During food production, food enterprises might encounter questions like, which foods are allowed to be sub-packaged? What specific requirements are there for sub-packaging? Global Foodmate has summarised the principles on sub-packaging for food production enterprises and some FAQs as follows:
1. Definition of sub-packaging
According to the Reply on Issues related to the Supervision and Management of Food Sub-Packaging and Sub-Packaged Foods issued by former MOH, foods that are simply packaged or added with a small amount of other ingredients belong to sub-packaged foods.
It should be noted that adding a small amount of other ingredients should not change the property of the processed food.
2. Principles on sub-packaging behaviours
According to Chinese regulations, regulations on sub-packaging are subject to the requirements of food production license. If sub-packaging is not mentioned in the detailed rules of certain food production license, sub-packaging is not allowed.
3. FAQs
Q: Can food enterprises sub-package the food they want?
A: Sub-packaging is one of the production behaviours. Food enterprises need to acquire corresponding license before conducting sub-packaging of certain food, and the food needs to be listed in the SC license directory.
Q: How to label the production date and shelf life for sub-packaged foods?
A: The production date of sub-packaged foods shall be the date of sub-packaging. The shelf life shall be the original shelf life, but if the shelf life of sub-packaged foods with added ingredients is shorter than that of original foods, the shelf life of finished product shall be the shorter one.
Q: Are there any special labelling requirements for sub-packaged foods?
A: The company name and the address of sub-packaging company shall be labelled, and the word of ‘sub-packaging’ shall be marked.
Q: Are there any prohibited sub-packaging behaviours by law?
A: According to Article 81 of Food Safety Law, powdered formula for infants and young children are not allowed to be produced in the means of sub-packaging, same company is not allowed to produce infant formula with different brands by using same formulation. Violation of the law will be punished in accordance with Article 124 of Food Safety Law.
Q: Are sub-packaged foods allowed to be sub-packaged again?
A: Currently, this act has not been mentio
ned in detailed rules for reviewing various foods, and it is not specifically prohibited in laws and regulations. It is recommended to co
nsult local authorities.
Please note: Original English article of Global Foodmate of Information Service and Business Department, please indicate the source from the Global Foodmate if reprint.
Global Foodmate Information Service Centre provides food standards & regulations research, labeling compliance consulting/Chinese label design, industry public opinion monitoring and analysis, registration services (of Infant formula, FSMP, Health food, Novel Food Ingredients, Novel Food Additives, New Varieties of Food-Related Products and Overseas manufacturers of imported food) and other comprehensive food safety solutions for domestic and overseas enterprises and institutions in food industry.
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