China Consults on New Version of GB 7718 General Standard for the Labeling of Prepackaged Foods

On January 19, 2024, China National Health Commission (NHC) announced to seek public feedbacks for four national food safety standards, including the long-awaited new version of GB 7718 General Standard for the Labeling of Prepackaged Foods. Stakeholders may submit comments via the online system before February 29.

GB 7718 is the overarching regulation for the standardization of food labeling in China, which came into effect in 2011. Since then, China has released several new versions aiming to replace the 2011 version, including the first draft in 2018 and the second draft in 2019. Now after over a decade, China proposed another new draft version, mirroring that we’re one step closer to the final release of the new GB 7718 standard. Compared to the current valid version, the highlights of the new draft can be summarized as the followings:

1. The application scope of GB 7718 is amended. 

The new draft expands the scope of prepackaged food to "food that is prepackaged or sold by weighing in packaging materials and containers". Besides, the current definition of "prepackaged food" includes the net content and the number of units when the prepackaging contains certain units of prepackaged food, while the new draft adds "length" as a new dimension for the determination of prepackaged food.

2. Production date will not be a mandatory labeling item for products with shelf life over 1 year. 

As per the new draft, the order of date labeling only retains year, month, and day, while other labelling orders are canceled. In response to the Anti-Food Waste Law, it is stipulated that prepackaged food with a shelf life of 1 year or more may be exempted from the labeling of the production date. The retention period is added as an optional labeling item, which can guide consumers to consume food reasonably after purchase and avoid food waste.

In addition, the draft newly specifies the requirements for the date labeling of multi-packed food products and sub-packed products. Notably, if the original packaging of imported prepackaged food does not indicate the production date, the production date should be calculated based on the shelf life and the best consumption date indicated on the original packaging.

3. Composite ingredients must be declared explicitly in the ingredient list.

The draft clearly states that the composite ingredients must be separately indicated and cannot be combined with the original ingredients in labeling, which aims to better meet the consumer's right to know and provide convenience for regulation.

For example, in the current GB Standard, if a product uses "item A" as a composite ingredient, and part of the original ingredients of "item A" is identical to other ingredients directly used in the same product, then it is allowed to not indicate the name of the composite ingredient. Instead, the corresponding original ingredients can be combined for labeling after the calculation of their added contents. Once this draft is approved, this kind of labeling will be prohibited.

4. Imported food shall be labeled with countries/regions for both production and sub-packaging. 

For imported food manufactured and filled/sub-packed in different countries/regions, it is mandatory to indicate both countries/regions. Furthermore, the sources of their raw materials or ingredients may be indicated optionally.

For example, if a product is manufactured in country A and sub-packed in country B, then both country A and B should appear on its label.

5. Digital labels are promoted to carry part of labeling information. 

The draft encourages food enterprises to display food information through digital labels in compliance with the draft. Food enterprises can provide digital labels based on specific consumer needs, such as providing food information through video, voice recognition, and other methods on the basis of text content on the physical labels.

The draft also clarifies that when enterprises use digital labels to correctly indicate the names of food producers and operators (excluding those registered in accordance with the law and those who are responsible for product safety and quality), addresses, contact information, product standard codes, and execution standard numbers, the specific content can be exempted from being indicated on the physical label. Instead, the physical label should clearly indicate that relevant information can be found in digital labels. Food producers and operators registered in accordance with the law and those who are responsible for product safety and quality still need to be labeled physically.

6. Food claims are further standardized and improved. 

To standardize the use of food claims on food labels, the draft newly incorporates the basic requirements for food claims into the standards. According to the purpose and regulatory methods of food claims, food claims can be divided into four categories:

• General claims, mainly including claims of characteristics, claims of conditions, claims of comparison, claims of quantity (content), and sensory claims. This type of claim is about the general use of prepackaged food. Descriptions of food or ingredients other than mandatory labeling content should be indicated in accordance with the specified requirements. Detailed classification and usage conditions of various claims are listed in Appendix E to help food enterprises standardize the use of general claims.

• Claims of nutrition and the effects of nutritional components. For claims involving nutrition, strict adherence to GB 28050 and GB 13432 should be followed.

• Claim of health effects of food ingredients or ingredients, which should comply with the requirements of the Food Safety Law and other relevant regulations. In the absence of relevant regulations, food enterprises are not allowed to claim health effects without authorization.

• Claims of health food, which should be indicated in accordance with relevant regulations, such as Health Function Catalogue Allowed for Health Food Claims - Nutrient Supplements (2023) and Health Function Catalogue Allowed for Health Food Claims Non-Nutrient Supplement (2023).

To help stakeholders to better understand this important regulation draft, ChemLinked will present a webinar: Stay Ahead of China's Food Labeling Changes with New GB 7718 Draft.