From the Year of the Snake to the Year of the Horse: China’s Food Law Year-in-Review 2025
As we transition from the Year of the Snake to the Horse, this is the ideal time to review changes to China’s food laws in 2025. We have seen major regulations – most notably regarding food labeling – move from draft proposals to final rules. Authorities also updated critical import protocols and tightened their grip on sensitive categories such as liquid infant formula. With the clock now ticking on transition periods for several major regulations, immediate adjustments are crucial to ensure compliance with the final rules.
This article reviews the most impactful regulatory developments of 2025 and provides a forward-looking analysis of what to anticipate in 2026.
The Food Labeling System in China underwent a significant transformation in 2025 with the promulgation of three pivotal national standards and regulations, namely National Food Safety Standard - General Standard for the Labeling of Prepackaged Foods (GB 7718-2025) [1], Management Measures for Supervision of Food Labeling [2], and National Food Safety Standard - General Standard for the Nutrition Labeling of Prepackaged Foods (GB 28050-2025) [3]. These regulations introduce substantial revisions to labeling requirements, such as new mandatory allergen declarations, mandatory warning labels advising children and teenagers to avoid excessive intake of salt, oil, and sugar, as well as adjusted date marking rules. The reforms signal a stricter regulatory stance on transparency and consumer protection. The framework also formally encourages the adoption of digital food labeling. Subsequent implementation guidance [4] clarifies that the scope of digital labels is distinct from marketing content (e.g., advertising) and mandates clear legibility without disruptive elements like pop-ups.
With a two-year transition period until full enforcement on March 16, 2027, stakeholders across all food sectors are advised to proactively review their product labels against these new standards. For further information, please refer to our CRM – Breaking News: China Publishes Revised Food Labeling Requirements.
New food ingredients and additives in China saw notable regulatory progress in 2025, with the National Health Commission (NHC) approving 15 new food ingredients and 31 food additives through its 2025 Announcements No. 1 [5], No. 3 [6], No. 4 [7], and No. 7 [8]. This included the approval of D‑allulose, which represents a significant development as the first new food ingredient derived from genetically modified microorganisms. Probiotics also remained a strong focus with the approval of three new strains. We have seen the authority continue to actively evaluate functional and nutritional substances. It extended approvals for certain substances like 2’-fucosyllactose (2’-FL) and lacto-N-neotetraose from new sources, while substances such as 3’-Sialyllactose sodium salt (3’-SL) and lacto‑N‑tetraose are currently undergoing government review. Advancements in protein innovation also continued, with the approval of mycoprotein from Fusarium venenatum and the review of fermentation-produced β-lactoglobulin illustrating a supportive regulatory pathway. On the other hand, while cultured meat has been approved in some countries under novel food frameworks, petitions for such products have not yet been reviewed by NHC; relevant guidelines are nevertheless in development. For further insights into China’s evolving regulatory framework for novel foods, please refer to our CRMs – Navigating Food Approvals in China: From Ingredients and Additives to Finished Foods and Tapping into China’s Booming Novel Food Market – A Regulatory Glance.
Imported foods faced a pivotal regulatory shift in 2025, centered on revised oversight for both traditional and cross-border e-commerce (CBEC) channels. The General Administration of Customs (GAC) published Decree No. 280 [9], amending the facility registration system for overseas manufacturers effective June 1, 2026. It streamlines the process by allowing companies to submit applications directly – even for higher-risk products [10] – and introduces a “batch registration” mechanism for recognized trading partners. More details can be found in our CRM – China Revises Food Facility Registration Requirements. Simultaneously, CBEC imports came under heightened scrutiny, with authorities proposing a negative list of prohibited or restricted items [11] and issuing the Announcement on Further Strengthening Recall Supervision of Retail Food Imported Through Cross-border E-commerce [12]. The new Announcement aims to strengthen the recall system by clarifying and reinforcing the responsibilities of all involved CBEC parties. These changes mandate that overseas CBEC operators appoint a domestic representative to act on their behalf in recall operations, closing a key enforcement gap and signaling a concerted move toward stricter accountability oversight for all food imports entering the Chinese market. For further information, please refer to our CRMs – China to Create a Negative List for CBEC Foods and China Moves to Strengthen Food Recall System.
The regulatory system for certain food categories advanced rapidly in 2025. A pivotal development was the resumption of registration approvals for imported health foods, ending an eight-year administrative freeze and signaling a welcome shift toward improved market access. In the meantime, the sector saw functional innovation with the official approval [13] in January 2026 of a new function claim, i.e., “Helps maintain bone and joint health (relieves pain or stiffness/alleviates cartilage damage),” following a public consultation held the previous year. The authority also introduced greater formulation flexibility by expanding the permitted dosage forms and excipients for popular supplements such as coenzyme Q10 and melatonin [14]. These developments are poised to facilitate greater product development and diversification in China’s health food market. Further details regarding China’s regulatory framework for health foods can be found in our recent articles – China: Master the Ingredient Regulations for Health Foods and China Revitalizes Approval for Imported Health Foods.
