On 14 March 2025, the State Administration for Market Regulation (“SAMR”) announced the amended Administrative Measures for the Supervision and Administration of Food Labeling (“New Measures”), replacing the current Regulations on the Administration of Food Labeling that came into effect in 2009 (“Current Measures”). Subsequently, on 16 March 2025, SAMR, alongside the National Health Commission (“NHC”), jointly released 50 national food safety standards. These include the long-awaited updated versions of the two mandatory national standards GB 7718 General Rules for the Labeling of Prepackaged Foods (“New General Standard”) and GB 28050 General Rules for Nutrition Labeling of Prepackaged Foods (“New Nutrition Standard”). Both standards have remained unchanged for 14 years since their promulgation in 2011 (“Current General Standard” and “Current Nutrition Standard”). These three pivotal documents represent the most significant changes to prepackaged food labeling in China. Coming into force on 16 March 2027, the amendments reflect evolving consumer demands and will significantly impact existing food labeling practices and related marketing strategies. This newsletter will introduce the key aspects of these amendments.
1. Changes to Mandatory Labeling Items
a) Production Date (生产日期), Expiration Date of Shelf Life (保质期到期日) and Consumption Storage Date (消费保存期)
Production date and shelf life (保质期) are two mandatory items to be indicated on food labels. The shelf life means the period a product maintains its quality under specified storage conditions. Under the Current General Standard, the shelf life can be labeled in the form of a specific date or a period (e.g., six months). When it is labeled as a period, consumers often have to perform a tedious calculation to determine the exact expiration date. The New Measures and the New General Standard now introduce a new term "expiration date of shelf life", specifically referring to a specific date when the shelf life will expire. Thus, under the new law scheme, in general cases, production date, and expiration date of shelf life, i.e. a specific date, instead of a period, shall be indicated. But in cases where production date is exempted (as demonstrated in the following paragraph), shelf life (labeled in form of a period) shall still be labeled together with the expiration date of shelf life.
The New Measures also bring clarity to production date determination. For single-layer packaged products, it is the completion date of the packaging process. For multi-layer packaged products, it is the completion of packaging directly contacting the food. However, if sterilization or fermentation is required, the production date can be extended to the completion of those processes. Despite these new rules, the New General Standard allows for exemptions from indicating a production date in three specific scenarios: for products with a shelf life exceeding six months; for products with a maximum packaging or container surface area of 20cm² or less; and for wine and alcoholic beverages with an alcohol content of 10% or more.
Another key change involves standardizing date formats and improving their visibility. According to the New General Standard, dates require a minimum font height of 3.0mm, or 2.0mm for packaging under 35cm². The only permissible date format is YYYY/MM/DD, prohibiting other common formats like DD/MM/YYYY and MM/DD/YYYY.
The New General Standard also introduces a recommendatory consumption storage date. This date means the final food consumption day, provided it has been stored according to label instructions. Food becomes inedible after its consumption storage period expires. In contrast, exceeding the expiration date of shelf life merely means the food has passed its optimal quality, but may still be edible. Therefore, the consumption storage date will always be later than the last day of shelf life.
b) Food Additives
Regarding the labeling of food additives in the ingredient list, the New General Standard permits the use of simplified labeling method, i.e. indicating functional name + INS code (e.g. emusition (477)), only when the product's maximum packaging surface area is 60cm² or less.
c) Nutrition Facts Table (营养成分表) and Nutrient Reference Values (营养素参考值)
In the Current Nutrition Standard, it is mandatory to label “1+4” core nutrients (energy, protein, fat, carbohydrates, and sodium) in the nutrition facts table. The New Nutrition Standard now expands this to “1+6” core nutrients by adding saturated fat and sugar. Furthermore, a specific salt, oil, and sugar warning stating “Children and adolescents should avoid excessive intake of salt, oil, and sugar (儿童青少年应避免过量摄入盐油糖)” shall be indicated directly below the nutrition facts table.
The Nutrient Reference Values (“NRV”) for various nutrients, particularly vitamins and minerals, have also been revised, which will directly impact the NRV% values (营养素参考值百分比) displayed on labels, potentially leading to the downgrading of nutrient claims. For instance, claims that previously met the criteria for “rich in” a nutrient may no longer be applicable.
d) Allergens (致敏物质)
Allergens were previously only recommended for labeling, and will become mandatory. They can be bolded or underlined directly within the ingredient list or highlighted in a separate warning note near the ingredient list. Furthermore, the New General Standard recommends declaring allergens that may be indirectly or potentially introduced during processing.
e) Font Size
The font size of the labelling items must now meet stricter criteria. For mandatory labeling items, a new requirement is that the height-to-width ratio of the font shall not exceed 3. The height of text, symbols, and numbers shall be no less than 1.8mm, which remain unchanged. However, for larger packaging, specific minimum heights apply. If the packaging’s largest surface area exceeds 150cm², text, symbols, and numbers outside the nutrition facts table must be at least 2.0mm high. If this area exceeds 400cm², that minimum height increases to 2.5mm.
