On July 28, 2021, the State Administration for market Regulation solicited public opinions on "Announcement on Further Regulating the Labeling and Identification of Infant Formula Milk Powder Products (Draft)" (Hereinafter referred to as the Draft) for further standardizing the labeling of infant formula products and urging enterprises to carry out the main responsibility and safeguarding the legitimate rights and interests of consumers. Foodmate will interpret the Draft in combination with GB 7718, GB 13432, Measures for Formula Registration of Infant Formula Milk products and Technical Guidelines for Infant Formula Products Registration Label Specification (Trial) and other documents for industry reference. This is part one.

1. The basic requirements are the same among some regulations

Draft: The product label of infant formula milk powder shall comply with the relevant provisions of food safety laws, regulations, standards and product formula registration. The content of the label shall be true, accurate, clear and easy to distinguish, and shall not contain false, exaggerated, misunderstood or absolute language.

The Draft specialized that the label of infant formula shall not contain false, exaggerated, misunderstood or absolute language, which is consistent with the basic requirements of labeling standards and regulations for infant formula. If the above requirements are reiterated again, the manufacturers need to pay special attention, and even some vague description or description nearly violate regulations need to be reassessed.

2. Requirements of content claims and function claims for infant formula milk powder

Draft: “Second Milk powders suitable for infants aged 0-6 months are not allowed to claim content and function.” The current regulatory requirements is “not allowed to claim content and function of essential nutrient.”, but the provision in the Draft stipulates that shall not claim content and function of all the nutrient. If this provision is formally adopted, the “claims for selective nutrient” should be adjusted promptly.” However, “Formula milk powders suitable for infants over 6 months of age shall not make content claims and function claims for its essential ingredients, and its optional ingredients can be used in text form on non-main display pages for content claims and function claims permitted by the national food safety standards.” is complete new. As many manufacturers have claimed essential nutrient in the labels of older infant and young children formula at present, if this provision is formally implemented, many product labels may be impacted.

However, this provision of the Draft is completely consistent with the Draft for Food Labeling Supervision and Management Measures. Therefore, it is expected that before the official release of Draft for Food Labeling Supervision and Management Measures. We also need pay special attention to the Draft.

3. Requirements for content on the main display panel

Draft:“The main display page of the product label should be marked with the product name, net content (specification), and registration number. It can be matched with a pattern that meets the requirements. It can also be marked with a registered trademark on the corners of the main display page. No other content should be marked.”

This provision limit the content on the main display. In addition to the “product name, net content and registration number” which must be indicated and the “registered trade mark” which can be selectively indicated, only some patterns matching requirement can be used. Any other text or symbols shall not appear on the main display.

As for "patterns matching requirement", it must meet the basic requirements of label, without any ambiguity and misunderstanding.

We will interpret other content of Further Regulating the Labeling and Identification of Infant Formula Milk Powder Products in next part. Please look forward to.