Countdown to the Implementation of Food Labels' "New ID Card"! Eight Major Changes to Watch
- Three food-labeling regulations/standards—GB 7718-2025, GB 28050-2025, and SAMR Order No. 100 (Measures for the Supervision and Administration of Food Labeling)—will take effect on March 16, 2027.
- GB 28050-2025 upgrades nutrition labeling from “1+4” to “1+6” by adding saturated fat (or saturated fatty acids) and sugars as two mandatory labeling items.
- GB 28050-2025 requires the statement “children and adolescents should avoid excessive intake of salt, oil and sugar” below the nutrition facts table, except for exempt nutrition facts tables.
- GB 28050-2025 defines sugar as the sum of fructose, glucose, sucrose, maltose and lactose in food, and sets the energy coefficient at 0 kJ/g for erythritol and 10 kJ/g for other sugar alcohols.
- GB 7718-2025 focuses on food names, ingredient emphasis and quantitative labeling, ingredient lists, date labeling, allergenic substances, digital labels, and food-claim principles; the Measures focus on fonts and font sizes, date-labeling position/size/color, net content, producer/operator information, and labeling for combination and multi-layer packaging.
Food labels are getting a "new ID card"! Three regulations and standards — the National Food Safety Standard – General Rules for the Labeling of Prepackaged Foods (GB 7718-2025), the National Food Safety Standard – General Rules for Nutrition Labeling of Prepackaged Foods (GB 28050-2025), and the Measures for the Supervision and Administration of Food Labeling (Order No. 100 of the State Administration for Market Regulation) — will take effect on March 16, 2027. Compared with the previous versions, the new rules make major adjustments across multiple dimensions. For example, GB 7718-2025 focuses on the following technical requirements for labels: food names (requirements and principles), ingredient emphasis and quantitative labeling, the ingredient list (food additives, compound ingredients, cultures, etc.), date labeling (content, form and exemption principles), allergenic substances, digital labels, and principles for the use of food claims; the Measures for the Supervision and Administration of Food Labeling focuses on the following supervision and administration requirements for labels: fonts and font sizes, the position, font size and color of date labeling, net content, information on producers and operators, and labeling requirements for combination packaging and multi-layer packaging. To help food producers and operators achieve a smooth transition and operate in compliance, the Provincial Market Supervision Administration has sorted out eight core changes based on practical operations. Let's take a look →→
01 Nutrition labeling upgraded from "1+4" to "1+6" GB 28050-2025 adds "saturated fat (or saturated fatty acids)" and "sugars" as two mandatory labeling items, upgrading it to "1+6". In addition, the new standard explicitly stipulates that "children and adolescents should avoid excessive intake of salt, oil and sugar" shall be labeled below the nutrition facts table. Nutrition facts tables that are exempt are excluded. Other important changes: The definition of sugar is explicitly tightened: it refers specifically to the sum of fructose, glucose, sucrose, maltose and lactose in food. The energy conversion coefficients for sugar alcohols are clarified: the energy coefficient of erythritol is 0 kJ/g, and that of other sugar alcohols is 10 kJ/g. Impact on enterprises: A large number of products will for the first time require quantitative testing of the individual contents of saturated fatty acids and five sugars. Enterprises need to complete product testing and label design updates as soon as possible. 02 Comprehensive upgrade of date labeling — "findable, legible, no calculation needed" The pain point of consumers being unable to find the production date no matter how they search the package is resolved under the new rules. Main requirements of Order No. 100: Production date: The production date of prepackaged foods shall be determined according to the completion of the production processes. Where the smallest sales unit is single-layer packaging, the date on which the packaging process is completed shall be taken as the production date; where the smallest sales unit has multi-layer packaging, the date on which the packaging process in direct contact with the food is completed shall be taken as the production date; where processes such as sterilization and fermentation are still required after packaging is completed, the completion date of the corresponding process may be taken as the production date. Where the smallest sales unit contains multiple independent packages, the shelf-life expiry date no later than that of the earliest-expiring food shall be labeled, or the shelf-life expiry dates shall be labeled one by