Recently, departments such as the National Health Commission and the State Administration for Market Regulation jointly issued the Announcement on the Issuance of 50 National Food Safety Standards including GB 7718-2025 National Food Safety Standard General Standard for the Labeling of Prepackaged Foods and 9 Amended Documents (No. 2 of 2025). To ensure a smooth transition between the old and new standards, a certain transition period has been set in the policy. This is to facilitate food production enterprises to get familiar with the standards and make corresponding adjustments to their products.

PART. 1 Design Logic and Real Considerations of New Standards

For domestic foods, according to the Regulations for the Implementation of the Food Safety Law of the People's Republic of China and the FAQs on National Food Safety Standards promulgated by the China National Center for Food Safety Risk Assessment, after the announcement of food safety standards, food producers and operators may implement them before the implementation date specified in the food safety standards and publicly disclose the early implementation situation. After the implementation date, food producers and operators, food safety regulatory agencies, and inspection agencies should follow the new standards. Foods produced before the implementation date can continue to be sold within their shelf-life. This regulation not only avoids the waste of resources caused by large-scale product destruction but also provides a window for domestic enterprises to upgrade their technologies.

For imported food, according to the Announcement on the Implementation Time of New Standards for Imported Food (No. 41 of 2012) promulgated in 2012, as of the implementation date of the newly - issued national food safety standards, the inspection application date should be taken as the criterion for all imported food. This regulation stems from the complexity of the imported food supply chain. For example, cross-border transportation has a long cycle and risks spread quickly. Taking the inspection application date as the boundary can achieve "source control". However, considering the long-distance transportation and customs clearance time required for imported food, on December 30, 2022, the General Administration of Customs of China issued the Announcement on the Inspection Related to the Requirements for Imported Infant and Young Children Formula Food, Processed Cheese and Other Products in Compliance with National Food Safety Standards (Announcement No. 136), clarifying the relevant supervision regulations for infant formula, older infants formula, young children formula, processed cheese and cheese products, and concentrated dairy products. Products of the above mentioned food categories that are produced and imported before the implementation date of the new national standard and meet the provisions of the original national standard can continue to be imported and sold within their shelf-life.

It should be noted that, except as otherwise specified in special announcements, all other imported foods should meet the requirements of Announcement No. 41 in 2012. Based on the date of inspection application, all of them should be inspected in accordance with the new standards. Only products that pass the inspection in line with the standards are permitted to be imported.

PART. 2 Differentiation of Enterprises' Response Strategies under New Standards

Domestic enterprises need to play a combination of "inventory digestion" and "technological upgrading". On the one hand, establish a dynamic inventory management system and accelerate the circulation of products under the old standards through promotional activities, channel expansion to lower-level markets, etc. On the other hand, force changes at the production end. For example, speed up the learning of changes in the new standards, increase training on new regulations, select third-party professional institutions or professional technicians to conduct a compliance evaluation of the food labels they provide, and further review and approve the food labels.

Import enterprises, on the other hand, face the compliance pressure of "racing against time". Since the inspection application requires a test report that complies with the new standards, enterprises need to restructure the supply chain rhythm. For instance, they can shorten the production cycle of overseas factories, add pre-inspection warehouses in bonded areas, and compress the inspection application time to ensure the smooth customs clearance of products during the transition period. Moreover, the adjustment of label design requires advance planning. Enterprises should start the packaging modification in advance to avoid the risk of goods being returned due to non-compliant labels.

PART. 3 Conclusion

For enterprises, the transition period is not only a stress-testing period but also a window of opportunity for transformation. With the full implementation of the new regulations, food safety governance in China will enter a new stage featuring "precise supervision, industrial coordination and public participation", building the most stringent standard defense line for "Healthy China".

Source: Antion

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