Food labeling has always been concerned by food manufacturers and importers in the Chinese market. Indeed, the importance of food labels can never be over-emphasized for carrying so much significant information, and for being a minefield for stakeholders, which can be proved by the fact that unqualified food labeling has been one of the top reasons for import failure. Compared with the ordinary prepackaged food with single packaging, multipack food has to deal with more complex labeling requirements, and might be more likely to fall into the minefield.

At present, the regulatory definition of "multipack food" in China is still blank. Given the actual situation and practice, multipack food can be divided into two categories according to whether the multipack food as a whole can be considered as the smallest sales unit. To make qualified labels for multipack food, you need first figure out which category your product belongs to, then make sure your products conform to the corresponding labeling requirements.

1. Multipack Food as the Smallest Sales Unit 

If a product contains multiple items, and none of them are intended to be sold separately, e.g., instant noodles with its sauce bag, which as a whole is considered as the smallest sales unit.

* This image is from Taobao.com

Labeling Requirements for Inner Packaging 

At present, there are no corresponding labeling requirements for the inner packaging in the smallest sales unit. However, we can refer to the former Food Department of National Health and Family Planning Commission's response on the labeling requirements for the instant noodles' source bag. As revealed by the response, sauce bag is considered as a part of the whole prepackaged food such as instant noodles, which is not intended to be sold separately. Therefore, labeling requirements stated in GB 7718-2011 General Standard for the Labeling of Prepackaged Foods shall not apply to such inner packaging.

Labeling Requirements for Outer Packaging 

First of all, according to the definition of "prepackaged food" in GB 7718-2011, the multipack food product as the smallest sales unit is considered as prepackaged food, which means the outer packaging of this kind of multipack food shall conform to all the labeling requirements for prepackaged food, including mandatory requirements and recommended requirements.

Besides, according to Article 45 of Q&A of GB 28050-2011 General Rules for Nutritional Labeling of Prepackaged Foods, there are two methods for the labeling of nutrient content on the outer packaging of multipack food products including instant noodles:

• Mark the average food nutrition constituents from multiple inner packing products. The average content can be the experimental data of the whole package or the nutrition constituent content calculated pro ratio.

• Mark the nutrition constituents of each inner packing product respectively, with the information of shared nutrition constituents.

Considering the production dates and shelf lives may differ from multiple items in the same sales unit, Article 18 of Q&A of GB 7718-2011 General Standard for the Labeling of Prepackaged Foods offers three options for the indication of the production date and shelf life on the outer packaging:

• Indicate the production date of the single product that is produced at the earliest and the shelf life of the single product that expires first.

• Indicate the production date on which the outer packaging is formed into a sales unit and the shelf life of the single product that expires first.

• Indicate the production date and the shelf life of every single product on the outer packaging.

Note: The labeling methods related to the production date and shelf life are also applicable to the multipack food that is not the smallest sales unit. 

2. Multipack Food as the Non-Smallest Sales Unit 

If a product contains several prepackaged foods which can be sold independently, e.g., a snack gift pack or inner items with individual packaging in a larger packaging, then the product as a whole cannot be considered as a smallest sales unit.

* This image is from Amazon.com

Labeling Requirements for Inner Packaging 

For multiple individual items in the same outer packaging which are intended to be sold independently, they should be labelled in full accordance with the requirements stated in GB 7718-2011 with no exception. Besides, these individual items are also required to be attached with the nutritional label according to GB 28050-2011 General Rules for Nutrition Labeling of Prepackaged Foods for being the smallest sales unit.

Labeling Requirements for Outer Packaging 

According to Article 17 of GB7718-2011, the labeling of the outer packaging is divided into two kinds as follows:

• Firstly, the outer packaging shall be labelled in accordance with the requirements stipulated in this standard. All mandatory labeling information of each variety of food shall be indicated on the outer packaging if several types of food products contained in the unit belong to different varieties. The shared information can be indicated uniformly.

• Secondly, the labeling information of inner prepackaged foods may not be declared on the outer packaging repeatedly if the outer packaging is easy to be opened, or the whole or part of the mandatory labeling information indicated in the inner packaging can be clearly identified through the outer packaging.

It should be noted that for multipack food product contains several individual prepackaged foods, the specification shall be declared in addition to the net content on the outer packaging, please refer to C.2 in Annex C of GB 7718-2011 for the indication of the specification.