China Released New National Food Safety Standards for Public Comments

On August 1, 2025, China’s National Health Commission (NHC) released [1] a number of draft GB standards for food products, covering general standards for the use of nutrition fortification substances, nutritional supplement foods for the elderly, foods for special dietary uses, as well as the limits of contaminants in foods and specifications of food additives, etc. Comments should be submitted to the authority before September 26, 2025. We provide a summary below of some of these draft GB standards.

• Draft Standard on the Use of Nutrition Fortification Substances in Foods (GB 14880 -XXXX)

This is the third version of the revised draft GB standard on food nutrition fortification substances [2] published by NHC since 2012. Compared with the current GB 14880, the draft standard classifies the use of nutrition fortification substances in food into “mass food fortification” and “voluntary food fortification.”

Specifically, “mass food fortification” refers to the addition of micronutrients or other nutritional components to specific widely consumed foods (limited to five categories in the draft - fortified milk, vegetable oil, rice, wheat flour, and soy sauce), for which the Chinese government encourages nutritional fortification and takes the lead. In contrast, “voluntary food fortification” involves the addition of micronutrients or nutritional components to other foods at the discretion of producers. Permitted nutrient types and usage levels for both categories are detailed in Appendices A and B of the draft.

In addition, the draft incorporates nutrition fortification substances newly approved under NHC announcements since 2012 and updates the list of permissible nutrient sources. For instance, substances such as vitamin K2 and 2’-fucosyl-lactose were newly added as permissible substances for fortification.

For further details on the first two drafts, please refer to Keller and Heckman’s prior CRM articles - Updates on China’s Regulation of Food Ingredients and Additives and China Announces Draft Standard on Nutritional Fortification Substances: What Will its Impact Be on Alternative Protein Foods?

• Draft Standard on General Principles of Sports Nutrition Foods (GB 24154 - XXXX)

Compared with the current GB 24154, the draft [3] revises product classification by removing the general categorization based on characteristic nutrients and sports events. However, it retains the specific subcategories under these classifications, including energy supplements, energy control products, protein supplements, speed and strength products, endurance products, and post-exercise recovery products. The post-exercise recovery category is further divided into physical recovery and joint recovery subcategories.

The draft also updates technical specifications for various sports nutrition food categories, introducing new nutritional indicators and testing methods. For instance, it proposes amendments to the technical requirements for protein supplements, adding specifications for semi-solid products and modifying fat indicators for solid products.

• Newly Proposed Food Standards

In addition to the revisions of the existing standards discussed above, NHC also proposed new standards for foods to address regulatory gaps, including nutritional supplement foods for the elderly [4] and edible livestock and poultry blood products [5].

For nutritional supplement foods for the elderly, they are defined as a subcategory of special dietary foods that use milk, milk protein, soya and/or soy protein as the basic components, with options of adding vitamins, minerals, and other ingredients to meet the nutritional demands of the elderly consumers. Specification requirements for such foods are also detailed in the draft. Health aging is a hot topic in China. With the development of this standard, industry would have the necessary regulatory guidance to formulate nutritional foods suitable for the elderly.

The draft standard for edible livestock and poultry blood products applies to the products made from single types of livestock and poultry blood, such as duck, pig, chicken blood, etc. Technical requirements such as the use of food additives, protein content, contaminants and microbial parameters are provided in the draft.

In addition, NHC proposed new requirements specific to the limits of contaminants and mycotoxins for dried aquatic products and foods for special medical purposes through the revisions of GB 2762 National Food Safety Standard - Maximum Levels of Contaminants in Foods [6] and GB 2761 National Food Safety Standard - Maximum Levels of Mycotoxins in Foods [7]. Draft standards for a list of food additives [8] are also published by NHC in the same announcement, which involve additives such as Lycopene (synthetic), Gelatine, Galacto-oligosaccharides (GOS), etc. Companies producing these additives should review the draft additive standards to assess whether the specifications proposed by China are acceptable, or if any changes should be made by submitting comments.

Should you wish to learn more details on the draft GB standards or have questions about the general food regulatory requirements in China, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), Sharon Tian (tian@khlaw.com), or your existing contact at Keller and Heckman LLP.

Keller and Heckman LLP represents the food industry on regulatory matters around the world.  Please sign up for our newsletters here.

[1] https://www.nhc.gov.cn/sps/c100088/202508/d225acc0b11e42afa7e59e7a54d7e9db.shtml
[2] https://sppt.cfsa.net.cn:8086/cfsa_aiguo?task=a_do&standard_guid=8D3D29D8-BB04-4D22-89A7-F735F0208650&pici=8C03788A-7009-0DA1-34D6-6E095B32ABB5&net_rand=7e034880-e109-c1b6-b126-7d62cd8d2e5b
[3] https://sppt.cfsa.net.cn:8086/cfsa_aiguo?task=a_do&standard_guid=03D57CF5-6B0A-434A-8ECC-A2867D96D4DB&pici=D3572D36-BAFD-24BA-6582-B5C9FEE77938&net_rand=6d28e903-15b5-6aa4-6b82-2f2e5cfa2aea
[4] https://sppt.cfsa.net.cn:8086/cfsa_aiguo?task=a_do&standard_guid=9BF5B568-93D2-4239-8DFF-0DDF3A3139A6&pici=DEDF73DE-C1E0-C47E-A449-6031930F7170&net_rand=11a38842-ed77-ae6b-38e0-f63c143f9eef
[5] https://sppt.cfsa.net.cn:8086/cfsa_aiguo?task=a_do&standard_guid=6CD895C5-7B0C-4A8C-B63D-A82405EF7E7D&pici=5542F359-E5B3-8640-E5EC-6BACFAAF059F&net_rand=6336ec54-212e-1fac-f551-2a01a2a09e8f
[6] https://sppt.cfsa.net.cn:8086/cfsa_aiguo?task=a_do&standard_guid=294DDE8A-C19B-4A4A-A99B-B712AC0CA5B5&pici=AD6CB8DA-6072-1304-5008-E3D10F502EA8&net_rand=e0ff255a-9c74-3b16-f402-398ffbc74d41
[7] https://sppt.cfsa.net.cn:8086/cfsa_aiguo?task=a_do&standard_guid=49AA5C1A-31BF-40F4-A75D-A8F58C6E7625&pici=3B13F561-CE28-EB3B-B27E-EACF49B3E066&net_rand=5234ad32-43e0-82f2-e0ff-e945d6e650aa
[8] https://sppt.cfsa.net.cn:8086/cfsa_aiguo