Labeling of Prepackaged Food in China

Regulatory Amendment

On 26 November 2018, The Food Safety National Standard Review Committee issued General Rules of the Labeling of Prepackaged Food (Draft for Comments) (“Draft”) calling for public comments. The Draft makes amendments to the current General Rules of the Labeling of Prepackaged Food GB 7718-2011 (“Current Version”) and is expected to come into force soon. The Draft is a mandatory national food safety standard for the implementation of the Food Safety Law, which aims to regulate the food market on food labeling, and ensuring food safety. Major changes and new developments under the Draft are summarized below.

Requirements for imported prepackaged food

The Draft allows imported prepacked food labels to be bilingual. Simplified Chinese is always required; the second language can either be traditional Chinese or a foreign language. The size of lettering of traditional Chinese or foreign language shall not be larger than the size of the simplified Chinese characters.   

In case the imported prepackaged foods are sold directly to consumers, the labels shall state in Chinese: the product name, ingredient list, net content and specifications, name of the distributor or importer or agent, their address and contact information, country of production, production date and shelf life, storage conditions, etc.

Ingredients on labels

The Draft explicitly prohibits several ways of labeling food products by only showing certain ingredients. For example: if flavors are enhanced by, or totally consisting of, extracts of a certain product, the draft prohibits the use of photos of the original ingredients (the ingredients which the extracts are made from) on the packaging, to avoid misleading consumers. The Draft also prohibits using expressions like "no added" or "no use" and similar terms.

Information on allergenic ingredients

The Draft requires that ingredients which may cause allergic reactions, like nuts, fish, eggs, grain, dairy, etc., shall be clearly marked in the ingredients list. The allergenic elements shall be underlined and marked in bold font. In the appendix of the Draft one may find examples of correct labeling.

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