[Updated] China Proposes New Amendment to GB Standard for Restricting Overpackaging of Food, Tea and Baby Foods Involved

Background

In 2021, China unveiled the GB 23350-2021 Requirements of Restricting Excessive Package–Foods and Cosmetics, which will be fully enforced on September 1, 2023. Compared to the current GB 23350-2009, the new version stipulates more detailed packaging requirements for 31 categories of foods and 16 categories of cosmetics. Click ChemLinked News for more details.
In 2022, China proposed and approved the First Amendment Sheet to GB 23350-2021, with effect from August 15, 2022. The amendment introduces more stringent packaging requirements for two Chinese traditional festival foods, namely, mooncakes and zongzi (rice dumplings). Click ChemLinked News for more details.

Latest Update:

On January 9, 2024, China MIIT released another draft of the second amendment to GB 23350-2021. Comments can be sent to [email protected] before January 15.

Compared to the previous draft, the new draft modified the k value of milk powder and modified milk powder products from 3.0 to 6.0. Besides, it specifies the k value of dried bean products as 12.0. The k value of blended bean products with 10 or more individual items inside the packaging is 11.0.

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Update:

On November 23, 2023, China MIIT released the second draft of the second amendment to GB 23350-2021. Comments can be sent to [email protected] before November 29.

Compared to the first draft, major updates are as follows:

Total mass of tea: the new draft specifies that the total mass of tea products should not exceed "8" times the mass of the tea in the contents, instead of "6" times specified in the first draft.
Necessary spatial coefficient of commodity: the new draft adds the notes as "for products using freeze-drying process, k = 18.0; Products using the puffing process, k= 20.0". Besides, several commodities are subject to new k values, including dried seaweed products, fish floss and shrimp floss products, instant dried sea cucumber products, nuts products, as well as baby foods. The draft also further details the k value requirements for tea products.
Calculation method for commodity packaging mass: the draft adds the calculation method for the mass of commodity packaging as a new section in 5.7.

Except for the changes regarding necessary spatial coefficient of commodity, which shall take effect immediately after the draft is officially published as a new regulation, other updates and revisions will be implemented with a 12-month grace period. Products produced before the implementation date that comply with GB 23350-2021 can be sold until the end of their shelf life. In addition, products that have been put on the market before December 31, 2021 and are within the shelf life or are exempt from labeling the shelf life can continue to be sold.

On August 18, 2023, China Ministry of Industry and Information Technology (MIIT) released the draft of the second amendment to GB 23350-2021 Requirements of Restricting Excessive Package–Foods and Cosmetics. This draft mainly introduces new packaging requirements for tea products and complementary baby food products. Any comments can be submitted to [email protected] before September 17. Details are as follows:

New Revisions Revealed by the Draft

1. Package layers of tea

This draft changes the requirements for the number of package layers of tea from no more than four layers to no more than three layers, as nowadays tea products are heavily overpackaged.

Standard	Number of package layers
GB 23350-2021	Package layers of grain and its processed products: ≤ 3 layers; Package layers of other commodities: ≤ 4 layers.
First Amendment Sheet to GB 23350-2021	Package layers of grain and its processed products, mooncakes and zongzi: ≤ 3 layers; Package layers of other commodities ≤ 4 layers.
Draft of Second Amendment Sheet to GB 23350-2021	Package layers of grain and its processed products, mooncakes, zongzi and tea: ≤ 3 layers; Package layers of other commodities: ≤ 4 layers.

2. Package cost of tea

New requirements for package cost of tea are specified, that is, the cost of all packages (excluding the package directly in contact with the contents) of tea with sales price over 200 RMB shall not exceed 15% of product selling price. Besides, precious metals and mahogany should not be used in the packaging of tea, in addition to mooncakes and zongzi stipulated by the First Amendment Sheet to GB 23350-2021.

Standard	Requirements for package cost
GB 23350-2021	Cost of all packages (excluding the package directly in contact with the contents): ≤ 20% of the product selling price.
First Amendment Sheet to GB 23350-2021	Cost of all packages (excluding the package directly in contact with the contents): ≤ 20% of the product selling price; Cost of all packages of mooncakes and zongzi with sales price over 100 RMB: ≤ 15% of the product selling price; Precious metals and mahogany should not be used in the packaging of mooncakes and zongzi.
Draft of Second Amendment Sheet to GB 23350-2021	Cost of all packages (excluding the package directly in contact with the contents): ≤ 20% of the product selling price; Cost of all packages of mooncakes and zongzi with sales price over 100 RMB: ≤ 15% of the product selling price; Cost of all packages of tea with sales price over 200 RMB: ≤ 15% of the product selling price; Precious metals and mahogany should not be used in the packaging of mooncakes, zongzi and tea.

3. Total mass of tea

This draft adds a new section, 4.5 Total mass of commodities, according to which the total mass of tea products should not exceed 6 times the mass of the tea in the contents.

4. Necessary spatial coefficient of tea and complementary baby foods

As per GB 23350-2021, interspace ratio is largely determined by the necessary spatial coefficient of commodity (expressed as K value). The smaller the K value, the larger the interspace ratio. Compared to the current standard, the draft sets more detailed K values for tea products and complementary baby foods.

Standard	Requirements for interspace ratio
GB 23350-2021	Tea and tea products: K=13.0
First Amendment Sheet to GB 23350-2021	Tea and tea products: K=13.0
Draft of Second Amendment Sheet to GB 23350-2021	Tea and tea products (compressed tea): K=9.0 Tea and tea products (loose tea and tea related products): K=13.0 Certain types of tea include HouKui, Maofeng, ShouMei, Bai MuDan, leaf and flower substitute teas: K=20.0 Raw cereal-based complementary foods for infants and young children: K=4.5 Cookies and other cereal-based complementary foods for infants and young children: K=10.0 Rice cake for infants and young children: K=20.0

5. Implementation requirements

All revisions will be provided with a 12-month grace period, except for the new K value for certain types of tea and complementary baby foods, which will be enforced immediately after the amendment is officially published. Within the grace period, commodities produced as per the original GB 23350-2021 can still be sold until their expirations.

In addition, for commodities already circulated in the market before the publish date of GB 23350-2021 (August 10, 2021), they can continue to be circulated as long as they are within the shelf life or they are exempt from labeling shelf life.