SAMR Issues Health Food Disclaimer and Labelling Guidelines

The disclaimer 'health foods are not medicines and cannot replace medicine to treat diseases' shall be marked in an obvious area on health food labels. If a package contains more than one piece of health food, then the production and expiration date of each piece shall be marked on the label/package. The complaint service phone number and service hours shall be marked on the label of the health food, and manufacturers shall ensure they could receive/handle calls during the hours specified.

On Aug. 20th, SAMR released Health Food Labelling Warning Language Guide ^[1], the formulation of this guide is based on China's Food Safety Law, Administrative Measures for Registration and Filing of Health Foods, etc., and it will come into force on Jan. 1st, 2020.

For better understanding, the below two pictures show the differences between the labels before and after implementation.

*Note: For a high-resolution image, please click picture 2.

The changes in labels mainly focus on the following four aspects:

1. The warning language

Health food labels shall use appropriate disclaimers and warnings. Warnings and disclaimers should appear on the minimum sales packaging (containers) of the main package, the area should not be less than 20% of its surface. There shall be obvious colour difference between the text and the background of the warnings. Warnings shall be printed in bold type and include the following:

Health foods are not medicines and cannot replace medicine to treat diseases.

When the surface area of the main display page is greater than or equal to 100cm², then the font height shall not be less than 6.0mm. When the surface area of the main display page is less than 100cm², the minimum height of the warning words varies in proportion to the above provisions.

2. Production & expiration date

The production date and shelf life shall be clearly marked on the outside of the minimum sales package (container). In addition, the following requirements for the font and format of labelling should be followed:

The date shall be marked in sharp contrast with the background colour and shall be easy to recognize. Date marks are not allowed to be affixed, reprinted or altered.
The production date of a single health food with multi-layer packaging shall be the completion time of the inner packaging, which directly contact the food.
When the same pre-package contains more than one piece of food, the date of production and shelf life of each piece of food shall be marked on the package.
Mark the date in order of year, month and day.
The shelf life shall be marked as 'shelf life to XXXX-XX- XX'.

3. Complaint service telephone number

Health food labels shall include a complaint service telephone number, service hours etc. Health food production and operation enterprises shall ensure that they can receive and handle consumer complaints and reports within the promised service period, and record and keep relevant service information for at least 2 years.

4. Consumption notice

In addition, operators should also mark consumption tips such as 'health foods are not medicines and cannot replace medicine to treat diseases' in prominent positions while selling on e-commerce platforms or other places.