published guidance, not general assumptions.

What the Fair Trading Act actually requires:

The Fair Trading Act prohibits misleading or deceptive conduct and false representations in trade, and pricing falls squarely within that. The Commerce Commission’s own consumer guidance is direct about what this means in practice: “When you see a price on a product or a shelf price, it is reasonable to expect that this is the price you will be charged at the checkout.” That’s not a technicality, it’s the baseline expectation the law is built around.

How much pricing errors are actually costing New Zealand:

This isn’t a small or theoretical issue. The Commerce Commission has estimated that pricing errors could be costing New Zealanders tens of millions of dollars a year, across the retail sector as a whole. That figure covers every kind of pricing mismatch, not just electronic systems, but it’s a clear signal of how much scrutiny this area is under.

Penalties have increased significantly:

As of the Commerce Commission’s own 2025 announcement, maximum penalties for Fair Trading Act breaches have increased from $600,000 to the highest of three times the commercial gain, three times the value of the transactions, or $5 million. Penalties for other conduct breaches have also increased, from $10,000 to $60,000 for individuals and from $30,000 to $200,000 for body corporates. Most breaches have also moved from a criminal liability regime to a civil one, though serious or deliberate conduct remains a criminal offence. The direction is clear either way, this is an area getting more attention, not less.

How price discrepancies actually happen at the shelf edge:

Almost none of this comes from retailers deliberately trying to overcharge. It happens because a price changes in the till system before or after someone manually updates the paper tag on the shelf, and for a window of time, however short, the two don’t match. The more SKUs a store carries and the more often prices change through promotions and supplier cost updates, the more often that gap opens up. It’s an operational problem with a compliance consequence, not a compliance problem on its own.

Unit pricing rules retailers need to know:

Separately from general pricing accuracy, New Zealand’s Unit Pricing Regulations have been in effect since 31 August 2023, requiring certain grocery retailers to display the unit price of goods clearly and legibly, at no less than 25% the size of the main marked price. If your store falls under these regulations, this is worth checking alongside your general pricing accuracy, since it’s a specific, separate requirement rather than something covered automatically by fixing shelf-to-till matching.

How digital price tags close the gap:

This is exactly the gap electronic shelf labels remove. Because a digital price tag updates from the same central system that sets the till price, there’s no manual step in between where a mismatch can creep in, both update from the same source, at close to the same time. It doesn’t replace the need to get your pricing right in the first place, but it removes the specific mechanical cause of most shelf-to-till discrepancies. We cover the mechanics in our guide to digital price tag pricing in New Zealand.

A practical compliance checklist:

  • Audit a sample of shelf prices against till prices regularly, not just after a promotion ends
  • Have a clear process for who updates shelf prices and how quickly, after any system price change
  • Check whether your store falls under the Unit Pricing Regulations, and whether your current display meets the size requirement
  • Keep a record of when pricing errors are found and corrected, in case it’s ever raised
  • Review how promotions are rolled out and wound back, since this is when most gaps appear

Where to find official guidance:

The Commerce Commission is the actual authority here, not us. Their consumer pricing guidance and their business pricing guidance are the primary sources, and worth checking directly for anything specific to your situation.

Do digital price tags help with Fair Trading Act compliance?

They help by removing the manual step where shelf and till prices can drift out of sync, since both update from the same system. They don’t replace the need to set correct pricing in the first place.

What are the current penalties for Fair Trading Act pricing breaches?
As of the Commerce Commission’s 2025 announcement, maximum penalties increased from $600,000 to the highest of three times the commercial gain, three times the transaction value, or $5 million, with lower conduct-breach penalties also increased significantly.

Want to reduce the risk of shelf-to-till pricing mismatches in your stores? EON Solutions supplies, installs and supports digital price tags across New Zealand.

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Written by Tejas Chandegara, EON Solutions.

Category: Digital Price Tags

Frequently Asked Questions About Scanner Price Accuracy in New Zealand:

Is it illegal for the shelf price to differ from the checkout price in NZ?

The Commerce Commission’s guidance is that shoppers should reasonably expect the shelf price to match what they’re charged at checkout, and this falls under the Fair Trading Act’s prohibition on misleading conduct and false representations about price.

The Commerce Commission enforces the Fair Trading Act, including pricing accuracy, and has recently increased the penalties available for breaches.

Most errors come from a gap between a till price change and a manual shelf tag update. Reducing that gap, whether through tighter processes or through electronic shelf labels that update automatically, directly reduces the risk.

They help by removing the manual step where shelf and till prices can drift out of sync, since both update from the same system. They don’t replace the need to set correct pricing in the first place.

As of the Commerce Commission’s 2025 announcement, maximum penalties increased from $600,000 to the highest of three times the commercial gain, three times the transaction value, or $5 million, with lower conduct-breach penalties also increased significantly.

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