China Releases First Group Standard for General Plant-Based Foods
With the booming market of plant-based food in China, industry is looking for regulatory guidance.
Some guidance came in late 2020 when the Chinese Institute of Food Science and Technology (CIFST) published the first voluntary group standard for plant-based meat. More progress was made in April 2021 when CIFST further released for comments the first group standard for plant-based foods (draft). The group standard is intended to be a general document that addresses a variety of matters pertaining to plant-based foods, from product definition, classification, use of ingredients, technical specifications, to labeling and claims.
Specifically, the standard defines plant-based foods as foods processed with the characteristics similar to that of animal-derived foods by using plant raw materials (including algae and fungi) or their processed product as the source of, for example, protein and fat, and classifies them into the following categories:
- Plant-based meat products
- Plant-based dairy products
- Plant-based egg products
- Plant-based frozen beverages and their ingredients
- Other plant-based foods
The draft also provides definitions for each of the above plant-based food categories. For instance, "plant-based dairy foods" are defined as "plant-based foods with corresponding characteristics similar to animal milk and dairy products, including plant milk, plant yogurt, plant cheese, plant condensed milk, plant cream, and other categories."
Furthermore, the draft sets forth the basic requirements for plant-based foods, including specifications for the use of food ingredients and food additives and labeling requirements. For example, protein and fat in plant-based foods must be derived from plant-based ingredients. In addition, words such as "plant," "plant-based," "plant protein," "plant-sourced," etc. should be used in the naming of plant-based food; otherwise, such words should be indicated on the panel where the food name is declared.
It is worthwhile to note that, currently, there are no mandatory regulations or national standards specifically governing plant-based foods in China. The development of this group standard could fill in some gaps and provide guidance for the plant-based food industry. However, we should note that China is currently amending its food labeling standard and regulation. For instance, the term "plant-based" is not clearly indicated in the naming of plant-based foods in the Draft Measures for Supervision and Administration of Food Labeling. Therefore, given that the group standard is voluntary in nature, industry must closely monitor the regulatory updates in terms of applicable requirements for plant-based foods set forth in the general food regulations and food safety national standards, which are mandatory.
Keller and Heckman represents the food industry including alternative protein companies around the world on various regulatory matters. We will continue to report updates in this area. Please sign up for our newsletters here. If you have any questions on the above or need a copy of the draft standard for plant-based food, please do not hesitate to contact David Ettinger (firstname.lastname@example.org), Jenny Xin Li (email@example.com), or your existing contact at Keller and Heckman LLP.
 On December 25, 2020, the Chinese Institute of Food Science and Technology (CIFST) issued the voluntary Group Standard for Plant-Based Meat Products, available at: http://www.cifst.org.cn/uploads/file/20201225/1608879643796557.pdf
 Please find more details of Chinese food labeling in our
CRM Alert- Are You Ready for China's New Food Labeling Requirements?
 http://www.samr.gov.cn/hd/zjdc/202007/P020200728518616517268.doc; According to the Draft Measures for Supervision and Administration of Food Labeling, when plant-based ingredients are used as raw materials to imitate animal-derived food, words such as "imitated", "artificial" and "veggie", etc. must be added to the product name to explain the true nature of the food.