China Consults on GB 7718 General Standard for the Labeling of Prepackaged Foods, Along With Other 13 GB Food Standards

On June 27, 2024, National Health Commission (NHC) announced to seek public comments on 14 national food safety standards. These include four product standards, five food additive standards, three operation and hygiene criteria, one testing standard, and notably, the GB 7718 General Standard for the Labeling of Prepackaged Foods. Stakeholders are invited to submit their feedback online for the GB 7718 until July 10, 2024. For the remaining standards, comments are encouraged up until August 26, 2024.

Now the GB 7718 and Administrative Measures for Supervision of Food Labeling are concurrently open to the public for comments. They will work in coordination to effectively manage food labeling. For the interpretation of the draft of the Measures, please refer to the following article:

• China Unveils the Draft of Food Labeling Supervision Administrative Measures

List of the Proposed GB Standards

 Key Changes in Draft GB 7718

The current version of GB 7718, the cornerstone regulation for standardizing food labeling in China, came into effect in 2011. Afterwards, China has released several drafts aiming to replace the current version, including the first draft in 2018, the second draft in 2019, and the third draft in early 2024. Now China puts forth a new draft version, which represents a significant update from the existing GB 7718 and its three prior versions. The key changes introduced in this new draft can be summarized as follows:

Specific labeling requirements such as font size and producer information are deleted from GB 7718.

Specific labeling requirements such as font size, net content, and producer information for pre-packaged food labels will no longer be covered in GB 7718, and will be separately stipulated by the Administrative Measures for Supervision of Food Labeling. NHC and the State Administration for Market Regulation (SAMR) have agreed that GB 7718 and the Administrative Measures for Supervision of Food Labeling should work in coordination with each other to effectively manage food labeling. The draft of the Administrative Measures was released on June 28, 2024.

Definitions of prepackaged food, shelf life and production date are amended.

• The definition of prepackaged food is proposed to be expanded to include “foods that are pre-packaged or made in packaging materials or containers for sale by measurement”. In addition, the current definition of prepackaged food covers pre-packaged foods and food pre-produced in packaging materials or containers with a unified labeling of quality or volume, and the quality or volume is within a certain limit range. The draft adds “length” as an additional unified measurement.

• The definition of shelf life is proposed to be simplified to exclude the additional requirements on the product's suitability for sale and requirements on the maintenance of specific qualities, either stated or implied, on the label within the shelf life.

• The definition of production date (manufacturing date) in the draft is updated with the removal of “the date when it becomes the final sales unit” from the definition. The draft specifies the definition as: The date when the food becomes the final product, including the date of packaging and filling.

• The definition of the principal display panel is deleted.

Production date will not be mandatory for products with shelf life over 1 year.

According to the new draft, for pre-packaged food products with a shelf life of over 1 year and a maximum packaging surface area not exceeding 20cm², it is permissible to exclusively indicate the shelf life and its expiration date, which means the inclusion of the production date no longer mandatory. In addition, the “storage life after consumption” is added as an optional labeling item, which can guide consumers to consume food within a reasonable time schedule after purchase and avoid food waste.

Digital labels must not be altered.

Digital labels refer to food labels displayed on food packaging through information technology means like QR codes. In addition to adhering to the standard requirements for pre-packaged food labels, food enterprises are encouraged to display food label information through digital labels. Content displayed on digital labels should be clear, striking, and easy to read, and must not be altered.

The draft stipulates that if the matters that should be labeled on pre-packaged food are indicated through digital labels, the label information displayed on the packaging can be simplified according to relevant labeling regulations. In particular, if there are explicit provisions from Chinese laws, regulations, food safety standards, or food safety national standard departments of the State Council, these provisions should be followed.

The food claim requirements are revised.

The draft introduces the principle requirements of food claims, which should accurately and truthfully describe the characteristics, properties, and features of the food, its ingredients, or components. In particular, if there are explicit provisions from Chinese laws, regulations, food safety standards, or relevant departments of the State Council, these provisions should be adhered to. In addition, it's worth noting that the new draft removes the previous draft's introduction of specific classifications and related labeling requirements for food claims.

Wines and alcoholic beverages can be exempted from showing the production date in specific situation.

The draft updates the exemptions for labeling. Wines and alcoholic beverages with an alcohol content of 10% or more can be exempted from showing the production date, provided the batch number is displayed. Similarly, these types of beverages can omit the shelf life and expiration date, as long as the production date is displayed.

For pre-packaged food products where the maximum surface area of the packaging material or container is less than 20 cm², only the food name, net content, production date or expiration date, shelf life, storage conditions, producer and/or operator's name and contact information, production license number, product standard code, and sequence number shall to be labeled. Other labeling items should be displayed on the sales container or provided in the form of attached instructions, digital labels, etc.