2. Changes to Product Names and Claims
a) Product Name
These amendments provide for more detailed naming rules and explicitly prohibit those misleading naming practices. An “attribute name” (属性名称) concept is introduced as the official product name. It refers to the specific names that reflect a food’s inherent characteristics—those that are self-evident or already stated. This includes descriptions of a food or ingredient’s features, processing methods, food category, or other exclusive food characteristics. If a name is established in national, industry, or local standards, or by relevant State Council departments, one of these must be chosen as the attribute name. Otherwise, the attribute name must accurately describe the food’s true nature to prevent consumer misunderstanding. The concept of common name (常用名称) or colloquial name (通俗名称) as provided for in the Current General Standard cannot be used anymore in such case.
For food products achieving their intended taste through flavorings and fragrances instead of through a certain ingredient, the New Measures expressly stipulate that in such case, if the flavor of that ingredient is reflected in the food name, the words ‘flavored’ (某味) or ‘flavor’ (某风味) shall be added to the name.” Furthermore, for such product, the label must not feature a real photo of that ingredient or food. Instead, only patterns are allowed with a disclaimer like “the pattern is for taste reference only” (图案仅供风味参考).
For animal-derived food (动物源性食品), the New Measures add a provision that if a food’s name references poultry, livestock meat, or animal-derived aquatic products, that raw material must be the primary ingredient. Specifically, when a product name indicates a single type of animal-derived ingredient, all animal-derived raw material must come solely from that specified source. If the name reflects multiple animal-derived ingredients, they must be listed in descending order of their added quantities. For plant-derived foods (植物源性食品) simulating animal-derived foods, terms like “imitation” (仿), “vegetarian” (素), or “a certain plant” (某植物) must be added to the name to prevent confusion.
b) Content Claims
(1) Emphasizing certain ingredients using terms “added” (添加), “contains” (含有) or “low in content” (含量较低) etc.
If a label particularly emphasizes that one or more ingredients are “added” (添加), “contained” (含有), or “low in content” (含量较低), the exact amount added or the content in the final product must be clearly indicated. This must appear either directly within the ingredient list or through additional textual explanation. This rule also extends to cases where certain ingredients are specifically mentioned in the product name. Notwithstanding the above, the New General Standard outlines several reasonable exemptions where quantitative ingredient claims are not required.
(2) The term “not containing” (不含), “zero (0)” (零), and other essentially identical expressions
For food additives, contaminants, and substances that are not allowed to be added to food or should not be included in food according to laws, regulations, and standards, the New General Standard specifically prohibits the use of “free from” (不含), “without” (无), or similar terms to describe them. This means claims like “0 added” for food additives, such as “0 preservatives” (0防腐剂) and “0 sweeteners” (0甜味剂), are forbidden under the New General Standard.
For ingredients such as sugar, when terms like “free from” or “contains no” are used, the corresponding ingredient or component content must be “0” or the content otherwise specified by other laws, regulations, national standards, industry standards, or local standards.
(3) The term “no added” (不添加), “no use of” (不使用) and other essentially identical expressions
The New General Standard comprehensively prohibits the use of “no added” (不添加), “no use of” (不使用), and similar expressions, including “not added” (未添加), “zero added” (零添加), and “not used” (未使用). This ban applies to all claims asserting that a certain ingredient or a certain food additive was not added during production.
3. Digital Labels
The New General Standard establishes a crucial legal basis for the standardized application of digital labels. This opens a new avenue for food companies to manage and present product information. With the new font, ingredient list, and nutrition facts table requirements, some products may find existing physical labels lack sufficient space. Digital labeling provides a viable solution. However, further detailed regulations are still awaited.
4. Conclusion
The amendments not only redefine mandatory labeling requirements, but also will have an influence on existing marketing practices for food companies. The changes extend beyond mere label redesigns, concerning more fundamental aspects like ingredient adjustments, allergen identification, and nutrition content testing. The signal from these changes is clear: regulatory authorities will be stricter on marketing strategies on labels that can cause misunderstandings. Although the New Measures and amended standards will not be officially implemented until 16 March 2027, offering two years of transition time, companies are recommended to swiftly begin assessing their current labels and practices and make necessary adjustments in a timely manner.
