China Implements New Food Additive Regulation with Comprehensive Governance Plan

China has announced new food additive regulations and a “comprehensive” plan to govern food additives, according to a recent release. On May 6, 2025, China’s State Council Food Safety Commission and key ministries unveiled the “Comprehensive Governance Plan for the Abuse of Food Additives,” marking a significant tightening of oversight across the entire supply chain. The new measures - from farm-level sourcing and customs import checks to production, sales, and end-use supervision - reinforce the Food Safety Law and demand heightened compliance, transparency, and product integrity from both domestic and international manufacturers.

Main Content of the Plan

Source Governance: Strict Control from Farm to Import

Production of Edible Agricultural Products

Regulatory Measures: The Ministry of Agriculture and Rural Affairs will crack down on the use of banned agricultural inputs in the production of edible agricultural products. By establishing a special monitoring mechanism for preservative and freshness-preserving pesticides, the quality and safety of agricultural products will be ensured before they enter the market.
Impact on International Manufacturers: For international manufacturers engaged in the processing of agricultural products or relying on imported agricultural raw materials, this means that they need to conduct stricter reviews of supplier qualifications to ensure compliance with China's regulatory requirements. At the same time, companies should pay attention to China's list of banned agricultural inputs to avoid product non-compliance due to raw material issues.

Import Link

Regulatory Measures: The General Administration of Customs will increase efforts to combat the undeclared import of food additives. The "positive list" system will be strictly implemented to prohibit the import of unapproved additives, and a "circuit breaker mechanism" for the disposal of substandard food will be established.
Impact on International Manufacturers: When exporting food additives to China, international manufacturers must ensure that their products fully comply with China's regulatory requirements and declare all relevant information truthfully. Any violations may result in products being denied entry or even severe penalties.

Comprehensive Supervision of Production, Sales, and Use

Production Link

Regulatory Measures: The State Administration for Market Regulation has formulated a unified national review detail for food additive production licensing, covering 62 review standards from factory facilities to formula and process. At the same time, a mechanism of "permit screening - classified disposal - dynamic exit" will be used to eliminate non-compliant production capacity.
Impact on International Manufacturers: For international enterprises producing food additives in China, they need to optimize production facilities and processes in accordance with the new review standards. Companies should strengthen internal management to ensure compliance with regulatory requirements and avoid being phased out of the market due to non-compliant production.

Sales Link

Regulatory Measures: A comprehensive investigation and cleanup of food additive products will be conducted in both online and offline channels to regulate business practices. Online platforms are required to strengthen the management of food additive sales and supervise operators within the platform to fully and accurately display product label information.
Impact on International Manufacturers: When selling food additives in China, whether through offline channels or e-commerce platforms, international manufacturers must ensure that product labels and instructions comply with China's laws, regulations, and standards. Companies should enhance cooperation with sales platforms to ensure product information transparency and avoid penalties due to false advertising or non-compliant labeling.

Use Link

Regulatory Measures: Market regulation departments will strictly supervise the use of food additives in food production and catering services, establish a negative list for "excessive use" (exceeding the scope and exceeding the limit) of additives, and innovate the "process traceability verification" mechanism.
Impact on International Manufacturers: For international manufacturers selling food products in the Chinese market, it is necessary to pay special attention to whether the use of food additives in product formulas complies with Chinese regulations. Companies should establish a sound quality traceability system to ensure strict control over the amount and scope of additive use during production, avoiding product disqualification due to non-compliant use of additives.

Cross-Departmental Coordination and Social Supervision

Cross-Departmental Coordination

Regulatory Measures: At all levels, the food safety office will lead the strengthening of inter-departmental risk consultation and problem notification mechanisms, regularly assessing prominent risks associated with food additives. The Ministry of Agriculture and Rural Affairs, the Ministry of Industry and Information Technology, the General Administration of Customs, the National Health Commission, and the State Administration for Market Regulation will work together to form a regulatory synergy.
Impact on International Manufacturers: International manufacturers need to recognize the cross-departmental coordination mechanism of China's food safety regulation. This means that companies may face inspections from multiple departments, so they must ensure compliance with regulatory requirements at all stages to avoid overall business impact due to negligence in a particular link.

