10 Significant Changes in the Draft of Supervision and Administrative Measures on Food Labeling

On 21 November 2019, SAMR issued the Supervision and Administrative Measures on Food Labeling (draft) (herein after referred as The Draft) for public comments. Advices and opinions shall be given before 20 December 2019. The Draft is a uniform requirement for food labeling in China. CIRS has listed the 10 significant changes in the Draft for your reference.

1. The content of the label should be clearly contrasted with the background

The Draft stipulates that, the font and logo color of the label shall be clearly contrasted with the background. The difference between the percentage of light reflected from the background and the percentage of light reflected from the print should not be less than 70% in principle.

2. More contents need to be marked conspicuously

At present, only the product name shall be indicated at the prominent position of food label. According to the Draft, more contents are regulated to be indicated conspicuously at the prominent position, including the product name, production date, shelf life and warning (signs).

3. The Chinese label of imported food shall be pasted or printed in the production process

The Draft stipulates that imported food shall have Chinese labels, which shall be directly pasted, printed or marked on the minimum sales package of food during the production process. Thus it demonstrates that the Chinese labels for imported food shall be pasted or printed on the minimum sales package before the food arriving at the port. 

4. Forbid to emphasize that product is more suitable for specific people

Generally speaking, general food should be suitable for ordinary people and shouldn’t be labeled with suitable crowds or unsuitable crowds. The Draft stipulates that in the absence of relevant laws, regulations or food safety standards, food labels shall not be written with the words of “specifically for” or claim the product is more suitable for infants, children, the elderly, pregnant women and other specific groups.

5. Strict the labeling requirements for food additives

At present, all food additives can be indicated as specific names, or function name and INS codes. The Draft intends to further strengthen the labeling requirements on sweeteners, preservatives, colorants, emulsifiers, and thickeners. If above 5 kinds of food additives are used directly in food, their specific names shall be indicated.

6. Production date and expiry date shall be marked in the format of YYYY/MM/DD

At present, the format of production date and expiry date can be indicated in different orders. However, according to the Draft, the date information shall be indicated in the format of YYYY/MM/DD. And if the shelf life is within 72 hours, the dates shall be indicated in hour (24-hour system).

7. Standardize the labelling of special dietary food

The Draft stipulates that, nutrition information of the food especially for infant and other special groups shall be indicated in accordance with the order listed in corresponding national standards.

8. Add requirements for the labeling of health food filing products

In accordance with the Draft, a statement of “this product has not been registered by the market supervision and administration department” shall be indicated on the label of filing products.

9. The regulatory focus is clearly mentioned

The supervision of food labelling would be focused on the following 3 points: 
  • 1) Production date and expiry date;
  • 2) Nutrition information table of special dietary foods;
  • 3) The claims of health food labels and promotional materials.

10. Stipulate the transitional period of old labels

When the food labels fail to comply with current regulations due to the adjustment of regulatory policies or the alteration of name, address and production license number of the food producers/operators, the food producers/operators shall update the information as soon as possible. The transitional period for the use of old labels is 6 months. And products with old labels produced during the transition period are allowed to be sold to the end of shelf life.

Official Notice: http://www.moj.gov.cn/government_public/content/2019-11/21/657_3236134.html