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A Comparative Analysis of Labeling Requirements in Taiwan and Chinese Mainland

During the REACH24H’s China regulatory annual conference (CRAC), the different labeling requirements in Taiwan and Chinese mainland were compared in many aspects.

Takehome:

During the REACH24H’s China regulatory annual conference (CRAC), the different labeling requirements in Taiwan and Chinese mainland were compared in many aspects.

Mandatory labeling information in Taiwan:

  • Product name

  • Ingredients

  • Weight

  • Manufacturing date/shelf life

  • Country of origin

  • Importer and its contact information

  • Allergen information

In China mainland, the labeling of allergen information is optional.

Food additive labeling:

Taiwan area:

In Taiwan, all food additives should be labeled. For sweeteners, preservatives and antioxidants, both the food additive name (generic name) and its function should be labeled (excluding flavorings). The labeling of functions of other food additives is exempted.

Chinese mainland:

In Chinese mainland, labeling requirements for prepackaged foods are specified in “GB7718 General Standard for the Labeling of Prepackaged Foods”, which can be divided into three types:

1. Only the food additive name is labeled;

2. Both the food additive name and its function are labeled (the labeling of food additive function is optional);

3. Food additive function and relevant INS number are labeled.

GMO labeling

Taiwan area:

The management of GMO foods focuses on raw material management in Taiwan. All GMO raw materials used in foods must be labeled. If the final products do not contain GMO ingredients but are processed using GMO ingredients, it should be labeled as “this product contains GMO ingredients in its raw materials but not in its final products”.

Chinese mainland:

The GMO labeling requirements in Chinese mainland are similar to those in Taiwan area. Please see “Regulatory Environment for GMO Foods in China” for details.

Labeling of country (district) of origin

Taiwan area:

In Taiwan, for products with raw materials imported from different countries (districts), all these countries (districts) should be indicated on the label. Only when there is substantial change of the product (e.g. one product is reprocessed into another different product in Taiwan), can the country (district) of origin be changed to Taiwan. If one product is only sub-packaged in Taiwan, the country (district) of origin of the original producing country (district) should still be indicated on the label.

Chinese mainland:

In Chinese mainland, the country (district) of origin is the place where the final sale unit is formed, i.e. if imported foods are sub-packaged in China, the country (district) of origin should be changed to Chinese mainland.

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