We note that in 2025, China amended its Food Safety Law [15] to implement stricter regulatory controls over two specific areas of concern, namely liquid infant formula and the bulk road transportation of liquid foods. The reform introduces a new licensing regime for the bulk road transport of liquid foods, a direct response to the 2024 scandal involving edible oil contaminated by shared fuel transport containers. Additionally, the amendment formally expands the existing registration system to cover liquid infant formula, subjecting it to the same stringent pre-market approval requirements as powdered infant formula. These targeted updates reflect a regulatory intent to strengthen accountability and close safety gaps in critical food supply chains.
In a key move for emerging sectors, Chinese authorities announced new management rules for food livestreaming in December 2025 [16], establishing definitive governance for this rapidly growing industry. The rules implement a clear “negative list” barring 13 unsafe food categories and explicitly banning 10 deceptive practices, including false health claims. China also concurrently released key regulations governing online trading platforms [17] and live-streaming e-commerce [18], further solidifying the regulatory framework for the digital commerce ecosystem in food trade.
The regulation of pre-made dishes, a high-growth market, will see significant development this year. Authorities issued the draft national standard for public comment in early February 2026 [19]. Once finalized, this standard will become the main regulation governing the definition, ingredient use, specifications, labeling, and packaging requirements for pre-made dishes.
At the enforcement level, China implemented finalized rules that exempt penalties for specific minor and first-time violations [20], such as cases involving food labeling noncompliance if certain conditions are met. It is worth noting that SAMR continues to develop further exemption categories [21], indicating an evolving policy approach. Such rules are expected to reduce the compliance burden on businesses and allow regulators to focus resources on serious, willful misconduct that poses genuine risks to public safety.
In the meantime, the newly issued Measures for the Handling of Market Regulation Complaints and Reports [22], effective April 15, 2026, clarifies that market supervision authorities will not accept complaints related to purchases made for non-consumption purposes and directly target malicious and abusive claims. This balanced framework aims to reduce operational burdens on legitimate businesses while ensuring regulatory resources focus on substantive violations.
Outlook for 2026
As we look ahead to 2026, the regulatory landscape for China’s food industry is poised for a year of significant refinement and expanded oversight.
As noted above, the anticipated adjustments and potential streamlining of facility registration under GAC Decree 280 will be a critical focus for overseas manufacturers, directly impacting the efficiency and predictability of the food import process. The industry should closely monitor the forthcoming list of high-risk foods – currently still under development and expected to be finalized soon – and assess any resulting changes to the risk classification of their products.
In addition, key national food safety standards, most notably GB 14880 governing the use of nutrition fortification substances, are expected to be finalized in 2026. These updated standards will provide critical clarity for product formulation and compliance across the industry.
We will continue to monitor and update the latest regulatory developments throughout the year. In the meantime, if you need any support navigating China’s food laws and regulations, 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.
[1] https://sppt.cfsa.net.cn:8086/db?type=2&guid=63F005D7-BA6F-428C-8098-826735B6C13E
[2] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2025/art_4edcff1e8d894890a012aac1e974c1ff.html
[3] https://sppt.cfsa.net.cn:8086/db?type=2&guid=01848F78-13AB-4F40-9DF8-DE1158E7BC26
[4] https://www.nhc.gov.cn/sps/c100088/202509/07b01e0a2fff482789cbb8c400c649a2.shtml
[5] https://www.nhc.gov.cn/sps/c100088/202502/943dcc40bc45486cbcda67859bf1fddb.shtml
[6] https://www.nhc.gov.cn/sps/c100088/202505/c3f86f8a80b34251892cf040bb4b218e.shtml
[7] https://www.nhc.gov.cn/sps/c100088/202507/63194b55e9fd4a6daa74f59a06cfd792.shtml
[8] https://www.nhc.gov.cn/sps/c100088/202511/f5f423bd3f9647b99627a1b315c7244e.shtml
[9] http://beijing.customs.gov.cn/customs/302249/2480148/6775328/index.html
[10] It should be noted that GAC inherited the existing Official Recommendation by the food authority in the exporting country for prescribed foods with a higher risk. Thus, if a food is considered high risk by GAC, the company should still obtain an official recommendation letter from the food authority in the home country and include such a letter in the company’s facility registration application that it submits to GAC.
[11] http://www.npc.gov.cn/npc/c2/c30834/202510/t20251027_448926.html
[12] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/spcjs/art/2026/art_b0bcafe73bf747279b27cef39d04e6b1.html
[13] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/tssps/art/2026/art_d1c641c2d2e345cea5f316b2c7826f61.html
[14] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/tssps/art/2025/art_960ad341a1604308955ec375e548f7c2.html
[15] http://www.npc.gov.cn/npc/c2/c30834/202509/t20250912_447764.html
[16] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2026/art_2ac47420b5064685b0e4a6b558af28df.html
[17] https://www.samr.gov.cn/wljys/gzzd/art/2026/art_74b094e2fda240cbada023e223bc25bb.html
[18] https://www.samr.gov.cn/wljys/gzzd/art/2026/art_fe860c192a4c45e0a77e39c14543be69.html
[19] https://www.nhc.gov.cn/sps/c100087/202602/895e1a278b3b4a3dad3292314770ace5.shtml
[20] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/zfjcs/art/2025/art_142d79c3d24d42b4a2334520b6093864.html
[21] https://www.samr.gov.cn/hd/zjdc/art/2025/art_d12caedb01d84d0cb221c567b8e5c823.html
[22] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2026/art_e4d03a20c0fd49769e408c7bf3791ff5.html