On January 19, 2024, the National Health Commission issued the National Food Safety Standard General Standard for the Labeling of Prepackaged Foods (Draft for Comments) (hereinafter referred to as the "Draft"), and the deadline for comments is February 29, 2024. Since GB 7718 National Food Safety Standard General Standard for the Labeling of Prepackaged Foods (hereinafter referred to as the "current GB 7718") was issued in 2011, many opinions have been solicited, and the Draft has collected and summarized relevant suggestions, and been modified and improved according to market demand. Antion compared the Draft with the current version, and analyzed and interpreted its main changes and impacts as follows:

01 Removed the stipulation that the label content does not need to be marked on the outer package for those "easy to open"

The current GB 7718 standard stipulates that the complete label content does not need to be marked on the outer package when the prepackaged food is "easy to open", but the concept of "easy to open" is vague, and it is difficult to define whether the package is easy to open. This Draft removed the clause requirement to facilitate consumers to view the complete label information.

02 Newly added the definition of nature name and standardized the requirements for nature name

The current GB 7718 requires the nature name to be marked in a prominent position, and the Draft is revised to "the nature name of the food shall be marked with the same font, size and color in the prominent position of the food label"; in addition, the current GB 7718 stipulates that when there are words or terms that cause misunderstanding of food nature, the specific name of true nature of food shall be marked with the same size and the same font color in the same display panel near the name shown, and the Draft is amended to "When containing words or phrases that are likely to mislead or confuse the food nature, they shall be marked in the adjacent position of the same display panel using a font size not larger than that of the nature name and the same font and color as that of the nature name".

03 Prohibited expanding the labeling of composite ingredients combined with the original ingredients

The current GB 7718 and its Q&A stipulate that some of the original ingredients of composite ingredients are the same as other ingredients in the food, and each original ingredient in the composite ingredient can be indicated directly in the ingredients list. The Draft deleted this content, making it clear that composite ingredients must have their original ingredients arranged in parentheses in accordance with the decreasing order of the amount added (as mass), and cannot be expanded to combine with the original ingredients. This provision is conducive to the management of supervision departments.

04 Modified the labeling of food additives

The current GB 7718 stipulates that there are three labeling methods for food additives, one is to indicate the specific name at the same time; the second is to indicate the name of function category and international code at the same time; the third is to indicate the name of function category and the specific name at the same time. The Draft requires that only "when the maximum surface area of the package or packaging container of the prepackaged food is not greater than 60 square centimeters", the name of function category and international code can be indicated.

05 Newly added the labeling requirements for strain classification

The Draft intends to stipulate that the bacteria species directly added in the production process, without inactivation or removal process, should be indicated the specific name of the bacterial species added. For bacterial species that play a fermentation role in foods, it can be indicated as "fermentation bacterial species" or "microbial starter"; if the bacterial species has been inactivated or removed by filtration, it may not be indicated. The sterilization process of the product should be indicated near the food nature name or the ingredients list, or words such as "inactivated", "non-live bacteria" and "sterilized", which can fully explain the inactivity of the bacteria species, should be indicated. At present, the products with bacterial species added on the market are a mixed bag, and the supervision situation is also uneven. The new labeling content of the Draft has a more clear labeling regulation for inactivated bacterial species, which avoids the sale of non-live bacteria products posing as live bacteria products, and is conducive to purifying the market environment.

06 The ingredients or components referred to in the food name should be quantitatively indicated

The Draft listed four situations under which the labeling of the added amount or content can be exempted, such as the situation where the added amount or content specified in the national standard, only the taste is described and use the word "taste" for modification.

07 Prohibited the use of words such as "no added", "no using" and their synonyms

The Draft stipulated that words such as "no added", "no using" and their synonyms should not be used, which include words of the same nature such as "not adding", "zero addition", "no adding" and "not using".

08 Standardized the requirements for labeling of date

Only dates in year, month and day order are allowed. In the Draft, the requirement to mark the date in accordance with the order of day, month and year is deleted, and the production date may not be marked if the shelf life is 1 year or more. However, it should be noted that when the maximum surface area of the package or packaging container is not greater than 20 square centimeters, the shelf life can be marked in ways such as ×× months (or ×× days, or ×× weeks, or ×× years) under the premise of marking the production date. In addition, in order to avoid food waste, the manufacturers are encouraged to mark the shelf life of products, to effectively save resources, and meet the requirements of national policies.

09 The production date, the sub-packaging date and the expiration date of shelf life should be marked at the same time for sub-packaged foods

The current GB 7718 and related regulations stipulate that the sub-packaging products need to mark the sub-packaging date and shelf life. The new requirements for marking the production date in this Draft avoided the problem of incorrect marking of enterprises due to misunderstanding.

10 The sensitizers are modified to the mandatory labeling content

The sensitizers in the current GB 7718 are the recommended labeling content, and this Draft modified them to the mandatory labeling content.

11 Newly added the labeling of food claims

The labeling principles for general claims are detailed in Appendix E, to help enterprises have a basis for food claims and facilitate supervision by relevant departments. This labeling principle fills a gap in some of the current regulations, such as specifying that unprocessed substances (animals, plants, algae, bacteria, microorganisms, minerals, water of natural origin, etc.) can be claimed as natural, when they are used as ingredients and meet requirements a, b and c in E3.2. The rest of the food claims should be indicated in accordance with the regulations of the State Council and other relevant departments.

12 Improved the requirements for the labeling of imported food

In combination with the relevant documents issued by the General Administration of China Customs, it is clear that imported food should mark the Chinese registration number of the overseas manufacturer or the registration number approved by the competent authorities of the country or region where it is located. In addition, the Draft newly added the requirement for the country of origin (region), clarifying that if the country or region of canning or sub-packaging is inconsistent with the country of origin, the canning or sub-packaging country or region should be marked at the same time, and the source or production country or region name of raw materials or ingredients can also be marked at the same time. In addition, if the production date is not marked, it should be marked after projecting the relevant information such as the shelf life and the best before date indicated on the original package. If the shelf life is not less than 1 year, the production date may not be marked. This Draft listed the provisions on imported food separately, which is conducive to importing enterprises to fully understand the regulatory requirements, standardize the labeling of imported food, and relevant departments to supervise imported food.

13 Encourage manufacturers to display food information through digital labels

The Draft stipulated that the name, address, food implementation standard number, food production license number and recommended labeling content provided in food safety standards by digital labels can be exempted from marking on food labels. This provision is conducive to saving the label layout, adapting to the needs of social modernization and promoting the innovation and development of enterprises.

Through the interpretation of the above Draft, Antion hopes to help food-related enterprises and industry personnel better grasp the trend of standard changes and regulatory trends, and provide a reference for the next step.

Source: Antion

Note: This article is compiled by Antion. Please indicate the source for reprint.