On June 28, 2024, the State Administration for Market Regulation issued the Measures for Supervision and Administration of Food Label (Draft for Comments) (hereinafter referred to as the "Draft"), and the deadline for comments is July 27, 2024. The Draft specified in details the font, size, production date, net content and other contents not listed in the draft of GB 7718, and supplemented the requirements for the label of special food, the labeling requirements for food sales and other contents. Antion compared the Draft with the current Provisions on the Management of Food Labeling (hereinafter referred to as the "Current Provisions"), and analyzed and interpreted its main changes and impacts. Details are as follows:
01 Newly added the labeling requirements for font and size
The text, symbols, numbers, and pattern colors on the labels of prepackaged food should be in stark contrast with the background color to ensure clear reading. The font size of the labeling content should be not less than 1.8 mm in height, and the ratio of the height to the width of the text should not be more than 3. When the maximum surface area of prepackaged food’s packaging exceeds 150 square centimeters, the height of the text and numbers should not be less than 2 mm. When the maximum surface area of the packaging or container exceeds 400 square centimeters, the height of the text and numbers outside the nutrition information should not be less than 2.5 mm.
02 Changed the requirement for production date and shelf life expiration date
The Draft requires that the production date and expiry date must be prominently marked on the main display panel of the smallest sales unit of prepackaged foods in the format of year, month, and day. In terms of the location, if the smallest sales package has multiple layers, the information should be marked on the outermost packaging. In terms of the color, the information must be clearly marked in a designated area in black text on a white background or with a similar contrasting color scheme. In terms of the font size, for prepackaged foods with a maximum surface area greater than 20 square centimeters, the height of the text and numbers should be no less than 3 mm; for other prepackaged foods, the height of the text and numbers should be no less than 2 mm.
03 Improved the requirement for food name
For food made from two or more main ingredients that combine to a uniform and indistinguishable appearance, the name of the food must not reflect only one of the ingredients.
For food made from plant-based ingredients that simulate animal-based food, the name should be prefixed with terms such as "Imitation," "Vegan," or "Plant-based", and must indicate the true nature of the food's properties.
For food that contains only food flavorings to mimic the flavor of a specific ingredient, the name of the food must not mislead consumers into an impression that the actual ingredient is used.
04 Made it clear that food should not be claimed on minors
The Draft stipulates that the labeling content on prepackaged food products must not contain words or images to explicitly, implicitly, or emphatically suggest that the product is suitable for minors, unless otherwise specified in existing laws, regulations, rules, national food safety standards, or industry standards.
05 Made the definition of production date clear
The Draft specified in details that "the production date of the products with single-layer package is the date of the completion of the packaging process, which of those with multi-layer packaging is the date of the completion of the packaging process in direct contact with the food, and which of those required to sterilization, fermentation and other processes after the completion of the package is the completion date of the corresponding process".
06 Set a chapter to stipulate special requirements for the label of special food
In a separate chapter, the Draft sets forth specific labeling requirements for infant formula, health food and food for special medical purpose. Labels and instructions for these special foods must comply with relevant laws, regulations, rules, national food safety standards, as well as product registration and filing requirements. Any content that involves registration certificates or filing documents must be consistent with the labels and instructions for special foods as published by food safety super vision departments at the provincial level or above.
07 Optimize the penalty provisions on food label violation
Based on the severity of the violations, different penalties for food label violations will be applied. These range from orders to rectify, fines (between 5,000 to 30,000 RMB, between 10,000 to 50,000 RMB, or 5 to 10 times the value of the goods), orders to cease production and business operations, to the revocation of licenses.
08 Conclusion
If the Measures for Supervision and Administration of Food Label (hereinafter referred to as the Measures) is officially released, it is expected to give a two-year implementation transition period. The Measures will become an important regulatory requirement of food labeling. At the same time, food production and operation enterprises also need to combine GB 7718 and other regulations and standards to regulate food label.
Through the interpretation of the above Draft, Antion hopes to help food-related enterprises and industry related personnel better grasp the trend of standard changes and regulatory trends, and provide a reference for the next step.
Source: Antion and Chemlinked
Note: This article is compiled by Antion. Please indicate the source for reprint.