China SAMR Releases FAQs on Labeling Requirements for Infant and Young Children Formula Foods

On September 20, 2026, the State Administration for Market Regulation (SAMR) released the FAQs on Labeling Requirements for Infant and Young Children Formula Foods (the “FAQs”), providing further clarification on labeling requirements for infant and young children formula milk powder and liquid formula.

The FAQs address several key labeling issues, including the indication of production dates and shelf-life expiration dates, allergen statements, milk-source and organic certification claims, label changes and filing requirements, production by other companies within the same corporate group, and the transition between old and new labels.

1. How should the production date and shelf-life expiration date be indicated?

The production date and shelf-life expiration date of infant and young children formula foods, including formula milk powder and liquid formula, shall be indicated in a designated area on the package in the order of year, month, and day. If the designated area is not located on the principal display panel, the principal display panel shall indicate wording such as “See [specified part] of the package” to direct consumers to the date information.

2. Is an allergen statement mandatory on labels of infant and young children formula foods?

Yes. Labels shall indicate other information required by applicable laws, regulations, and food safety standards. Allergen labeling shall comply with GB 7718. For infant and young children formula foods, the statement “This product contains milk” shall be provided in a location close to the ingredient list.

3. What are the labeling requirements for formula foods using imported or organic milk sources?

Where a product makes a claim regarding the source of raw materials, such as raw milk or milk powder, the country of origin or specific place of origin shall be truthfully indicated on the label.

For products that have obtained organic certification, the organic certification may be indicated in text or by using the relevant certification mark on a non-principal display panel. A copy of the certification certificate shall be submitted when applying for registration, including registration of changes.

In addition, labels for products with the same formula manufactured by the same enterprise shall have consistent content, format, and color. Where a milk-source claim is made, the milk source shall be clearly stated on the label. Manufacturers shall not distinguish different milk sources solely through packaging color, including the color of the can lid, can shape, or other packaging characteristics.

4. Are registration changes required when updating the production date, allergen statement, milk-source information, etc.?

According to the relevant registration regulations and technical guidelines, if manufacturers adjust the indication of the production date and shelf-life expiration date, allergen statements, milk-source information, or other similar labeling content based on the latest regulations, standards, and the FAQs, and the adjustment does not affect consistency with the registered product formula, an application for a change in product formula registration is not required.

However, manufacturers shall file the updated labels with the provincial-level market regulation authority in accordance with the Food Safety Law and the Guidelines for Filing Matters Concerning Ingredients and Other Items of Infant and Young Children Formula Foods.

Labels of products placed on the market shall remain consistent with the relevant registered and filed information.

5. How should labels be handled when a registered formula is produced by another controlled subsidiary or the parent company within the same corporate group?

Where an infant and young children formula milk powder formula is allocated for production by another controlled subsidiary or the parent company within the same corporate group, the relevant arrangement shall be reported to and publicized by SAMR in accordance with applicable requirements.

The product label shall clearly indicate the name and production address of the actual manufacturer. Such information shall be readily identifiable and shall be consistent with the manufacturer's name and production address stated on its food production license.

6. Can infant and young children formula foods produced before implementation of the Measures for the Supervision and Administration of Food Labeling continue to be sold?

Infant and young children formula foods produced before the implementation of the Measures for the Supervision and Administration of Food Labeling may continue to be sold if their labeling does not violate mandatory prohibitions under applicable regulations.

However, products whose labeling violates regulatory prohibitions shall not continue to be sold. Products that do not violate such prohibitions may remain on the market until the end of their shelf life.

It is worth noting that SAMR has clarified that the Measures for the Supervision and Administration of Food Labeling will take effect on March 16, 2027. Therefore, manufacturers should pay close attention to the transition period and review existing labels and labeling materials in advance.

Key Takeaways for Manufacturers

The release of the FAQs provides more specific guidance for manufacturers of infant and young children formula foods on label compliance. In particular, companies should review:

• Whether production dates and shelf-life expiration dates are presented in the required format and location;
• Whether the required allergen statement is included;
• Whether milk-source and organic certification claims comply with the applicable requirements;
• Whether label changes require registration changes or only subsequent filing;
• Whether actual manufacturer information is correctly indicated for intra-group production arrangements; and
• Whether existing products and labels meet the applicable transition requirements before the implementation of the Measures for the Supervision and Administration of Food Labeling.

Manufacturers are advised to conduct a systematic review of their current packaging, registered labels, filed information, and production arrangements to ensure consistency and compliance ahead of the implementation date.

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