Food Labeling in China: From Buzzwords to Regulatory Boundaries

Behind every viral claim, regulators are rewriting the rulebook, offering guidance to ensure products are correctly promoted within legal frameworks. From “zero GI” rice to “free of artificial colors” and “AI-personalized” probiotics, the world’s grocery shelves have become a battleground of buzzwords. This article highlights some of the trendiest claims in China’s food and beverage scene—what they mean, the rules that must be followed, and best practices that should be considered for compliance in China.

1. “Free” Claims

Chinese consumers are increasingly more health-conscious. They are looking for foods that are free from food additives, artificial colors, and preservatives, among many other things. While the concept of “clean label” itself may not be familiar to many Chinese consumers, the common rationale, e.g., to pursue naturalness, minimal processing, and the use of fewer food additives, is reflected in the labeling of many prepackaged foods sold in China. For instance, some soy sauce products may be labeled as “free from preservatives,” while candies might be described as “free from artificial colors.”

In March 2025, China published [1] the revised new food labeling national standard GB7718, i.e., GB7718-2025 [2] (effective on March 16, 2027), which expressly bans the use of terms including “no added,” “does not use,” “free,” and other expressions sharing similar meanings, unless the regulations or standards state differently [3]. The labeling restriction dissuades brands from using language that could put food additives in a negative light and potentially mislead consumers.

2. Ingredient Claims

Some ingredients are used in food due to their special characteristics or values. Companies, therefore, like to highlight their presence in food, such as through narratives or pictorial information. For instance, plant sterols may be emphasized on the label of a cooking oil product for the benefit of lowering cholesterol levels, while probiotics may be highlighted through the labeling of biscuits for their digestive benefits [4]. GB7718-2025 updated the previous rules to make claims about the emphasized ingredients.

As a general principle, the content of the emphasized ingredient should be declared on the label. However, there could be exceptions. For instance, if the reference to the ingredient appearing in a photo on the label is simply to suggest the flavor, taste, or consumption method, etc., such a reference is not considered emphasizing the ingredient through labeling.

3. Probiotics

Probiotics are popular ingredients used in foods sold in China. The Chinese Institute of Food Science and Technology (CIFST) published the Scientific Consensus on Probiotics (2020) [5], which provides a useful reference for industry and consumers to understand probiotics. A range of standards has also been developed, from the safety assessment of strains, to the labeling, to the manufacturing process, such as:

• T CIFST 009-2022 – General Standard of Probiotics for Food Use [6]
• T/CQCA 020-2023 – Labeling of Edible Probiotic Products
• T/CHC 1008-2023 – Ready-to-Eat Probiotic Foods
• T/CQCA 024-2024 – Operating and Management Specifications for Edible Probiotic Products
• DB43/T 2903-2024 – Technical Specifications for the Production of Probiotics and their Products

In terms of labeling, the standard T CIFST 009-2022 specifically commented on how to make claims about probiotics. It states that the product name of probiotics may be labeled as “Food Use Probiotics,” “Microbial Cultures (Probiotics) for Food Processing,” or any equivalent descriptors. Foods containing probiotics may be labeled as “Probiotic [product name]” or “Contains Probiotics [product name],” among similar expressions. Furthermore, it is recommended to include a warning such as: “If you are currently taking antibiotics, it is recommended to consume probiotic-containing foods at least two hours apart from antibiotics.” It is worth noting that in addition to these specific labeling provisions in the probiotics standards, the general food labeling requirements, e.g., not false and misleading, would apply to any claims pertaining to probiotics as well.

4. Plant-Based & Alt-Proteins

Alternative protein ingredients have become increasingly familiar to Chinese consumers, particularly plant-based food ingredients. Claims such as “veggie meat” and “plant-based milk” are commonly seen. The Chinese State Administration of Market Regulation (SAMR) updated its food labeling regulation in March 2025 [7], introducing specific provisions to address these claims. It requires that plant-based foods that imitate animal-derived products must include the descriptor “imitated,” “vegetarian,” or the name of the plant source in the product name.

GB/T 44336-2024 [8] addresses the Terminology and Classification for Veggie Meat Analogs under which the definitions of “veggie meat analogs,” “plant-based veggie meat analogs,” and “microorganism-based veggie meat analogs”, etc., are provided. There are voluntary group standards published for plant-based foods as well, such as:

• T/CIFST 002-2021 General Rules for Plant-based Foods
• T/CIFST 001-2020 Plant-based Meat products
• T/CHC 1004.1-2023 Plant-Based Milk Power

For other alternative protein foods, such as cultivated meat, it remains novel in China. The government has not released any guidelines or documents for their claims or labeling to date.

