2020 promises to be a very important year for food regulatory in China – at least for food labeling.
We saw that in November new draft of food labeling administration measures was issued, and indeed on the very last day of 2019 we saw the publication of the new draft GB 7718 – the cornerstone of food labeling regulation in China.
Here a brief summary of some of the most relevant provisions.
Ingredients containing allergens – as widely announced - become a mandatory item. In particular, the mandatory allergenic labeling concerns the following ingredients:
- gluten-containing cereals and their products (such as wheat, rye, barley, oats, spelt wheat or their hybrids);
- crustaceans and their products (such as shrimp, lobster, crab);
- fish and its products;
- eggs and their products;
- peanuts and their products;
- soy and its products;
- milk and dairy products (including lactose);
- nuts and nuts products.
Beside those, voluntary labeling can be done for other ingredients containing possible allergens.
2. Quantitative labeling of Ingredient
Some provisions clarify when an ingredient is considered emphasized (and therefore its QUID necessary).
Ingredients mentioned on food label or in food product instruction slip is not considered emphasized in the following cases:
- ingredient or component mentioned in allergy alert, other warnings, or reminders;
- ingredient or component mentioned only in use instruction or product pairing;
- only used for description of sensory attributes such as product physical specs, flavor, taste, mouth feeling, technology etc.
Ingredients or component mentioned in food product name are considered emphasized, except in the following cases:
- food product name is identical to (or is equivalent to) those provided by a National, Industry or local standard, and its equivalent name, same meaning or substantially equivalent;
- ingredient or component content already regulated in National, Industry or local standard;
- ingredient or component used only to describe sensory attributes such as product physical specs, flavor, taste, mouth feeling, technology and so on. In such case the word "flavored", "flavor" and so on shall also be used.
Graphics or picture printed on package, to illustrate taste, flavor and so on, if related to a food or food ingredient, does not constitute emphasis. However, photograph of raw material or food is not allowed to be used in case the food product only contains the related essences.
When using "no" or "without", the content of such ingredient or component shall be 0.
In general, terms such as "without addition of", "without use of", and synonyms are not allowed.
Negative claims such as "without", "does not contain" and other synonyms are not allowed for:
- food additives;
- substance not allowed to be added according to relevant regulation or standard;
- substance ought not to exist in food product.
"Non-GMO" claim is forbidden.
3. Other changes
Country of origin
When two or more countries are involved in the production of food products, the country where substantial changes are finally completed is the country of origin.
It is allowed to also indicate the country/region of origin of the raw materials or ingredients.
Minimum font for mandatory labeling items is 1.8mm for food products with maximum surface area larger than 60cm2 (until now, such requirement applied only for food products with largest package larger than 35 cm2).
Simplified ingredient labeling
Starches and bacteria are added to the list of ingredients whose declaration can be simplified in the ingredient list.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.