November 12, 2021, the SAMR issued an announcement on the further standardization of infant formula milk powder product labeling (Hereinafter referred to as Announcement). Since the date of the announcement, the application for registration of infant formula milk powder products by this implementation. From February 22, 2023, the labeling and identification of products produced shall meet the requirements of this announcement. Products produced before can be sold until the end of the shelf life. Foodmate combines GB 7718, GB 13432, Administrative Measures for the Registration of Infant and Young Children Formula Milk Powder Product Formula, Technical Guidelines for the Registration of Infant and Young Children Formula Milk Powder Products (Trial) and other documents to interpret the content of this announcement for reference. Today is part 1.
1 The basic requirements are consistent
Original: 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.
Interpretation: The "Announcement" specifically pointed out that the label of infant formula milk powder products must not contain false, exaggerated, misunderstood or absolute language. It is consistent with the basic requirements of the current labeling standards and regulations for infant formula milk powder products. To reiterate the above requirements, the majority of manufacturers need to pay special attention, and even some "vague" or "scratching" descriptions in the early stage need to be reassessed.
2 Infant formula milk powder content claim and function claim requirements are more stringent
Original: Milk powders suitable for infants aged 0-6 months are not allowed to claim content and function. 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.
Interpretation: based on the original "essential ingredients shall not be allowed to make content claims and function claims", it has been expanded to "0-6 months old infant formula milk powder shall not make content claims and function claims". That is to say, all nutritional ingredients are not allowed to claim content and function. Companies need to promptly adjust the labels of infant formula milk powders that have claimed "selective nutrients". Meanwhile, “infant formula milk powder 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 allowed by the national food safety standards” is newly content. As many companies currently claim essential ingredients on the labels of older infant and toddler formula milk powder, the implementation of this clause will affect the labels of many products.
3 The content of the main display page is further clarified
Original: 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.
Interpretation: In the “The main display page of the product label should be marked with the product name, net content (specification), and registration number. It can be equipped with graphics that are required by national food safety standards and will not misunderstand consumers. The registered trademark can also be marked on the corners of the main display page. No other content is allowed.” This means that the "Announcement" restricts the content of the logo on the main display. Except for the "product name, net content and registration number" that must be marked and the optional "registered trademark", only some graphics that meet the requirements can be marked. Any other words or symbols shall not appear on the main display surface.
4 Further clarified the labeling requirements for animal origin
Original: If there is a certain animal origin in the product name, the raw milk, milk powder, whey powder and other milk protein materials should all come from that species. Where the milk protein raw materials used have two or more animal origins, the proportions of various animal origin raw materials shall be indicated in the ingredient list.
Interpretation: The "Announcement" further clarified that the product name includes a certain animal source, except for raw milk and milk powder, whey powder and other milk protein materials should all come from the same species.
