Pending Regulatory Crackdown: China’s CFDA to Initiate a New Round of Food Label Regulatory Compliance Checks

From the 28 to the 29 of May 2014, CFDA held a training course specifically dealing with food labeling regulations in China. The food & drug supervision departments and food industry representatives from Shanghai, Hainan, Hebei and Hubei, etc. all participated in the training program. During the training course the head of Shanghai Food & Drug Supervision Department pointed out that the governance of food labeling was the food regulators priority task in 2014. Ms. Emily Xu, the food regulatory expert from REACH24H’s Food Compliance Service Team, also attended this training and got the lowdown on the coming regulatory crackdown and some tips to avoid a compliance crisis. With the pending regulatory crackdown the CFDA were keen to give a clear and concise regulatory walkthrough of the most important compliance requirements and overview the failings most commonly encountered during compliance verification and label check.

From an industry perspective the most interesting information was provided in the form of case study analysis. From these case studies the take home messages can be summarized as follows:

1. Food names cannot directly or by inference reflect the physical characteristics or source of a food e.g. it is not permitted to market a product called delicious chicken, with a picture of chicken wing labeled on the package

2. All pre-package foods should have a comprehensive ingredients list

3. Usage of Units not permitted under Chinese standards

4. Ambiguity in English / Chinese translation

5. The marketing of specific food additives on the label is not permitted under Chinese regulations

6. Ambiguous or confusing dates of manufacture or expiration

7. GMO declaration is required only if the ingredients in your product belong to the GMO inventory

8. The required nutrients, including energy, protein, fat, carbohydrate and sodium, must be presented in nutrition facts. The other nutrients are optional.

9. The amount of trans-fat acid must be labeled if you have hydrogenated oil as ingredient

ChemLinked and Food Compliance Service Team will co-host an exclusive webinar on food labeling in July, during which our food regulatory specialist would like to explain detailed requirements for labels of imported food products based on related Chinese national standards and will share a number of examples of unqualized labels for your better understanding and give you practical compliance advice.