Navigating Food Repackaging Regulations in China

Food repackaging generally refers to the process of transferring food products from their original bulk packaging into smaller, consumer-friendly packages or different containers. In China, a 2004 reply from the Ministry of Health regarding food repackaging and supervision states that the production date of repackaged food should correspond to the date of repackaging, whether the food is repackaged in its original form or with the addition of small amounts of other ingredients. Based on this, food repackaging can be understood as the redistribution of prepackaged food into smaller units, often involving simple handling or minor modifications, typically carried out in a controlled manner to ensure food quality. This article provides an overview of the regulatory requirements surrounding food repackaging in China.

Enterprises Qualified for Food Repackaging

To legally engage in food repackaging, enterprises must obtain a food production license. According to the General Rules for Food Production License Inspection, applicants are required to provide detailed product information in compliance with the Food Production License Classification Directory. For products that intended to be repackaged, enterprises must clearly indicate this in the product details section. Foods that are not explicitly permitted for repackaging in the detailed inspection rules are prohibited from being repackaged.

Labeling Requirements for Repackaged Food

Several regulations provide clear guidance on labeling for repackaged food:

Repackager labelling: Regulations on Food labeling Management stipulate that repackaged food shall clearly display the name and address of the repackager, as well as include the term “repackaged” on the label.

Origin Identification: For repackaged food, the country of origin is identified as the repackaging address. According to the GB 7718: National Food Safety Standard General Standard for the Labeling of Prepackaged Food (2024 Draft), if the repackaging location differs from the original country or region of origin, both the repackaging location and the original origin should be listed. Additionally, the Draft suggests that it is optional to indicate the source or production country/region of raw materials or ingredients.

Production Date and Shelf Life: As per the 2004 official reply on food repackaging and supervision, repackaged food should display the repackaging date as the production date. The shelf life should be in line with the original food's shelf life unless an added ingredient has a shorter shelf life, where the shorter shelf life must be displayed. In addition, the 2024 Draft Administrative Measures for Supervision of Food Labeling reiterates that the shelf life of prepackaged foods produced by repackaging must follow the original food’s shelf life.

Ingredient Labelling: The 2024 Draft Administrative Measures for Supervision of Food Labeling also proposes that the ingredient list of repackaged food shall clearly indicate the ingredients of the original food, and the term “repackaged” shall be displayed.

Foods Allowed for Repackaging

The General Rules for Food Production License Inspection and the Food Production License Classification Directory specifies categories of food that are and are not allowed for repackaging. For instance, foods such as foods for special medical purposes, infant formula, and health foods are prohibited from repackaging. Permissible food categories for repackaging are shown in the table below: