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Q&A on Pre-packaged Food Label Compliance Requirements and Food Advertising Risk Prevention and Control

from CIRS by


On April 26, 2023, we held a webinar on Pre-packaged Food Label Compliance Requirements and Food Advertising Risk Prevention and Control, you can watch the webinar for free here. During the webinar, the attendees raised a lot of questions so we've collected them together into this Q&A article.

Q: What are the requirements for the character height of net content information? Do you need to mark “Net Content”?

A: According to GB 7718, the net content mark is composed of three parts: “Net Content”, figures, and legal units of measurement. So, the two words “Net Content” must be marked. One can refer to Section of GB 7718 for the specific character height requirements for net content information.

Q: Can you label the nutrition information of solid beverages based on the post-preparation content?

A: As stated in the FAQs of GB 28050, in labeling nutrition content claims of pre-packaged food to be consumed after preparation, such as milk powder, and solid beverages, enterprises can choose to label the food in liquid or solid state, or both. When the two states are both labeled, the NRV% should be calculated according to one of them and clearly stated.

Q: Does the warning statement for solid beverages have to be on the front-of-package or can it be on the reverse?

A: The Notice on Strengthening the Quality and Safety Supervision of Solid Beverages requires enterprises to mark the specific name “Solid Beverage” on the label in a conspicuous manner, and the warning statement must be on the same page. Although the mark position is not specified in the Notice, we suggest that the words “Solid Beverage” and warning statement are marked on the front-of-package in consideration of the related labeling requirements for the food name in GB 7718.

Q: Does the “0” content requirement to the claim of “Zero Sucrose” in the draft of GB 7718 involve the detection limit?

A: According to the interpretation of the revision of GB 7718 delivered by the experts from CFSA in a 2022 training meeting for the National Food Safety Standard, if the standard test method of an ingredient specifies the detection limit, and the detection result is “not detected”, the content of the ingredient can be regarded as “0”.

Q: In GB 7101, does the viable bacteria products need to be labeled with its lactic acid bacteria (LAB) content? How do you understand the “content”?

A: As stated in Section 4.2 of GB 7101, the LAB content of viable bacteria products must be no less than 10^6 CFU/g(mL), and the content should be labeled. The LAB should be tested by the method specified in GB 4789.35. Therefore, enterprises need to guarantee that the test result of the LAB content is not lower than the content indicated on the label during the shelf life.

Q: According to the new regulations, does the name of a strain that is patented need to be changed to the name on the new regulations?

A: The strain name needs to be labeled according to The List of Strains that Can Be Used in Food and The List of Strains that Can Be Used for Infants and Children.

Q: If the detection result of fat is 0.5 g/kg, should it be labeled 0 or 0.5 in the nutrition information?

A: 0.5 g/kg equals 0.05 g/100 g. According to the threshold limit value of fat indicated in GB 28050, when the fat content is no more than 0.5g /100 g or 100 mL, it should be labeled as 0.

Q: In GB 7101, LAB content is required to be clearly labeled. Is it feasible to label “LAB” as “probiotics”?

A: “Probiotics” is legally acceptable in health food, but it is lack of legal basis in common food. Furthermore, probiotics and LAB are not identical. It is recommended to label the “LAB content” instead of “probiotics content” according to GB 7101.

Q: Should solid beverages be labeled as viable bacterial products or non-viable bacterial products?

A: All the products with strains added should clearly label whether it has been processed by sterilization according to Section 4.1 of GB 7101. It goes the same for solid beverages.

Q: The draft of GB 7718 stipulates that the picture of food shall not be displayed if the flavor is made with flavoring additive rather than real food. So does it mean that a product with food pictures on the packaging is not possible to import?

A: We believe that such products can be imported by covering the original label.

If you are interested in the global hot topics of food compliance, our webinar will be unmissable to you. CIRS Group has made a list of the free webinars we plan to hold in 2023 for your reference: CIRS Food - Upcoming Free Webinars in 2023. We are looking forward to seeing you!


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