5. Lifestyle Claims

“Lifestyle claims” have moved from niche to mainstream in only a few years in China, but are popular in big cities. Urban consumers who look for healthy and responsible lifestyles are conscious about food claims, such as low-GI [9], whole-grain, clean food, carbon neutral, Rainforest Alliance, or keto. These claims are currently subject to the general food labeling requirements without mandatory legal definitions. However, there are industry initiatives aiming to standardize their use, such as “whole-grain” (LS/T 1105-2024 Classification and Labeling Requirements for Whole Grains), “low-GI” (Technical Requirements for Low-GI foods [10]), and “clean recipe food” (Technical Specification for Clean Recipe Foods) [11]. Industry should watch out for developments in this regard, as they might be “upgraded” into national standards in the future and become mandatory.

6. Health Claims

Health claims in China can only be made by “health food,” which is defined by the national standard for health food (GB16740-2014) [12]. Currently, only approved health claims can be used under the prescribed conditions, e.g., “assists in enhancing immunity” and “assists in improving memory.” Health foods are subject to pre-market approval. Therefore, if one is interested in making health claims for foods sold in China, approval from the SAMR should first be obtained. Notably, such a process is data-intensive and may take years.

Interestingly, the National Health Commission (NHC) indicated in July 2025 that they are working with SAMR to formulate new rules addressing “health claims” for substances considered to be both food and drugs (e.g., traditional Chinese medicines) through digital labeling [13]. It remains to be seen whether the collaboration between NHC and SAMR will provide some flexibility for industry to make health benefit claims on foods or ingredients.

Turning Compliance into Advantage

In today’s fast-evolving regulatory environment in China, international food companies can no longer afford to treat product claims as mere marketing tools—they are strategic assets that must align with China’s increasingly sophisticated compliance landscape. From “free” statements to highlighting functional ingredients and lifestyle-driven narratives, each claim carries both opportunity and risk. By proactively understanding the latest standards and anticipating regulatory shifts, companies can not only avoid costly missteps but also position themselves as trusted, forward-thinking brands in the eyes of both Chinese consumers and regulators. Now is the time to turn compliance into a competitive advantage, unlocking new opportunities in one of the world’s most dynamic food markets.

Note: This article was originally published by The World of Food Ingredients at https://www.foodingredientsfirst.com/theworldoffoodingredients/redefining-indulgence/50.html with further edits by the authors.

We will continue to monitor regulatory updates concerning food labeling and claims in China. Please sign up for our newsletters here.

Keller and Heckman represents the food industry around the world on various regulatory matters. If you have questions about food advertising and claims, or China market-entry strategy, please contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), or your existing contact at Keller and Heckman LLP.

[1] https://www.nhc.gov.cn/sps/c100088/202503/e8a432507f7d4f08a877e76a9b0578ce.shtml
[2] More details about GB7718-2025 can be found in Keller and Heckman’s China Regulatory Matters (CRM) newsletters at https://www.khlaw.com/insights/breaking-news-china-publishes-revised-food-labeling-requirements
[3] For instance, the food nutrition fortification standard (GB28050) allows nutrition claims such as “sugar free” so long as the prescribed criteria are met. Thus, “free” claim in this regard is permitted.
[4] Please note the descriptions of the ingredients refer to lowering cholesterol level or helpful for digestion, etc. may transform the food into a food regulatory category of “health food” subject to pre-market clearance.
[5] http://medi-guide.meditool.cn/ymtpdf/D5AA2E18-1B6B-CA34-D077-CD881A3C6509.pdf
[6] https://www.cifst.org.cn/uploads/file/20220616/1655343153183980.pdf
[7] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2025/art_4edcff1e8d894890a012aac1e974c1ff.html
[8] http://down.foodmate.net/standard/yulan.php?itemid=156520
[9] Low GI means low glycemic index.
[10] http://www.cnlic.org.cn/ZhinNengBuShi/ZhiLiangBiaoZhunBu/202311/P020231110114309.pdf
[11] https://www.cnfia.cn/wp-content/uploads/2025/09/qing-jie-pei-fang-shi-pin-ji-shu-yao-qiu-tuan-ti-biao-zhun.pdf
[12] https://sppt.cfsa.net.cn:8086/db?type=2&guid=C9648171-BCB6-49B3-8287-1C7D6CE94391
[13] https://www.nhc.gov.cn/wjw/tia/202507/3d0fc9faa40843fab75e94422800f68d.shtml