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 2 (Part 1 is reported).


5 It is clear that the primary ingredients of the compound ingredients need to be fully identified

Original: The compound ingredients in the ingredient list of the product label shall be marked in strict accordance with the requirements of the national food safety standards. If an ingredient is a compound ingredient composed of two or more other ingredients (excluding compound food additives), the name of the compound ingredient should be indicated in the ingredient list, and then the original ingredients of the compound ingredients are indicated in the parentheses in the descending order of the added amount.

Interpretation: This requirement is quite different from the GB 7718. GB 7718 stipulates that "where a compound ingredient (for which a name has been established in a national, trade or local standard) constitutes less than 25% of the food, its primary ingredients need not be declared." However, Article 5 of the announcement requires that all compound ingredients must be labeled with primary ingredients.


6 Emphasize that the recommended consumption and feeding recommendations on the product label should be scientific and the expression should be rigorous

Original: The recommended consumption and feeding recommendations on the product label should be scientifically based, and the expression should be rigorous, and the words "必须" and "严格" should be avoided.

Interpretation: At present, in the process of registration and application, companies are required to provide the scientific basis for the recommended consumption and feeding recommendations on the label. Therefore, this article will not have much influence on the industry. The "Announcement" further clarified that the words "必须" and "严格" must not be used. Foodmate reminds companies to pay attention to the rigor of expression and strictly follow the requirements of the "Announcement".


7 Further emphasis on industry self-discipline

Original: Encourage industry associations and other social organizations to play the role of industry guidance and self-discipline, and standardize product labeling and publicity claims. If any organization or individual finds violations of this announcement or other food safety violations or violations of consumer interests, please call "12315" to make a complaint and report.

Interpretation: The "Announcement" further emphasized that social organizations such as industry associations should strengthen industry self-discipline and guide the development of the industry. At the same time, social forces are encouraged to govern together and actively complain about food safety violations. Work together to standardize the compliance of product labeling and promotional claims better.

Summary:

The "Announcement" clarified that from the date of issuance, the application for registration of infant formula milk powder product formulas shall be implemented accordingly. Foodmate reminds relevant companies that for label changes to registered product formulas, companies that should register formulas by the new national standard should fully consider the impact of this announcement on the labels and adjust the labels promptly. For product labeling, the announcement gives a transition period of more than one year. Foodmate reminds companies that they need to manage inventory labels and packaging in advance, that is, they cannot affect normal market sales or cause excessive inventory to affect label replacement.