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Two Chinese Food Agencies Release Drafts of New Food Labeling Requirements

On June 27, 2024, China National Health Commission (NHC) published the draft Food Safety National Standard for the Labeling of Prepackaged Foods (GB 7718-xxxx), marking the fourth time seeking public comments on the same standard[1].

In parallel to NHC’s consultation on GB7718-xxxx, just one day later, on June 28, 2024, the Chinese State Administration of Market Regulation (SAMR) released the draft amendments of its Measures for Supervision and Administration of Food Labeling (“Labeling Measures”).

GB7718 and Labeling Measures are the two key documents in China addressing food labeling. The consultation on the documents at the same time is an outcome of years of coordination between NHC and SAMR to streamline their responsibilities and optimize the management over food labels.

Specifically, the draft GB 7718 introduced a range of significant changes compared with the last version that was released in January 2024, including the removal and revisions of some labeling requirements that overlapped or are inconsistent with those set forth by the Labeling Measures. For instance, compared with the earlier 2024 draft, the latest version of GB 7718 only keeps the general principles for the declaration of certain labeling items, such as font size requirements for labeled characters, the declaration of date labeling, net weight, as well as food manufacturers’ information. It appears that the food authorities agreed to shift more details concerning the above labeling items into the Labeling Measures to ensure consistency in food regulations. For example, the draft Labeling Measures require that the declaration of production date and shelf life expiration date must be specified in the order of year, month, and day, and placed in designated areas on the label in a form with black text on a white background or other background color with obvious contrast. 

In addition, the updated version of GB 7718 removes requirements related to food claims, such as detailed classification and corresponding declaration requirements[2], while maintaining strict scrutiny over negative claims. For instance, claims such as “free…” and “not contain…” will remain prohibited for food additives, contaminants, and substances whose presence in food is not allowed.

We should note that the requirements for the labeling of imported foods under draft GB 7718 in January 2024 remain unchanged. For example, the draft mandates that all labeling information visible to consumers declared on imported pre-packaged foods (including contents in a foreign language or traditional Chinese) must follow Chinese laws, regulations, and food safety standards. As indicated in our CRM - China Solicits Comments on Food Labeling Standard, such changes will likely bring some challenges to the industry. Please refer to our article for more details.

In the meantime, the draft Labeling Measures introduce a number of requirements applicable to special foods (e.g., infant formula, health foods, foods for special medical purposes), bulk foods, prepackaged foods sold via the Internet, etc. For instance, the draft incorporates claim requirements for infant formula as outlined in SAMR’s announcement[3] by introducing a provision that prohibits content claims or function claims for infant formula for 0-6 months. Further, pre-packaged foods sold through the Internet are required to declare food label information on the website, including food name, net content, ingredients, shelf life, product standard code, storage conditions, manufacturer name and address, etc. These revisions highlight the importance that Chinese authorities place on labeling issues for these food categories.

It is worth noting that SAMR proposed to grant a two-year transition period for the implementation of the Labeling Measures; however, no grace period is offered by NHC under the draft GB 7718. It is advisable for industry stakeholders to closely monitor both GB 7718 and the Labeling Measures as the requirements in these two documents would be supplementing each other to form the regulatory framework for labeling prepackaged foods marketed in China, whether locally produced or imported.

Should you wish to learn more details about the draft regulations and/or would like to discuss the food labeling requirements in China in general, please do not hesitate to contact David Ettinger (, Jenny Li (, Sharon Tian (, or your existing contact at Keller and Heckman LLP. 


[2] For example, under the last version, food claims are proposed to be classified into general claims, nutrition claims and claims concerning the nutrition effect, claims concerning the health effects of food ingredients, and health function claims.