Interpretation of announcement on Further Regulating the Labeling and Identification of Infant Formula Milk Powder Products (Draft)-II

On July 28, 2021, the State Administration for market Regulation solicited public opinions on "Announcement on Further Regulating the Labeling and Identification of Infant Formula Milk Powder Products (Draft)". Foodmate continues to interpret the Draft for industry reference. This is part two.

4. Requirements for label of animal origin raw material

Draft:“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.”

For infant formula milk powder whose name provides the name of animal origin,the milk and dairy ingredient of this product must all originate from the same animal species. Otherwise it is false propaganda. This provision is consistent with article 31 of Measures for the administration of formula registration of infant formula milk powder products, if the product name contains animal origin, the animal origin of raw milk, milk powder, whey (protein) powder and other dairy raw materials used shall be truthfully indicated in the ingredient list according to the product formula. If the raw materials used for dairy products are of two or more animal origin, the proportion of the raw materials of each animal origin shall be indicated. And also consistent with Interpretation 7 of Technical Guidelines for formula Registration Label Specification of Infant formula Milk Powder Products (Trial) —How to indicate animal origin in the product name? If the product name indicates that it is sheep milk powder, raw milk and milk powder should all come from sheep. It should not be labeled as sheep milk powder if raw milk or milk powder from more than two animal origin. The requirements of the label are basically the same, but the Draft further clarified that if there is one certain animal origin in the product name, in addition to raw milk and milk powder, milk protein raw materials such as whey powder should all come from the same species. There may be no label violating to this provision.


5. Label requirements for composite ingredients

Draft:“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.”

The content of this provision is greatly changed from requirement of GB 7718, which stipulates that “when a certain composite ingredient has national standards, industry standards or local standards, and the added amount is less than 25% of total food, it is not necessary to indicate the original ingredient of the composite ingredient.” It is voluntarily indicated the detailed ingredient on the label of composite ingredients. But the Draft stipulates that all the composite ingredient should be detailed list.

6. Emphasize the recommended consumption, feeding suggestions of scientific and rigorous expression

Draft:“The recommended consumption and feeding recommendations on the product label should be scientifically based, and the expression should be rigorous, and the words "must" and "strict" should be avoided.”

Currently, during the registration process, enterprises are required to provide the scientific basis for the recommended amount of food and feeding advice on the label. So this provision will not have much impact on the industry. But the enterprise should pay attention to the rigor of expression, avoid the use of "must" "strict" and other similar words


7. The transitional period for the Draft

According to the Draft“If the product label is inconsistent with the above requirements, the manufacturer shall complete the product label change within 6 months from the date of this announcement. After the change, the original label shall be stopped. Products previously produced can be sold until the end of the shelf life.” once the it was official released, there are only 6 months of transition period, so the enterprises need to do inventory labels and packaging management in advance, that is, can not affect the normal market sales, also can not lead to too much inventory affect the label change.

In combination with the Notice on The Issuance of The Action Plan for The Promotion of Domestic Infant Formula Milk Powder (2019) no.900 jointly issued by seven national ministries and commissions in 2019, industrial associations are encouraged to play the role of industry guidance and self-discipline, and make joint efforts to improve the quality and safety level of domestic infant formula milk powder. Actively complain and report violations of food safety laws and regulations. Jointly regulate product labeling and publicize claims of compliance.

From the current Draft, some requirements for the label change greatly, and the transition period is only 6 months, once released, the impact on the relevant enterprises. /Foodmate remind relevant enterprises to make preparations in advance, and promptly change the label of the registered product formula. Enterprises that register the formula according to the new national standard need to consider the impact of this announcement on the label and adjust the label in a timely manner. At the same time, Foodmate will continue to pay attention to the release of this announcement, to help enterprises to respond actively.

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