A compliant Chinese label is a critical step in successfully exporting products to China. The release of GAC's monthly blacklist of imported food shows many exporters and their agents still make simple but financially costly mistakes when designing China compliance Chinese language labels. This foodpedia article details important regulations and standards involved in imported food labeling in China.
1. General rules and regulations for pre-packaged food
former AQSIQ Notice 27 of 2012 Administrative Provisions on Supervision and Administration of Pre-packaged Imported and Exported Food Labeling
The Provisions were released on 5 Mar 2012 and became effective on 1 Jun 2012. It marked the beginning of a new period of China’s imported food labeling management characterized by stricter regulation and more stringent enforcement. The system of labeling inspection along with the goods was also established.
former AQSIQ Order 102 of 2007 Provisions on the Administration of Food Labeling
The Provisions took effect on 1 Sep 2008 in order to standardize food labeling and enhance relevant supervision. The provisions elaborate on the contents that shall be indicated on food labels and correct labeling procedures.
former AQSIQ Order 123 of 2009 Decision on the Revision of the Provisions on the Administration of Food Labeling. The revision to the Provisions became effective on 22 Oct 2009.
This standard, implemented on 20 Apr 2012, applies to the labeling of prepackaged foods available directly and indirectly to consumers.
This Standard applies to the description and explanation of nutrition information in nutrition labels of prepackaged foods, but not applicable to nutrition labeling of health food and prepackaged foods for special dietary use.
2. Important standards for prepackaged foods subject to special requirements
3. Label filing for imported prepackaged foods
Previously prepackaged food imported for the first time shall apply for label filing before exportation. However, label filing for prepackaged imported food was no longer be required starting on Oct.1, 2019. Label inspection for foods imported for the first time will be regarded as a normal sampling inspection item for customs release. If a prepackaged food product is selected to undergo on-site inspection or laboratory testing, the importer is required to provide the product qualification certificate, origin label and its translation, Chinese label sample and other supporting documents.
4. Documentation requirements for nutritional information labeling
(This part is contributed by Cheng Yu, experienced food regulatory expert at REACH24H Consulting Group)
If nutrition information is labeled, relevant testing reports should be provided:
For conventional food: The labeling of nutrition information for conventional food should comply with GB 28050-2011, mandatory nutrition information includes energy, protein, fat, carbohydrate and sodium. Certain nutritional components which are added according to GB 14880-2012 or notices of NHC (or former NHFPC/MOH) should be properly labeled. All the nutritional components present on the label should be verified by testing.
For special dietary food: The labeling of nutritional information for special dietary food such as infant formula should comply with GB 13432-2013. Mandatory nutrition information includes energy, protein, fat, carbohydrate, sodium and essential components stipulated in the corresponding product standards. Certain nutritional components which are added according to corresponding product standards, GB 14880-2012 or notices of NHC (or former NHFPC/MOH) should be properly labeled. All the nutritional components present on the label should receive nutrition tests.
Testing method and institutions
Testing method: Nutritional testing should use the testing methods stipulated in national standards or those which are equivalent to national standards. In cases where there is no referable national testing standard, the standards of an international organization or authoritative scientific literature could be referenced.
Testing institute: Manufacturers could either conduct self-analysis and testing of nutritional components, or authorize a qualified testing institution.