China Released the Implementation Q&A for China’s Administrative Measures for Food Labeling

Recently, China has issued an official Q&A to clarify key requirements under the Administrative Measures for Food Labeling. This guide addresses top compliance questions for food manufacturers, importers, and consumers regarding prepackaged foods, health supplements, and labeling standards. CIRS has collected some important questions and translated them into English for your reference: 

Q1: How to define the principal display panel (PDP) for prepackaged food packaging?

A1: The primary viewing surface that presents the product name, trademark, and net quantity of contents in the largest font size may be identified as the principal display panel.

Q2. The Measures require the production date and expiration date of prepackaged foods to be specifically indicated in a separate area of the packaging. What are the specific requirements for such a separate area?

A2: The separate area refers to a designated area on the packaging for indicating the production date and expiration date, which shall not overlap with other text, symbols, numbers, patterns, or other information on the label. Businesses are encouraged to use a clearly visible border that contrasts with the background to designate a specific area for indicating the production date and expiration date.

Q3. How is the production date determined for foods with multiple layers of packaging?

A3: For prepackaged foods with single-layer packaging, the date on which the packaging process is completed shall be taken as the production date. For prepackaged foods with multiple layers of packaging, the date on which the packaging process that directly contacts the food, i.e., the inner packaging process, is completed shall be taken as the production date.

Where sterilization, fermentation, or other processes are still required after completion of packaging—that is, after completion of the single-layer packaging process or the inner packaging process for foods with multiple layers of packaging—the date on which the relevant process is completed may be taken as the production date.

Q4. Where multiple production addresses are listed on a food production license, how should the production address be indicated?

A4: Where multiple production addresses are listed on a single food production license, any of the following methods may be adopted:

• Indicate only one of the actual production addresses listed on the license;
• Indicate all addresses listed on the license and use letters or numbers on the packaging to identify the actual production address; or
• Use a combination of a physical label and a numerical label.

Q5. Where a group company and its wholly owned subsidiaries each undertake part of the production process, how should manufacturer information be indicated on the label of the prepackaged food?

A5: Where a group company and its wholly owned subsidiaries jointly produce a food product by undertaking different stages of the production process, and the group company assumes overall responsibility for the product's quality and safety, the group company may be indicated as the manufacturer on the label. At the same time, the subsidiary undertaking part of the production process may be identified as a co-manufacturer through a numerical labeling method.

Q6. How should the warning statement area and warning statement be presented on health food labels?

A6: The warning statement area and warning statement on health food labels may be presented with reference to the Guidelines for Labeling Warning Statements on Health Foods. However, where the largest surface area of the smallest sales unit of a health food is less than 35 cm², the area of the warning statement may be exempt from the requirement under the Guidelines that “the warning statement area shall not be less than 20% of the surface area on which it is located.”

Q7. Are health foods required to indicate allergenic substances on their labels?

A7: Yes, health foods containing allergenic ingredients should proactively and completely provide allergen information in accordance with the Guidelines for Health Food Filing (Trial) and relevant national food safety standards.

Q8. Article 28 of the Measures provides that “where a trademark other than the trademark corresponding to the trademark name in the product name is used, the area of the trademark shall not exceed one-quarter of the area of the product name and shall be smaller than the area of the trademark name in the product name.” If an imported health food registration certificate or filing certificate specifies both a Chinese product name and an English product name, is the trademark corresponding to the English name subject to the above restrictions?

A8: The “trademark corresponding to the trademark name in the product name” referred to in the Measures means the trademark corresponding to the trademark name in the Chinese product name. Where a trademark corresponding to the English product name stated on the registration certificate or filing certificate of an imported health food is displayed on the label, it shall comply with the applicable requirements, including the restrictions on trademark area.

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Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, and R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

The vast majority of members in CIRS Food Business Division have over 10 years of professional experience in food compliance, with more than 80% holding Master’s or Doctoral degrees in food-related disciplines. The CIRS toxicology expert team consists of 24 Chinese Certified Toxicologists (DCST), 2 American Board Certified Toxicologists (DABT), and 2 European Registered Toxicologists (ERT). CIRS has provided one-stop food compliance services to over 1,000 domestic and international food and related enterprises. Leveraging its technical expertise, diverse resources, and global network, the CIRS Food Business Division offers global food compliance services, including but not limited to:

• Health food registration and filing in China;
• Application for “Three New Foods (new food additives, new food raw materials and new food-related products” in China;
• U.S. GRAS, NDI, and CAP notifications;
• EU Novel Food, food additives, and food enzymes applications; and
• Application for new feed ingredients and feed additives in China, the U.S., and the EU.