On January 19, 2024, the National Health Commission of China released a draft for soliciting opinions on four standards, including the General Rules for Prepackaged Food Labeling of National Food Safety Standards (GB 7718). Foodmate reviewed and compared the draft with the current GB 7718, and summarized the main changes related to imported food labeling as follows.

1. General requirements for imported food labels.

For imported prepackaged food labeling in Chinese, mandatory identification of the contents of the Chinese and foreign languages should have a one-to-one correspondence. The contents expressed in other foreign languages or traditional Chinese characters visible on the label should have a correspondence with the standardized Chinese characters (except for trademarks, producers and addresses of imported foods, names and addresses of foreign operators, and websites).

2. Changes to the Rules on Food Names.

In order to ensure that the attribute name truly and accurately reflects the true attribute of the food and avoid misleading consumers, it is required that the name of the attribute should be indicated in the same font, size, and color. The requirements for the use of attribute names are standardized to avoid misleading food names to consumers.

3. important Changes in Ingredient Labeling.

(1) Compound ingredient (ingredient added directly to food, which is made from two or more other ingredients or constituents (excluding compound food additives)) added to compound ingredient may not be labeled with their original ingredients. That is to say, the compound ingredient must be labeled separately and cannot be expanded to combine with the original ingredients.

(2) The labeling requirements of strains in the ingredients list have been added. For strain directly added in the production process without inactivation or removal process, the specific name of the strain added shall be marked, and the corresponding strain number and strain content may be marked at the same time. In addition, labeling requirements have also been established for whether the strains play a fermentation role in food, as well as whether they have been inactivated or removed through filtration and other methods.

4. Add the registration number of overseas production enterprises.

In accordance with the requirements of the General Administration of Customs of the People’s Republic of China (GACC), the requirements for labeling the registration number of the overseas production enterprise in China or the registration number approved by the competent authority of the country or region where the imported food is located have been added. This requirement is derived from the administrative requirements in GACC Decree No. 248. In the long run, it is recommended to indicate the registration number in China.

5. Detailed Labeling Requirements for Country of Origin (Region).

If the goods are obtained completely in one country (region), that country (region) is considered as the country of origin (region). If two or more countries (regions) are involved in the production of goods, the country (region) where the substantial changes are finally completed is considered as the country of origin (region). If the bottling or repacking country or region is inconsistent with the country of origin, both should be indicated. The source or production country or region of raw materials/ingredients can also be indicated.

6. Exemption from Labeling Production Date.

imported foods with a shelf life of more than one year may not be required to indicate the production date. For imported foods that do not indicate the production date, it can be inferred and indicated based on information such as the best before date and shelf life. Additionally, for wines and alcohols with an alcohol content of 10% or more, the production date can be replaced by a batch number, and no longer required to indicate a production date.

7. Adjusted the labeling requirements of allergenic substances.

The list of allergenic substances has not been changed, but the labeling of directly added allergenic substances has been changed from recommended to mandatory. Allergenic substances that may be introduced into production lines can be recommended for labeling.

8. Added the requirement for digital labels.

Food manufacturers may choose whether to use digital labels as label carriers. When using digital labels, it is necessary to comply with the relevant regulations of the standard and ensure that the information indicated by the digital labels is directly displayed on the first level page after scanning the code to obtain information, while avoiding pop-up advertisements, etc.

Summary

This draft is the third public solicitation of opinions since 2019. Firstly, it implements the relevant provisions of the Food Safety Law on food labeling. Secondly, it also summarizes the opinions and suggestions collected during the implementation of the current version of the standard. In addition, standard revision agencies also draw on the experience and trends of other countries and international organizations in the management of food labeling, aligns itself with the international practice, and focuses on the harmonization with the existing regulations and standards. Foodmate will continue to pay attention to the subsequent release and implementation requirements of the draft, providing timely interpretation of the labeling and compliance of imported food.