China is Updating its Food Laws

China continues to update their food safety programs which includes food labeling. On December 31, 2019, the National Health Commission of the People’s Republic of China (NHC) released 13 national food safety standards for public comments.  Two of the most important standards being revised are GB 7718- 2011: General Rules for the Labelling of Prepackaged Foods (More information on gComply here) and the Food Labelling Supervision and Management Measures. Another updated draft was just released by the government for comment.

The GB 7718 draft revises the way food additives are to be declared in the ingredient statement, makes allergen labelling mandatory, and adds a separate chapter for the labelling of imported prepackaged food.  There are other changes as well.  The GB 7718 draft has already undergone several rounds of public consultation, and China has also notified WTO (World Trade Organization) of the draft.  We expect the draft to be finalized later this year.

DRAFT Food Labeling Supervision and Management Measures is also under review.  These measures are “ministerial regulations” so they are a higher hierarchical standard than GB 7718.  This means that GB 7718 continues to be the cornerstone of the prepackaged food labelling regulation, but the content of these Measures must also be considered.  The draft mandates that Chinese labelling is to be carried out during the food manufacturing process.  This will impact imported foods as an imported product is often affixed with a Chinese sticker at the port or even after customs clearance.  This practice would no longer be permitted. This draft will also make it very difficult to revise or fix a labelling error at port since “double stickering” will be prohibited.  Additionally, redirecting food from another country to China will not be permitted if the food sold abroad does not possess a Chinese label.  This draft standard has been circulated for comments domestically and will be notified to the WTO.  There are already many questions about the timing, impact and enforcement of this draft.

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Posted on 29 July 2020