China Revises Pre-Packaged Food Labeling Rules and Digital Labels Under GB 7718-2025

On March 27, 2025, China's State Administration for Market Regulation (SAMR) and the National Health Commission (NHC) released 50 new national food safety standards, including the revised "National Food Safety Standard for General Rules for the Labeling of Pre-packaged Foods" (GB 7718-2025). On July 29, 2025, the two agencies issued a follow-up announcement clarifying how digital labels, including QR codes, may be used to display food labeling information while ensuring authenticity, readability, and traceability.

The package of new standards updates requirements for food labeling, special dietary foods, product specifications, and testing methods. For international food manufacturers already selling in China or preparing to enter the market, GB 7718-2025 is among the most consequential revisions.

The revised standard introduces new requirements for ingredient declarations, allergen labeling, product claims, imported food labeling, and digital labels, requiring many companies to review existing labels and compliance procedures before the March 16, 2027, implementation date.

China's New Food Labeling Standards: What Changed?

China’s food safety regulatory system has been continuously evolving to adapt to domestic market dynamics and align with international standards. The newly released standards span multiple domains, including:

• Food labeling
• Special dietary foods
• Food products
• Production and operation specifications
• Food-related products
• Quality specifications for food additives and nutritional fortifiers
• Testing methods

Together, the standards comprehensively cover the entire food supply chain from farm to table.

These updates are based on assessments of China’s current food safety landscape, shifting consumer demands, and global food safety trends. They refine and clarify requirements across all stages of food safety management, aiming to enhance food safety levels, protect consumer health rights, and provide a more robust foundation for the regulated development of the food industry.

For overseas manufacturers, GB 7718-2025 will likely have the most immediate operational impact because it affects how pre-packaged foods are labeled before entering the Chinese market. The subsequent digital label announcement adds another layer of practical importance, especially for companies managing multilingual labels, limited package space, traceability information, or product portfolios that require frequent information updates.

Key Changes Under GB 7718-2025

The revised food labeling standard introduces numerous updates that affect both domestic and imported pre-packaged foods. While some revisions clarify existing requirements, others establish entirely new compliance obligations that manufacturers exporting food to China should begin assessing now.

Expanded Definition of Pre-packaged Foods

GB 7718-2025 revises the definition of pre-packaged foods to include those sold by weight after pre-packaging and adds “length” as a permissible unit of measurement. This change addresses previous regulatory gaps for pre-packaged foods without net content labeling, meaning more food types must comply with pre-packaged labeling requirements.

International enterprises must review label compliance for products sold by weight under the new definition.

Revised Ingredient Labeling Requirements

The updated standard introduces several important changes to ingredient declarations:

• Single-Ingredient Foods: Ingredient lists are now explicitly required for single-ingredient foods, enhancing transparency for consumers.
• Edible Packaging Materials: Edible substances serving a packaging function must be listed in the ingredient list to prevent consumer misunderstanding.
• Exempted Ingredients: Ingredients that volatilize or are removed during processing, processing aids, inactivated enzymes, and excipients of non-functional additives may be omitted, simplifying labeling in certain cases.
• Detailed Composite Ingredient Labeling: Composite ingredients must be labeled with their names and constituent ingredients. If a composite ingredient has a recognized standard and constitutes less than 25% of the final product, its constituent ingredients do not need to be listed. The standard also clarifies rules for composite ingredients containing sub-composite ingredients.
• Revised Food Additive Labeling: International Numbering System (INS) codes for additives may only be used if the packaging's maximum surface area is 60 cm² or less. Compound food additives must list all functional additives present in the final product, either individually or grouped by compound attributes.
• New Microbial Strain Labeling Requirements: Live strains added during production must be labeled by name and may optionally include strain numbers and counts. Fermented strains may be categorized. Inactivated strains must specify the sterilization process if they are labeled.

Stricter Rules for Ingredient Emphasis and Product Claims

GB 7718-2025 establishes clearer rules for emphasizing ingredients and making product claims.

Ingredients highlighted in the product name or elsewhere on the label must generally be quantified unless a specified exemption applies. This is intended to prevent marketing that overstates the presence of featured ingredients.

Claims such as "free from," "contains no," or "not added" are also more tightly regulated. Such claims may only be used when the relevant substance is not detectable under the applicable testing method. The standard prohibits these claims for food additives, contaminants, and prohibited substances.

The revision also clarifies that images used to illustrate flavor, ingredient sources, or serving suggestions are not automatically treated as ingredient emphasis requiring quantitative declaration.

Updated Date Labeling Requirements

The revised standard standardizes how expiration dates must be presented.

Expiry dates must generally be presented using a year-month-day format. Limited exceptions apply to products with shelf lives of at least six months or to very small packages with a maximum surface area of 20 cm² or less.

Manufacturers may continue to provide voluntary "best before" dates, but these do not replace the legally required expiration date.

Quality Grade Labeling

Quality grades may only be declared where required by an applicable national standard, limiting the use of discretionary quality claims that could mislead consumers.

