China implements a mandatory labeling system for genetically modified foods. As long as the food contains or uses genetically modified ingredients, it shall be regulated as genetically modified food, and there is no specific content definition requirement.


The agricultural genetically modified organisms (GMOs) catalogue under China's label management shall be marked for agricultural GMOs that are listed in the label management catalogue and used for sale; those that are not marked or are not marked as required shall not be imported or sold.
At present, only the first batch of agricultural GMOs catalogues that implement label management are released: 1. Soybean seeds, soybeans, soybean meal, soybean oil, soybean meal; 2. Corn seeds, corn, corn oil, corn flour (including tax number 11022000, 11031300, 11042300 corn meal); 3. Rapeseed, rapeseed, rapeseed oil, rapeseed meal; 4. Cotton seeds; 5. Tomato seeds, fresh tomatoes, tomato paste.
Although tomatoes are in the catalog, there are currently no genetically modified tomato products in China.

According to "Management measures for identification of agricultural genetically modified organisms", there are three methods for the identification of genetically modified food:
 (1) Genetically modified animals and plants (including seeds, breeding livestock and poultry, aquatic seedlings) and microorganisms, genetically modified animals, plants and microbial products. Products containing genetically modified animals, plants, microorganisms or their product ingredients, such as seeds, breeding livestock and poultry, aquatic seedlings, pesticides, veterinary drugs, fertilizers and additives. The above cases are directly labeled "transgenic ××".
 (2) Directly processed products of genetically modified agricultural products are marked as "transgenic ×× processed products (manufactured products)" or "processed materials are genetically modified ××".
 (3) Products made from agricultural GMOs or products that contain agricultural GMOs, but products that no longer contain or cannot detect genetically modified ingredients in the final sales product shall be marked "This product is processed by genetically modified organisms. However, this product no longer contains genetically modified ingredients" or shall be marked "There are genetically modified ingredients in the raw materials of this product ××, but this product no longer contains genetically modified ingredients".
If it is difficult to mark agricultural GMOs on the original packaging label, the method of adding GMOs to the original packaging label can be used for marking, but the additional marking should be firm and durable. The specific methods are as follows:
 (1) Agricultural GMOs in the fast food industry and retail industry that are difficult to be marked on each sale product can be marked on the product exhibition (display) counter (table), or marked on the price tag or set up a labeling board (Brand) for identification.
 (2) For agricultural GMOs without packaging and labels, they can be identified by setting up identification boards (brands) when selling them.
 (3) For agricultural GMOs that are not packaged in a transport container, they can be marked on the container at the sales site during the sale, or an identification board (brand) can be set up for identification.
 (4) For agricultural GMOs without packaging and labels, it is difficult for them to be marked through the identification board (brand) when they are sold. Then, the seller should declare them in an appropriate way.
 (5) For imported agricultural GMOs that are not easily packaged and labelled, they should be marked on the inspection (customs) declaration form when they are not easy to be marked with identification plates (brands).


When the raw materials used in food are non-GMO, and the agricultural GMOs catalog under label management contains the substance, the producer can label or declare its product as "non-GMOs." For example, soybeans are in the catalog, products produced using non-GMOs soybeans can be labeled or declared as “non-GMOs”.
Those that are not in the agricultural GMOs catalog shall not carry out "non-transgenic" publicity and labeling. If china has not approved the import of raw materials for processing, has not approved the commercial planting in the country, and the genetically modified crops and processed products do not exist on the market, the use of non-genetically modified labels and advertisements is prohibited.
For example, sunflower seeds are not in the label management catalog. Therefore, sunflower seeds on the market must not be labeled or declared as "non-GMOs."

Genetically modified marker position: (1) The logo should be printed directly on the product label; (2) The label should be close to the ingredient list or raw material composition of the product. Those without a list of ingredients and ingredients should be marked near the product name.
"GMOs" font specifications: (1) When the maximum surface area of the package is greater than or equal to 10cm2, the text specifications should meet: ---The height is not less than 1.8mm; ---Not less than the text of other minimum mandatory markings in the product label. (2) When the maximum surface area of the package is less than 10cm2, the text specification shall not be less than the other minimum mandatory text on the product label.
GMOs font color: (1) The color is the same as that of other mandatory labels in the product label. (2) When the text color is different from other mandatory labels in the product label, it should be obviously different from the label's background color, and the color difference should not be used to make it difficult for consumers to identify.

China mandates that all agricultural GMOs listed in the labeling management catalogue and used for sale shall be labelled according to the prescribed method; those that are not labelled or not labelled in accordance with the regulations shall not be imported or sold. Those not in the catalog shall not be marked or declared non-GMOs. The text position, text specification and color of the genetically modified label are also stipulated. The color of the genetically modified label should be significantly different from the background color of the label, and the color difference shall not be used to make it difficult for consumers to identify. 

---

Please note: Original English article of Business Division of Food Safety and Regulatory Compliance of Global Foodmate, please indicate the source from the Global Foodmate if reprint.

Business Division of Food Safety and Regulatory Compliance of Global Foodmate provides food standards & regulations research, labelling 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. 

Please feel free to contact us: +86 10 68869850, E-mail: global_info@foodmate.net