When browsing the diverse array of imported food products available,
have you ever paid attention to the Chinese labels on their packaging?
Asa small tag, the label holds key information.
More than just a legal ID,
it is your gateway to understanding the food's safety and nutrition.
I. What Are Prepackaged Food and Food Labels?
Prepackaged Food refers to food that is pre-quantified and packaged in materials or containers before being offered for sale. Common examples include a bottle of milk or a package of chocolate biscuits.
Food Labels encompass all tags, labels, text, graphics, symbols, or other descriptive information attached to or printed on the food packaging container. They function as an "instruction manual" for the product, conveying key details such as its ingredients and best-before date or expiry date (shelf life).
II. Why Is a Chinese Label Mandatory for Imported Prepackaged Food?
In accordance with Article 97 of theFood Safety Lawof the People’s Republic of Chinaand Article 30 of the Administrative Measures of the People’s Republic of China for the Safety of Food for Import or Export, imported prepackaged food is required to bear Chinese labels. Where an instruction manual is required by law, it must also be provided in Chinese.These labels and instruction manuals must comply with all applicable Chinese laws, administrative regulations, and national food safety standards. They are required to clearly indicate theplace of origin (country or region), along with the name, address, and contact information of the domestic importer or agent. The import of any prepackaged food lacking the necessary Chinese label or instruction manual, or whose label and instruction manual do not fully comply with these stipulations, is strictly prohibited.
III. What Essential Information Should a Proper Chinese Label Include?
To quickly determine if a label is compliant, keep the following mandatory items in mind:
1. Product name, specifications, net quantity, and date of manufacturing.
2. List of ingredients or components.
3. Name, address, and contact information of the importer, agent, or distributor (the manufacturer’s information is not mandatory).
4. Best-before date or expiry date (shelf life).
5. Storage conditions.
6. Generic names of any food additives used, as specified by national standards.
7. Country or region of origin (for example, Hong Kong, Macao, and Taiwan should be labeled as place of origin).
8. For prepackaged food sold directly to consumers, a nutrition label must also be provided in accordance with the National Food Safety Standard - Standard for Nutrition Labeling of Prepackaged Foods (GB 28050-2011), unless exempted under the Standard.
9. Any other items required by laws, regulations, or food safety standards.
Beyond these standard items, the following information is also important for specific consumer groups or under particular conditions:
. Batch Number
Companies may choose to include a batch number at their discretion.
. Usage Instructions
Where applicable based on different products, guidance such as opening, usage, and preparation instructions may be provided to ensure proper use.
. Allergens
Foods and food products containing known allergenic substances shall be declared using their common names, either within the list of ingredients or in a statement immediately adjacent to it.
. Irradiated Food
(1) Food treated with ionizing radiation must be labeled “Irradiated Food” near the product name.
(2) Any irradiated ingredients must be clearly indicated in the list of ingredients.
IV. Beyond General Labelling Rules: Are There Other Specific Requirements?
(I) Pursuant to Article 30 of the Administrative Measures of the People’s Republic of China for the Safety of Food for Import or Export, for the imported fresh and frozen meat products, there shall be firm, clear and identifiable written marks in Chinese and English or in Chinese and the language of the exporting country (region) on the internal and external packages, indicating the following contents: the country or region of origin, name of product, registration number of the manufacturer, and batch number. The specification, place of origin (the specific state/province/city), destination, date of manufacturing, best-before date or expiry date (shelf life), and storage temperature shall be indicated in Chinese on the external packages. The destination shall be the People’s Republic of China, and the official inspection and quarantine mark of the exporting country (region) shall be affixed.
(II) For the importedaquatic products, there shall be firm, clear and identifiable written marks in Chinese and English or in Chinese and the language of the exporting country (region) on the internal and external packages, indicating the following contents: commodity name and scientific name, specifications, date of manufacturing, batch number,best-before date or expiry date (shelf life) and storage conditions, mode of manufacturing (sea fishing areas, freshwater fishing countries or regions, and aquaculture), manufacturing area (sea fishing areas, freshwater fishing countries or regions, and the country or region where aquaculture products are located), name, registration number and address (the specific state/province/city) of all the manufacturing and processing enterprises involved (including fishing vessels, processing vessels, transport vessels, and independent cold storages), and the destination must be the People’s Republic of China.
(III) The Chinese labels of the health-care food and food for special dietary use for import must be printed on the smallest sales package and shall not be affixed.
(IV) In accordance with Article 15 of the Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food,registered manufacturers shall mark their registration number issued by the Chinese authority or the registration number approved by the competent authority of their home country or region on the internal and external packages of food products exported to China.(Note: This requirement applies to imported food products manufactured on or after January 1, 2022.)
V. What Happens to Imports with Non-Compliant Food Labels?
Each year, a number of imported prepackaged food shipments require corrective action due to non-compliant labels identified during Customs inspection.
Non-compliant imported prepackaged food may be identified under the following conditions:the product lacks a Chinese label; upon inspection, the label format or layout may fail to comply with Chinese laws, administrative regulations, rules, or food safety standards; or the results of conformity assessment are inconsistent with the declarations on the label.
Disposal methods for non-compliant imported prepackaged foodare as follows: in cases of safety, health, or environmental protection violations, authorities will order the return or destruction of the entire batch. For non-compliance in other cases, the importer may carry out technical adjustments under Customs supervision. If such adjustments are not possible, or if the product still fails re-inspection after adjustments, Customs will require the goods to be returned or destroyed.
VI. Important Note
It is important to note that the prepackaged food labeling requirements outlined above pertain specifically to products imported through general trade channels. Different regulations apply to prepackaged food entering China under the following circumstances: as exhibition items or samples, through certain duty-free operations (excluding offshore duty-free), for the personal use of diplomatic missions, carried by incoming travelers, or imported via mail, express delivery, or cross-border e-commerce platforms. Such products are generally exempt from the mandatory Chinese labeling requirement and shall be handled in accordance with their respective applicable regulations.
