On September 26 2021, the National Health Commission (NHC) issued the National Food Safety Standard “General Principles for Nutrition Labeling of Prepackaged Foods” (GB 28050) (draft for comments). Foodmate has compared the current version of GB 28050-2011 with this draft and analyzed the major changes of this second draft for industry reference.
1. The scope of application of the standard has been further clarified.

The scope of the draft for comments expanded as “prepackaged foods that are not directly provided to consumers and food storage and transportation packages that need to be labeled with nutrition labels shall be implemented in accordance with this standard.” That is, prepackaged foods that are not directly provided to consumers do not have to apply mandatory labeling requirement. Whereas nutrition label is necessary, it should be implemented in accordance with this standard, which is also consistent with the newly released draft of GB 7718 for comments.

2. Enriched and perfected terms and definitions.

• (1) The terms and definitions of energy, protein, fat and fatty acid, carbohydrate and sugar have been added.

• (2) Deleted the definition of "core nutrient".

• (3) Revised the definition of "Nutrient Reference Value (NRV)".

• The draft stipulates that NRV is applicable to the nutrition label of prepackaged food consumed by people 36 months of age and above. It explains the basis of NRV and adds the way of use.

• (4) Added the definition of "Serving Reference Value".

The reference value of the serving size of the prepackaged food was added in the draft, which is applicable to the food with the “serving” in the nutrition ingredient table indicating the value of the nutrient content of the food, and gives a reference suggestion value for the quality or volume of each serving of food (in edible parts).

3. The use of minority languages and the requirements for the nutrition labeling of imported prepackaged foods was added in the "General Requirements".


4. Certain mandatory labeling items and warning words were added.

• (1) The mandatory label items were revised from “1+4” (energy + protein, fat, carbohydrate, sodium) to “1+6” (energy + protein, fat, saturated fat (or saturated fatty acid), carbohydrate, sugar, sodium).

• (2) Warning requirements was added stating that "Prepackaged foods should be clearly labeled: Children and adolescents should carefully choose high-salt, high-fat and high-sugar foods."

5. Certain optional labeling items and serving size labeling requirements were added.

• (1) The "0" threshold and rounding interval for n-3 fatty acids, ɑ-linolenic acid, EPA and DHA were added in the serving size labeling items.

• (2) Added the portion size label to clarify the method of use. When labeling the energy and nutrient content of the prepackaged food by serving size, the quality or volume of each food can be referred to the value of food serving reference recommended in Appendix E.

• (3) Added other supplementary information, including explanation such as the products can use the customer-familiar "oil/salt" to replace “fat/sodium” and "Cal" to replace "kJ". The dietary guide pagoda graphics and core recommendations can be used to promote reasonable meals and “Three-Reductions (reduce salt, sugar and fat consumption)”.

6. Improve the requirements for the label value of nutritional ingredients and the interval of rounding up.

• (1) The draft clarifies the source of the label value and the expressing method of the nutritional components. That is, "The determination of the listed value of the nutritional components can be valued by testing with the current effective national standard method, or it can be calculated based on the composition of the raw materials in formula using the "Chinese Food Composition Table" and other sources of credible data. When determining the accuracy of listed nutrient values, the method should be comprehensively considered.

• (2) The names, expression units, rounding intervals and "0" thresholds of some nutrients have been revised in Table 1: a. Adding the expression units, rounding intervals, and the "0" threshold value of n-3 polyunsaturated fatty acids, α-linolenic acid, EPA, and DHA; b. Sugar and lactose are marked separately, and should meet the corresponding unit and the “0” threshold value; c. Rounding interval and "0" threshold value of vitamin A, vitamin E, vitamin B12, niacin (niacinamide) and zinc.

• (3) The allowed error range for energy value and content of nutritional components have been revised in Table 2. The allowed error range of protein, poly-unsaturated and monounsaturated fats (polyunsaturated and monounsaturated fatty acids), carbohydrates, lactose, total soluble or insoluble dietary fiber and its monomers, vitamins, minerals (excluding sodium) and other enhanced nutritional components is ≥ 80% of the listed value. The allowed error range of Energy, fat, saturated fat (fatty acid), trans fat (fatty acids), cholesterol, sodium, sugars in food is ≤ 120% of the listed value.

7. The scope of foods that exempted from the mandatory nutrition labeling is revised.

• (1) An exempt products was added in the draft which is the “single raw and dried products that are simply processed or cleaned”.

• (2) Exempt food with maximum surface area≤40cm2.

• (3) Deleted the exemption provisions for the on-the-shelf sale and the sale of pre-packaged food by measurement.

8. Revise nutrient list and delete NRV of cholesterol.

The nutrient list have been revised: the NRV of cholesterol was deleted; in the meantime NRV is still not established for chlorine, molybdenum, and chromium. NRV list contains reference values for energy and 31 kinds of nutrients.


9. More detailed description of the nutrition label format.

In Appendix B Formats of Nutrition Label, clauses have been added to describe the formats, description of servings, the labeling method of NRV and the energy unit in specific text, and some recommended formats of nutrition labels have been added.

10. The requirements for energy and nutrient content claims and comparative claims have been revised.

• (1) Appendix C specifies the requirements, conditions and synonyms for the energy and nutrient content claims of prepackaged foods. The main changes are as follows: a. The "low protein" claim was deleted; the restrictive condition of "skim" was revised to "other dairy products should meet the corresponding national food safety standards"; b.The restrictive condition of "no or do not contain saturated fat" was deleted; the restrictive condition of “low saturated fat” was revised to "saturated fat energy that supply ratio ≤ 10%"; c. The content claims and requirements of "n-3 polyunsaturated fatty acids" were added; d. The item "Carbohydrate (sugar)" was divided into "sugar" and "lactose", and the corresponding content requirements and restrictive conditions remain the same; e. The restrictive conditions claimed by "dietary fiber" was revised to list monomer components. The claim of dietary fiber was added with "soluble dietary fiber (or monomer) source or containing soluble dietary fiber (or monomer)" and "high or rich in soluble dietary fiber or (monomer)", and specify the corresponding content requirements and conditions.

• (2) The "food for comparison" in the comparative claim was revised to: a. The measured data of the same type or the same category or the same quality grade food of the same enterprise”; b. The similar food data derived from the "Chinese Food Composition Table".

This draft of comments is due until November 21, 2021, and feedback can be submitted online in the National Food Safety Standards Management Information System (https://sppt.cfsa.net.cn:8086/cfsa_aiguo).