China Issues New Food Labeling Standard Affecting Imported Pre-Packaged Products

On March 27, 2025, China’s State Administration for Market Regulation and the National Health Commission 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). These updates cover labeling, special dietary foods, product standards, and testing methods. International food manufacturers already operating in or planning to enter the Chinese market should note that the new requirements will affect label design, ingredient declarations, allergen disclosures, and compliance procedures. The implementation of these changes marks a significant regulatory update with direct implications for market access and product approval in China.

Background and Overall Framework of the New Standards

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, and testing methods, comprehensively covering 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.

Key Changes in the National Food Safety Standard for General Rules for the Labeling of Pre-packaged Foods (GB 7718-2025)

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.

Optimized Ingredient List Labeling Requirements

• Single-Ingredient Foods: Explicitly require ingredient lists for single-ingredient foods, enhancing transparency for consumers.

• Edible Packaging Materials: Edible substances serving packaging functions 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 non-functional additives’ excipients may be omitted, simplifying labeling in certain cases.

• Detailed Composite Ingredient Labeling: Composite ingredients must be labeled with their names and original components. If a composite ingredient has a recognized standard and constitutes less than 25% of the final product, its original components need not be listed. Rules for composite ingredients containing sub-composite ingredients are clarified.

• 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. Compound food additives must list all functional additives in the final product, either by individual quantity or grouped by compound attributes.

• New Microbial Strain Labeling Requirements: Live strains added during production must be labeled with their names, optionally including strain numbers and counts; fermented strains may be categorized. Inactivated strains must specify sterilization processes if labeled.

Standardized “Special Emphasis” and Claims

• Quantitative Labeling for Emphasis: Ingredients emphasized in product names must be quantitatively labeled, with formats and exemptions specified in an appendix.

• Regulated “Free From” Claims: Terms like “no,” “free from,” or “not added” require the corresponding ingredient or additive to be undetectable (≤0). Prohibited for additives, contaminants, or banned substances.

Clarified Use of Images on Labels

• Images illustrating flavor, ingredient sources, or usage are exempt from “special emphasis” rules, providing clarity for compliant label design.

Precision in Date Labeling

• Expiry dates must be explicitly stated as “year-month-day.” Exceptions apply for products with ≥6-month shelf lives or packaging ≤20 cm². Voluntary “best before” dates may be added but do not override statutory requirements.

Modified Quality Grade Labeling

• Quality grades may only be labeled if mandated by applicable standards, curbing arbitrary claims.

Mandatory Allergen Labeling

• Eight allergen categories (gluten-containing grains, crustaceans, fish, eggs, peanuts, soybeans, dairy, nuts) must be highlighted in or near the ingredient list. Voluntary labeling applies to other allergens. Appendix D provides formats and exemptions.

New Principles for Food Claims

• Claims must be truthful, accurate, and compliant with Chinese laws, regulations, and standards.

Integrated Labeling Rules for Imported Pre-packaged Foods

• Dedicated sections consolidate requirements for imported foods, including origin labeling (based on substantial transformation), mandatory bilingual labeling for specific information, and alignment with customs rules.

Alignment with Food Labeling Supervision and Administration Measures

• Font, font size, multi-layer packaging, and other details are delegated to the Measures, requiring enterprises to comply with both documents.

Impact of New Standards on International Food Enterprises

• Increased Label Compliance Costs: Redesigning labels for ingredients, claims, dates, allergens, etc., may raises compliance burden on companies, but particularly for multinationals that already comply with stricter requirements the change is likely to be a net positive, because they will likely already be in compliance unlike local competitors.

• Formula and Production Adjustments: Changes to additive rules or nutritional requirements may necessitate recipe revisions or process upgrades.

• Market Access and Competition: Non-compliant products risk exclusion, while compliant ones gain competitive advantage.

Recommendations for International Food Enterprises

• Conduct Timely Standard Training: Engage experts to ensure accurate understanding and monitor official guidance.

• Comprehensive Label Review: Audit existing labels against new rules and implement corrective actions.

• Reassess Formulas and Processes: Align with updated additive, nutritional, and production requirements.

• Strengthen Supply Chain Management: Ensure suppliers meet new standards and provide documentation.

• Leverage Professional Services: Partner with consultants like Cisema for regulatory compliance support.

Navigating Compliance in China’s Market

China’s updated food safety standards reflect heightened regulatory rigor, presenting both challenges and opportunities for international enterprises. Proactive adaptation, including compliance with labeling, formulation, and supply chain requirements, will enable businesses to thrive in this critical market.

Further Information

To read the original SAMR and NHC announcement about the new food safety standards for labeling of pre-packaged foods, please click here.

If you are a food manufacturer with questions about how the GB 7718-2025 standard affects your labeling compliance or market entry into China, please contact Cisema.

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