On June 27, 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 July 10, 2024. Since the release of GB 7718-2011 National Food Safety Standard General Standard for the Labeling of Prepackaged Foods (hereinafter referred to as the "current GB 7718") in 2011, many opinions have been solicited, and the Draft has collected and summarized relevant suggestions, and modified and improved according to market demand. Antion compared the draft with the current version, and analyzed and interpreted its main changes and impacts. Details are as follows:

01 Modified definition of prepackaged food and removed definition of the "principal display panel"

The Draft newly added "length identification" and measurement method, clearly classifies the food sold by measurement method into the prepackaged foods, and adds that the prepackaged food sold by measurement method should be marked with the words "measurement" or "measurement and weighing".

02 No more regulations on fonts, font sizes, etc.

The Draft no longer requires the use of standardized Chinese characters, no longer requires that the height of the text, symbol, and number of the mandatory content should not be less than 1.8mm, and no longer specifies the minimum height of the net content characters.

03 Newly added the definition of attribute name and standardized the requirements for attribute name

The Draft modified the "same size, same font color" to "no larger than the size of the attribute name and the font and color that are the same as the attribute name are marked".

04 Modified the labeling methods of food additives

The Draft requires that only "when the maximum surface area of the packaging or packaging container of the prepackaged food is not greater than 60 square centimeters", the functional category name and international code can be marked.

05 Newly added the labeling requirements for the classification of bacterial species

The Draft intends to stipulate that the bacterial species directly added in the production process, without inactivation or removal process, should indicate the specific name of the bacteria added. The draft for comments proposes to add new requirements, for strains that play a fermentation role in food, can be labeled as "fermentation bacterial species" or "microbial starter"; If the bacterial species have been inactivated or removed by filtration, they may not be marked, such as indicating the sterilization process of the product near the food attribute name or ingredient list, or indicating words such as "inactivated", "non-live bacteria", "bactericidal", "sterilized", etc., which can fully explain the inactivity of the bacteria.

06 Standardized the labeling requirements for the date

l The definition of prepackaged food is proposed to be expanded to include "foods that are pre-packaged or made in packaging materials or containers for sale by measurement". In addition, the current definition of prepackaged food covers pre-packaged foods and food pre-produced in packaging materials or containers with a unified labeling of quality or volume, and the quality or volume is within a certain limit range. The draft adds "length" as an additional unified measurement.

l The definition of shelf life is proposed to be simplified to exclude the additional requirements on the product's suitability for sale and requirements on the maintenance of specific qualities, either stated or implied, on the label within the shelf life.

l The definition of production date (manufacturing date) in the Draft is updated with the removal of "the date when it becomes the final sales unit" from the definition. The draft specifies the definition as: The date when the food becomes the final product, including the date of packaging and filling.

l The definition of the principal display panel is deleted.

l According to the Draft, for prepackaged food products with a shelf life of over 1 year and a maximum packaging surface area not exceeding 20 square centimeters, it is permissible to exclusively indicate the shelf life and its expiration date, which means the inclusion of the production date no longer mandatory. In addition, the "storage life after consumption" is added as an optional labeling item, which can guide consumers to consume food within a reasonable time schedule after purchase and avoid food waste.

07 Modified the sensitizers to the mandatory labeling information

In the current GB 7718, sensitizers are the recommended labeling information, the draft modified them to the mandatory labeling information, and besides the above eight mandatory labeling of sensitizers, increased the voluntary labeling of other potential sensitizers.

In addition, the Draft stipulated that for highly processed ingredients, protein components that may cause allergic reactions have been removed, can be exempted from the requirements for the labeling of sensitizers, and two special cases such as consumption of alcohol can be exempted from the labeling of sensitizers.

08 Newly added the labeling methods of food claims

The Draft introduces the principle requirements of food claims, which should accurately and truthfully describe the characteristics, properties, and features of the food, its ingredients, or components. In particular, if there are explicit provisions from Chinese laws, regulations, food safety standards, or relevant departments of the State Council, these provisions should be adhered to. In addition, it’s worth noting that the new Draft removes the previous draft's introduction of specific classifications and related labeling requirements for food claims.

09 Encourage the manufacturers to display food information through digital labels

Digital labels refer to food labels displayed on food packaging through information technology means like QR codes. In addition to adhering to the standard requirements for pre-packaged food labels, food enterprises are encouraged to display food label information through digital labels. Content displayed on digital labels should be clear, striking, and easy to read, and must not be altered.

The draft stipulates that if the matters that should be labeled on pre-packaged food are indicated through digital labels, the label information displayed on the packaging can be simplified according to relevant labeling regulations. In particular, if there are explicit provisions from Chinese laws, regulations, food safety standards, or food safety national standard departments of the State Council, these provisions should be followed.

10 Modified the content of exemptions from labeling

The Draft updates the exemptions for labeling. Wines and alcoholic beverages with an alcohol content of 10% or more can be exempted from showing the production date, provided the batch number is displayed. Similarly, these types of beverages can omit the shelf life and expiration date, as long as the production date is displayed.

For prepackaged foods where the maximum surface area of the packaging material or container is less than 20 square centimeters, only the food name, net content, production date or expiration date, shelf life, storage conditions, producer and/or operator's name and contact information, production license number, product standard code, and sequence number shall to be labeled. Other labeling items should be displayed on the sales container or provided in the form of attached instructions, digital labels, etc.

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.