Since the implementation of new “Food Safety Law of the People's Republic of China”, the Chinese government has paid more and more attention to supervision and administrations food production and trading activities. Food labeling has always been one of the focuses of administrations food production in China. Some National food safety standards such as “National Food Safety Standard, General Standard for the Labeling of Prepackaged Foods” (GB7718-2011), “National Food Safety Standard, General Rules for Nutrition Labeling of Prepackaged Foods”(GB28050-2011) and some National Regulations such as “Provisions for the Administration of Food Labels” contain provisions which can be exempted in China, Foodmate has summarized the provisions which can be exempted for your reference.

1. Summary of Exemptions from Labeling Requirements of prepackaged foods

1.1 Shelf life

The following prepackaged foods can be exempted from declaring shelf life:

a. alcoholic beverages in which the alcohol content is 10% or over
b. vinegar
c. salt
d. sugar in solid form （such as White granulated sugar, White soft sugar, Brown sugar, crystal sugar, etc.）
e. MSG


1.2 Nutrition labeling

The following prepackaged foods are exempt from mandatory nutrition labeling:

a. Fresh food, such as packaged raw meat, raw fish, fresh vegetables and fruits, fresh eggs, etc.
b. Alcoholic beverages in which alcohol content is ≥0.5%
c. Food with total packaging surface area being ≤100 cm2 or with the largest surface area being ≤20 cm2
d. Food prepared and sold on the spot
e. Packaged drinking water
f. Prepackaged food of which daily intake level is ≤10 g or 10 mL
g. Other prepackaged foods that are exempt from nutrition labeling according to the provisions of the laws, regulations and standards.

However, Nutrition labeling cannot be exempted in the following cases:

a. there is any nutrient such as "Protein ≥3.3%" on the prepackaged food label;
b. a prepackaged food in which nutritional fortification substances or “hydrogenated” or “partially-hydrogenated” vegetable oils are used;
c. there is any nutrition claim or nutrient function claim on the prepackaged food label.


1.3 The place of origin

If the address of the manufacturer is the actual place of the place of origin, or if the company which by law bear independent statutory and the manufacturer are in the same prefecture-level region, the place of origin can be exempted.

However, the place of origin shall be declared in the following cases: first, if the products produced by branch office or production facility of a group company, and only have the name, address of the group company declared, the place of origin shall be declared. Second, if contract packer authorized to produce the prepackaged food, and only the name and address of the company that authorizes the contract packer be declared, the place of origin shall be declared.

1.4 Other circumstances

a. For imported prepackaged food

For imported prepackaged food, the country or region (such as Hong Kong, Macao or Taiwan) of origin, and the name, address and contact information of the agent, importer or distributor registered in the People’s Republic of China, shall be declared. The name, address and contact information of the manufacturer can be exempted. Serial number of the food production license and product standard code can be exempted too.

b. A package or container whose largest surface area is less than 10cm2

For a package or container whose largest surface area is less than 10cm2, the name of the product, net content, the name and address, production date and shelf life of the manufacturer or distributor may only be declared. List of ingredients, storage conditions, serial number of the food production license and product standard code can be exempted.

c. The prepackage foods to be offered to consumers indirectly

Labels of the prepackaged foods to be offered to consumers indirectly shall, indicate food name, specification, net content, production date, shelf life as well as storage conditions. List of ingredients, serial number of the food production license and product standard code can be exempted. The contents not declared on the label shall be clearly indicated in the instruction or contract.


2. Instructions of the exemptions

The exemptions mean that the items are not the mandatory labeling information, the manufacturer and the distributor can choose whether to label it or not. If the condition changed, exemptions may be converted to mandatory labeling items. For example, a prepackaged food is exempt from mandatory nutrition labeling as “National food safety standard General Rules for Nutrition Labeling of Prepackaged Foods”(GB28050-2011), but there is some nutrition claim or nutrient function claim on the prepackaged food label, nutrition labeling shall be adhered, and nutrition labeling cannot be exempted.