Mandatory Allergen Labeling

GB 7718-2025 requires mandatory labeling of eight major allergen categories:

• Cereals containing gluten
• Crustaceans
• Fish
• Eggs
• Peanuts
• Soybeans
• Milk
• Tree nuts

These allergens must be clearly identified in or adjacent to the ingredient list. The standard also allows voluntary disclosure of additional allergens and includes guidance on acceptable presentation formats.

Digital Labels for Pre-packaged Foods

The July 29, 2025, NHC and SAMR announcement clarifies the implementation of digital labels under GB 7718-2025. A digital label presents food labeling information through digital technology, such as a QR code, to supplement the physical label. It must comply with Article 67 of the "Food Safety Law of the People's Republic of China" and all mandatory national food labeling requirements.

Where package space is limited, digital labels may provide additional information, including ingredient sources, production processes, place of origin, usage instructions, traceability, food safety, and nutrition information. They supplement rather than replace mandatory physical labeling.

Key requirements include:

• Content must be clear, prominent, easy to read, and free from overlapping information or disruptive elements such as pop-up or floating windows.
• Advertising and promotional content are not permitted.
• QR codes should be integrated where practical to support "one code for multiple purposes."
• Information must be authentic, accurate, objective, scientific, and not misleading.
• Content updates must be documented with modification details, timestamps, and responsible personnel to ensure traceability.
• For health foods, foods for special medical purposes (FSMP), and infant formula products, digital content must match information registered or filed with the relevant authorities.

The announcement also introduces greater flexibility for production address labeling. Where the full production address is provided through a digital label, manufacturers may abbreviate the physical label to the county-level administrative region following the manufacturer's name.

New Requirements for Imported Food Labeling

GB 7718-2025 consolidates labeling requirements specifically applicable to imported pre-packaged foods.

The revised provisions clarify country-of-origin determination based on the principle of substantial transformation, identify information that must appear in Chinese, and align food labeling requirements with customs regulations.

Companies exporting food products to China should carefully review imported product labels to ensure compliance across all applicable regulatory requirements before products enter the market. Where digital labels are used, overseas manufacturers should also confirm that digital content remains accessible, accurate, traceable, and consistent with any registration or filing information required in China.

Alignment with the "Food Labeling Supervision and Administration Measures"

Certain technical requirements, including font size, typography, and multilayer packaging, are now addressed in the separate "Food Labeling Supervision and Administration Measures" rather than GB 7718-2025 itself.

As a result, manufacturers must comply with both documents when developing compliant labels.

What GB 7718-2025 Means for International Food Manufacturers

Although many revisions focus on label content, the business implications extend well beyond packaging design. Companies exporting food to China should expect broader reviews involving regulatory affairs, product development, quality management, supply chain documentation, and digital information governance.

Increased Compliance Costs

Updating labels to reflect revised requirements for ingredients, allergens, claims, date formats, imported food information, and digital label content will require additional regulatory and operational resources. However, multinational manufacturers that already comply with more stringent international labeling standards may find the transition less burdensome than companies with less mature compliance systems.

Formula, Documentation, and Digital Content Reviews

Changes affecting food additive declarations, nutritional information, and product claims may require manufacturers to reassess product formulations, manufacturing processes, technical documentation, and supporting compliance records.

Companies using digital labels should also establish internal controls for digital content approval, version management, modification records, and consistency checks between physical labels, digital labels, product specifications, and China registration or filing materials.

Market Access Considerations

Failure to comply with the revised food labeling requirements could delay product approvals, interrupt imports, or create barriers to market access. Digital labels may offer practical flexibility for products with limited packaging space, but they also create new compliance responsibilities related to accuracy, readability, cybersecurity, and traceability.

Companies that prepare early will be better positioned to maintain uninterrupted access to the Chinese market.

How Companies Should Prepare Before March 2027

With implementation approaching, manufacturers should begin compliance planning well before enforcement begins.

Priority actions include:

• Training regulatory, quality, labeling, and digital content teams on the revised requirements.
• Conducting a comprehensive review of existing physical and digital product labels.
• Evaluating formulations and manufacturing processes against the updated standards.
• Confirming suppliers can provide the documentation needed to demonstrate compliance.
• Reviewing QR code design, digital label readability, content controls, and modification records.
• Verifying that digital label content for health foods, foods for special medical purposes, and infant formula foods matches registered or filed information.
• Seeking expert regulatory affairs support where product classifications or labeling obligations remain uncertain.

Final Thoughts

China’s updated food safety standards reflect heightened regulatory rigor, presenting both challenges and opportunities for international enterprises.

For international manufacturers, early preparation will be essential. Companies that proactively review labels, reassess compliance strategies, and coordinate across regulatory, quality, and supply chain functions will be better positioned to maintain uninterrupted market access and avoid costly delays.

If you are a food manufacturer with questions about how GB 7718-2025 affects your labeling compliance, or if you need support with Chinese food labeling requirements, product registration, or broader regulatory affairs in China, contact Cisema today.

Further Information

Explore Cisema's services for health foods and supplements regulatory compliance in China.

References

Read the original SAMR and NHC announcement on the new national food safety standards, including "National Food Safety Standard for General Rules for the Labeling of Pre-packaged Foods" (GB 7718-2025).

Read the NHC and SAMR announcement on matters related to the implementation of digital labels for pre-packaged foods.