On December 5, 2017, China CFDA released an announcement detailing conditions that require a label change application. Generally speaking, if there are changes relate to product formula within the registration validity period, manufacturers are obliged to apply for label change to CFDA; otherwise, they can update the label themselves based on relevant regulations.
Cases requiring application | Cases not requiring application |
changes in: | changes in: |
Product name Enterprise name, production address Ingredients list, nutrition facts Allowable content claim Registered trademark Others involving consistency with formula registration
| production date, expiration date, usage method, dosage, storage condition, notice, product tracing, alert, after-sales service claims of raw materials’ origin, including lactogenesis, raw milk powder content place (excluding trademark and product name) on principal display panel; content place on non-principal display panel Trademark holders, agent, production license No. (registration No. of overseas manufacturer) , contact information (QR code, telephone, etc.) color of certification mark, label product specification (net content) Others not involving consistency with formula registration
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Manufacturers shall follow the procedures specified in article 26 of Administrative Measures for Registration of Infant and Young Children Milk Powder Formula Recipes to apply for label changes.