In accordance with Food Safety Law of the People’s Republic of China (2015 version), prepackaged foods including general food and infant food shall comply with the quality and hygienic test requirements in the applicable Chinese National Food Safety Standards (hereinafter called “National standards”). The National Standards regarding the test requirements of prepackaged foods are listed as follows:
Applicable National Standards
Name of National Standards
GB 2761-2011 National Food Safety Standard Maximum Levels of Mycotoxins in Food
GB 2762-2012 National Food Safety Standard Maximum Levels of Contaminants in Food
GB 2763-2014 National Food Safety Standard Maximum Residue Limits for Pesticides in Food
GB 29921-2013 National Food Safety Standard Maximum Levels of Pathogens in Food
Commodity Standards (some examples)
GB 5420-2010 National Food Safety Standard Cheese
GB 9678.2-2014 National Food Safety Standard Chocolate, Chocolate with Cocoa Butter Alternatives and Their Products
GB 7101-2015 National Food Safety Standard Beverage
GB 19298-2014National Food Safety Standard Prepackaged Drinking Water
GB 10765-2010National Food Safety Standard Infant Formula
In fact, the test requirements for different prepackaged food categories are different. In order to have a better understanding of the test requirements in China, the example of Yogurt is provided as follows:
Yogurt belongs to the category of fermented milk in China. Therefore, the applicable commodity standard is GB 19302-2010 National Food Safety Standard Fermented Milk. According to GB 19302-2010, the required quality and hygienic tests are collated from below three National standards (GB 19302-2010, GB 2762-2012 and GB 2761-2011):
Test requirements in GB 19302-2010
Consistency in color, presenting in white or yellowish.
Put proper quality of samples into 50ml beaker, and observe the color and texture under natural light. Smell the flavor, and gargle with warm water then taste.
Taste and flavor
Specific taste and flavor of fermented milk.
Exquisite texture, homogeneous, light whey separation allowed.
Nonfat Milk Solid (SNF) (g/100g)a
Limit of microorganism (including pathogens)(CFU/g or CFU/mL)
GB 4789.3 Plate count
GB 4789.10 Qualitative
Lactic acid bacteria count Indicator (CFU/g or CFU/mL)
Lactic acid bacteria countb
a only applicable to whole milk products.
b no requirement of lactic acid bacteria for heat treated products after fermentation
n = the number of samples collected from the same batch of products;
c = the maximum allowable number of samples exceeding m level;
m = the acceptable limit level for pathogen index;
M = the highest safety limit for pathogen index.
Test requirements in GB 2762-2012
Limit of contaminants (mg/kg)
Lead (calculated as Pb)
Mercury (calculated as Hg)
Arsenic (calculated as As)
Chromium (calculated as Cr)
Test requirements in GB 2761-2011
Limit of Mycotoxins (ug/kg)
Based on CIRS regulatory compliance experience, prepackaged foods are strongly encouraged to pre-test the product quality according to applicable National standards before being imported into China, and monitoring risk items are also recommended for some food categories.
Why does CIRS recommend conducting pre-test?
I. According to the Administrative Measures on Imported – Exported Food Safety released by AQSIQ, all CIQs shall inspect the imported foods according to the mandatory applicable National standards after the commodity arrived at Chinese port. Meanwhile, companies will be faced with commodity rejection or destruction if the test result is unqualified (e.g., excessive lead, excessive coliform, excessive aflatoxin M1 etc.). Even more serious is that the importer, exporter and manufacturer of the unqualified food maybe recorded in the negative list. Please kindly click here to find the adverse impacts of the negative list.
II. According to the Plan on Food Safety Casual Inspection in Year 2016 published by CFDA, CFDA will carry out the casual inspection on food, food additive and health food (including imported food) every quarter. If the test result of the imported food is unqualified (e.g., excessive lead, excessive coliform, excessive aflatoxin M1 etc.), the responsible company will be subject to more than fifty thousand fine and all food will be recalled. In August, 2014, Heinz AD Calcium Hi-Protein Rice Cereal was recalled almost 1,500 boxes because of the excessive lead which were detected in the casual inspection of Zhejiang province in Eastern China. For the moment, this event has subsided, but lead exposure in food concerns remains.
III. As parts of the criteria for pathogens, contaminants and other quality indicators in food between domestic and overseas markets are different. Some foods which are qualified in original country or region (e.g., EU, USA, Taiwan etc.) may not comply with Chinese National standards. Therefore, pre-test is very necessary before food is imported into Chinese market.
What’s the benefit from pre-test?
Pre-test in certified laboratory could effectively avoid unnecessary punishment by CIQ or CFDA. If the food doesn’t comply with corresponding national standards after pre-test, probable reasons such as unqualified raw materials, mistaken operation and so on could be found and the problems shall be solved before formal importation.
When should you perform the pre-test?
Generally, pre-test should be conducted before mass-production. In addition the food formulation shall be confirmed before pre-test as well. Otherwise, the product will be an incompliant product in China although all test items are eligible since some ingredients are not allowed to be used in China. In this case, the first step is to modify the product formulation. After confirming the formula is in accordance with Chinese regulations, the pre-test is suggested to perform.
Where do you arrange the pre-test?
Pre-test could be arranged both in oversea and domestic laboratories. However, the test items, test methods etc. may be different in China and other countries, and the test report issued by Chinese certified laboratory is more acceptable by Chinese government. We suggest you to conduct the pre-test in a qualified Chinese lab.
Why choose CIRS?
I. CIRS has abundant experience on prepackaged food pre-test issues and has assisted lots of enterprises to carry out corresponding tests successfully.
II. CIRS cooperates with certified official laboratories in China to make sure the test results are authoritative and credible.
III. CIRS could help to deal with potential issues regarding pre-test on behalf of you. For instance, CIRS could help to confirm product category with required test items, and will help to check whether the test results are compliant in China etc.
IV. CIRS will provide free add-value consulting service regarding pre-test to let you have a brief understanding of Chinese national standard.
If you have any question, please contact us at firstname.lastname@example.org