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An Analysis of GB 13432-2013 Labeling of Prepackaged Foods for Special Dietary Uses

Basic information:

Name: GB 13432-2013 National Food Safety Standard Labelling of Prepackaged Foods for Special Dietary Purpose

Issuing date: 2013-12-26

Effective date: 2015-07-01 (food products that were produced before the date can be sold until the expiry date)

Previous version: GB 13432-2004 General Standard for the Labelling of Prepackaged Foods for Special Dietary Uses

Key changes made in the new version:

1.    The classification of prepackaged foods for special dietary purpose is specified, including

1)     Formula for infants and young children

a)     Infant formula

b)     Formula for older infants and young children

c)      Infant formula for special medical purpose

2)     Supplementary foods for infants and young children

a)     Cereal-based supplementary foods for infants and young children

b)     Canned supplementary foods for infants and young children 

3)     Formula for special medical purpose (excluding infant formula for special medical purpose)

4)     Other special dietary foods excluding the above (including complementary foods nutritional supplements, sports nutrition foods and other special dietary foods with corresponding national standards).

List of National standards for foods for special dietary purposes

EN name

Issuing date

Implementation date

GB 10765-2010 Infant Formula (婴儿配方食品)

2010-03-26

2011-04-01

GB 10767-2010 Older Infants and Young Children (较大婴儿和幼儿配方食品)

2010-03-26

2011-04-01

GB 25596-2010 General Rules of Infant Formula for Special Medical Use (特殊医学用途婴儿配方食品通则)

2010-12-21

2012-01-01

Q&A of GB 25596-2010 National Food Safety Standard General Rules for Infant Formula Food for Special Medical Purpose (特殊医学用途婴儿配方食品通则 问答)

2012-02-032012-02-03

GB 10769-2010 Cereal-based Complementary Foods for Infants and Young Children (婴幼儿谷物辅助食品)

2010-03-26

2011-04-01

GB 10770-2010 Canned Complementary Foods for Infants and Young Children (婴幼儿灌装辅助食品)

2010-03-26

2011-04-01

GB 29922-2010 General Rules for Foods for Special Medical Purposes (特殊医学用途配方食品通则)

2013-12-26

2014-07-01

Q&A of 29922-2013 General Rules for Foods for Special Medical Purposes (特殊医学用途配方食品通则 问答)

2015-04-15 2015-04-15

GB 22570-2014 Complementary Food Supplements (辅食营养补充品)

2014-4-29

2014-11-1

GB 24154-201x Sports Nutrition Food (运动营养食品)

A draft

GB xxxx-xxxx Nutritional Complementary Food for Woman (孕妇及乳母营养补充食品)

A draft

2.    New requirement for infant formula labeling claims (for 0-6 month babies)

Under GB 13432-2013, the necessary ingredients in infant formula (0-6 months) should not have content and functional claims. The national standard for infant formula has specific requirements for contents of necessary ingredients. Only those meet the content requirements are qualified. Besides, babies during 0-6 months are in need of comprehensive and balanced nutrition. Therefore, it’s not unnecessary to make claims for those mandatory ingredients. According to GB 10765, the mandatory ingredients include energy, protein, fat (linoleic acid andα-linolenic acid), Vitamin A,D,E,K1,B1,B2,B6,B12, niacin, folic acid, pantothenic acid, vitamin C, biotin, sodium, potassium, copper, magnesium, iron, zinc, manganese, calcium, phosphorus, iodine, chloride and selenium, which shall have neither content nor functional claim.

3.    Energy and nutritional information labeling simplified

In the old version, there are three ways to label energy and nutrients:

  • Declare a range;

  • Declare an average value; or

  • Declare the lowest or highest value

In the nutritional information of many foods the above declaration methods are used interchangeably which makes interpretation of information confusing.

But in GB 13432-2013 it’s required to label nutritional informational in consistent ways and specific values. In addition, the energy, protein, fact, carbohydrates and Na along with other nutritional ingredients and their contents required by corresponding product standards shall be labeled in the format of “table”. If the product contains other optional ingredients or some enhanced nutritional substances, those substances as well as their contents shall also be indicated in the table if required by the corresponding national product standards. Another important new rule is that the actual values of energy and nutritional ingredients shall not be lower than 80% of the ones labeled within the shelf life.

4.  More protein labeling options

Under GB 13432-2013, if the protein in prepackaged foods for special dietary uses is hydrolyzed protein, peptides or amino acids can be labeled as “protein”, “protein (equivalent)” or “total amino acids”. The reason is that prepackaged foods for special dietary use include those for special medical which are often made of individual amino acids, designed to not contain specific amino acids, (e.g. phenylalanine) or are short peptides or amino acid degraded from protein. For this kind of product protein can be labeled as “protein (equivalent)” or “total amino acids”.

5. Consolidation of non-mandatory labeling contents

 

GB 13432-2004

GB 13432-2013

Structure

  1. Scope

  2. Normative references

  3. Terms and definitions

  4. Basic requirements

  5. Labelling contents

    • Mandatory labelling contents

    • Optional labelling contents

    • Permitted labelling contents

    • Recommended labelling contents

Appendix A Format of declaration, method of expression and tolerance limit of values declared for energy and nutrient content of foods

  1. Scope

  2. Terms and definitions

  3. Basic requirements

  4. Mandatory labelling contents

  5. Optional labelling contents

Appendix A Category of foods for special dietary uses

Through comparison of the structures, the optional, permitted and recommended labelling contents separated in the GB 13432-2004 are consolidated into one part “optional labelling contents” in the new version. Moreover, in the new one, the comparative claims for energy and nutritional ingredients have been deleted.

6. Content claim

Under GB 13432-2003, only when the contents of energy or nutritional ingredients reach the minimum value or the minimum level of allowable nutrition enhancement specified in the correspondent product standard can the product bear a content claim. If the minimum value or the minimum level of allowable nutrition enhancement is absent in the product standard, references published by other countries (regions) or international organizations shall be provided to verify suitability of content claims.

7. Functional claim

Prepackaged foods for special dietary uses that meet the requirements of content claims can have functional claims for the energy and nutritional ingredients. The wordings for functional claim shall be selected from among the standard wordings for functional claim specified in GB 28050.

If GB 28050 does not list the standard wording for a functional claim, references published by other countries (or regions) and international organizations proving the product is suitable to bear a functional claim shall be provided.

Though the standard allows room for using foreign references, officials don’t recommend adopting those claims not mentioned in GB 13432-2013 to avoid unnecessary hassle.

Additional labelling requirements raised in the above product standards

Standard

Labelling requirements

  • GB 10765

  • GB 10767

  • GB 10769

  • GB 10770

Nutrients or optional ingredients as per 100kJ should be claimed.

  • GB 10765

  • GB 10767

  • GB 10769

  • GB 10770

On the label, product category and type (such as milk-based or soybean-based product and product form) and applicable infant age should be indicated;

Label of the formula applicable to infants over 6 months old should be indicated with “If this product serves infants elder than 6 month, supplementary foods should also be used”;

Label of the older infants formula should be indicated with “supplementary foods should also be used”;

Label of the complementary food for infants and young children should be indicated with “prepared with milk or other appropriate liquids containing protein” or other similar text;

Label of Juice canned food should be indicated with the content of the original fruit and vegetable juice or original pulp.

GB 10765

 

Label of the infant formula should be indicated with “the most ideal food for infants is breast milk for infants of 0-6 months; when breast milk is absent or not enough, this product can be used.”

Images of infants or women cannot appear on the labels. It is not allowed to use the expressions such as “like human milk”, “like breast milk” or similar terms.


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