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China CIQ Officials Further Clarify Labeling Requirements of Imported Infant Formula

Every month there is a startlingly high volume of imported infant formula and other products which fail CIQ label inspection and sample testing at port. Despite the huge financial losses associated with CIQ compliance check failures at port there are still far too many companies making fundamental mistakes. The biggest disappointment is that the vast majority of these issues could be easily avoided with the correct compliance advice or usage of a reliable agent to undertake compliance work.

Ms. Yao Lu, the food regulatory affairs expert from the Food Compliance Service Team of REACH24H, recently attended a government training program conducted by Shanghai CIQ, CCIC and Shanghai Inspection Corporation which clarified many of the major mistakes that occur during labeling and misapplication of the requirements outlined in national standards of nutritional enhancers used in infant formula. The training focused on some of the nuances associated with relevant national standards and the specific requirements needed to comply with these regulations. The take-home messages from this conference which industry should follow are:

  1. AQSIQ issued the Announcement No.133 on September 23, 2013. It stipulated that infant formula from unregistered overseas manufacturers is not permitted to enter China. For registered importers Chinese labels should be printed on minimum sales packages before entering the country.

  2. Director Xie from Yangshan CIQ explained that not all ingredients listed in Table C.1 of GB 14880 can be used in infant formula. For infant formula the gold standard reference is the infant formula product standard (GB 10765 or GB 10767). Where an infant formula ingredient appears both in GB14880 and the infant formula product standard then the infant formula product standard takes precedence. If there is no description of an ingredient in the product standard, then it cannot be added. For label review purposes it is also preferable to list the specific compound (e.g. magnesium content expressed as Magnesium sulphate content) sources of all ingredients.

  3. Marketing the concentration of a specific ingredient (content claim) and functional claims of essential ingredients in infant formula for 0-6 month-old infants is forbidden

  4. Ingredients listed in Table 2, 3 and 4 of GB 10765 are essential.

  5. When GB14880 does not specify a requirement for minimum value or lowest permitted level of an ingredient in the product standard, evidence should be presented that the ingredient can be claimed in foods for special dietary uses in other countries and/or verified by international organizations  (it will still be rejected unless enterprises provide a formal document from NHFPC verifying this).

  6. If the infant formula is imported for the first time, enterprises should submit an independent full testing report, which must be issued by an authorized third-party testing organization. Officials from Shanghai CIQ indicated that if the tests conducted by the Chinese Academy of Inspection and Quarantine, one of the accredited labs in China, the testing report will be highly recognized by Shanghai CIQ inspectors so the inspection process of the infant formula products at Shanghai port would be greatly expedited.

  7. From April 1, 2014, warehouses that haven’t been listed in “certified warehouse list for imported infant foods” announced by Shanghai CIQ will not be allowed to store products without a qualified inspection and quarantine certificate. 

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