Social Supervision

Regulatory Measures: Encouraging increased supervision by all sectors of society and the media, and encouraging consumers to report related illegal clues through the national 12315 platform and hotline.
Impact on International Manufacturers: Companies should pay attention to the power of social supervision and promptly respond to consumer concerns. At the same time, they should establish and improve internal quality management systems to ensure that product quality can withstand the test of social supervision.

Relationship with Existing Regulatory Framework

The Plan complements existing laws and regulations such as the "Food Safety Law" and the "Agricultural Product Quality and Safety Law," forming a more comprehensive regulatory system for food additives. By strengthening source governance, supervision of production, sales, and use, and cross-departmental coordination, China's food safety regulatory framework has achieved more detailed and comprehensive coverage in the field of food additives. Compared with previous regulations, the Plan places greater emphasis on the entire process of regulation from farm to table.

Key Points and Recommendations for International Manufacturers

Increased Compliance Requirements

International manufacturers need to recognize that the implementation of the Plan means that regulatory standards for food additives in the Chinese market have been further raised. Companies must ensure strict compliance with China's regulatory requirements in all aspects of the production, sales, and use of food additives. This includes not only the quality standards of the products themselves but also aspects such as labeling, instructions, and import declarations. Overseas manufacturers should collaborate with professional legal advisors or regulatory consulting firms, such as Cisema.

Importance of Supply Chain Management

From the perspective of source governance, international manufacturers need to pay more attention to supply chain management. For agricultural raw material suppliers, companies should establish strict review mechanisms to ensure compliance with China's list of banned agricultural inputs. For imported food additives, companies must ensure that the products provided by suppliers fully comply with China's "positive list" requirements and declare relevant information truthfully. By strengthening supply chain management, companies can effectively reduce compliance risks caused by raw material issues.

Establishment of Quality Traceability Systems

The Plan emphasizes the importance of the process traceability verification mechanism. International manufacturers should establish sound quality traceability systems to ensure that the use of food additives in the production process can be fully traced. This can not only help companies better manage product quality but also provide strong evidence in the face of regulatory inspections. Companies should use modern information technology, such as blockchain, to enhance the efficiency and reliability of quality traceability systems.

Communication with Regulatory Authorities

Faced with the situation of cross-departmental coordinated supervision, international manufacturers should strengthen communication with regulatory authorities. Companies should promptly understand the latest requirements and policy dynamics of the regulatory authorities and actively cooperate with their inspection work. At the same time, companies can use industry associations and other channels to provide feedback to regulatory authorities on actual problems faced by the industry, jointly promoting the improvement and implementation of regulations.

Optimization of Product Formulas and Production Processes

In accordance with China's regulatory requirements, international manufacturers may need to adjust their product formulas to ensure that the use of food additives complies with China's limits and scope regulations. At the same time, companies should optimize production processes to ensure strict control over the amount of additives used during production, avoiding the occurrence of over-scope or over-limit use.

Strengthening Quality Control and Testing

Companies should establish a strict quality control system to conduct quality testing at every stage, from raw material procurement to finished product release. In particular, the use of food additives should be subject to strict internal testing to ensure product compliance with China's regulatory requirements. In addition, companies should regularly commission third-party testing institutions to conduct product testing to enhance product credibility.

Improvement of Labels and Instructions

Labels and instructions are important ways for consumers to understand product information and are also key content for regulatory inspections. International manufacturers should ensure that product labels and instructions comply with China's regulatory requirements, clearly and accurately labeling the name, scope of use, and amount of food additives. At the same time, the use of misleading or ambiguous expressions should be avoided to prevent consumer misunderstandings or regulatory penalties.

Establishment of Emergency Response Mechanisms

In the face of potential regulatory risks, companies should establish sound emergency response mechanisms. Once it is found that products do not meet regulatory requirements, an emergency response plan should be activated immediately, problem products should be recalled, and the regulatory authorities should be reported to in a timely manner. Effective corrective measures should also be taken. At the same time, companies should strengthen communication with consumers, promptly respond to consumer concerns, and minimize the impact on corporate reputation.

Further Information

To read the original announcement about the Comprehensive Governance Plan for the Abuse of Food Additives released by China’s State Council Food Safety Commission and relevant ministries, please click here.

If you are a food additive or food product manufacturer with questions about how China's updated regulations impact your compliance strategy or market access, please contact Cisema.