one. Independent area: The production date and shelf-life expiry date of prepackaged foods shall be specifically labeled in an independent area on the package, and the specific dates labeled shall not easily fall off. If the independent area is not set on the main display panel of the package, the words "see a certain part of the package" shall be labeled on the main display panel, and shall be clear and conspicuous and accurately described, and the part where the specific dates are labeled shall be easy to find. Obvious contrast: The production date and shelf-life expiry date shall be labeled in a form with obvious contrast, such as black characters on a white background, to ensure clear legibility. Font height: The font height of the production date and shelf-life expiry date shall be no less than 3.0 mm; where the maximum surface area of the prepackaged food package is less than 35 square centimeters, the font height of the production date and shelf-life expiry date shall be no less than 2.0 mm. Year-month-day order: The production date and shelf-life expiry date of prepackaged foods shall be clearly labeled in the order of year, month and day. Impact on enterprises: If existing packaging designs cannot meet the requirements for an independent area, black characters on a white background and font height, the packaging layout needs to be re-planned, and simple sticker additions or supplementary printing are not allowed.
03 Expanded definition of prepackaged foods, foods sold by measurement formally included GB 7718-2025 formally brings "foods sold by measurement (including by weighing and by count)" into the scope of prepackaged food management, filling the gap in the original standard for prepackaged foods "without net content labeling". Impact on enterprises: Products sold by measurement that were previously managed as bulk foods must be labeled according to prepackaged food standards after March 16, 2027. Enterprises should systematically review the standards implemented for their products whose scope of application is the series of prepackaged food standards, and re-examine the reasonableness of the implemented standards. 04 Mandatory labeling of eight categories of allergenic substances GB 7718-2025 adds mandatory labeling requirements for eight categories of allergenic substances: gluten-containing cereals and their products, crustaceans and their products, fish and their products, eggs and their products, peanuts and their products, soybeans and their products, milk and dairy products (including lactose), and nuts and their kernel products. Enterprises may use one of two labeling methods in the ingredient list — bold font or underlining — or provide a centralized notice adjacent to the ingredient list. Impact on enterprises: All foods that use the above allergenic substances as ingredients must clearly indicate them on the label. Even when present as a component of a compound ingredient, they must still be labeled. At the same time, attention should be paid to the management of allergenic substances under GB14881-2025; identify, evaluate and optimize product formulations, and promptly assess the compliance of label marking. 05 Comprehensive expansion of prohibited label content GB 7718-2025 stipulates that prepackaged food labels shall not use terms such as "no addition", "not used" and "zero addition" to give special emphasis to food ingredients. Order No. 100 further expands the prohibited label content: It shall not be labeled with anything involving disease prevention or treatment functions; It shall not make false descriptions by means of deception, misleading or exaggeration; It shall not violate scientific common sense, offend public order and good morals, or promote feudal superstition; It shall not be labeled as "special supply", "exclusive supply" or "internal supply" for Party and government organs or the military, etc.; Foods other than health foods shall not claim health functions (efficacy) in food labeling; Where there is no basis in laws, regulations, rules, national food safety standards or industry standards, food labeling shall not claim to be suitable for minors to eat. Impact on enterprises: Products currently using promotional terms such as "zero addition" need to complete a full replacement of packaging and promotional materials before March 16, 2027. At the same time, it is necessary to check whether prohibited expressions such as "special supply" and "exclusive supply" exist, and whether health functions or suitability for minors to eat are labeled in violation of regulations. Where the text or images labeled on food packaging are sufficient to mislead consumers into believing that the food is suitable for minors to eat, it shall be deemed to claim suitability for minors (except for trademarks), such as the use of infant images on solid beverage packaging. 06 Food names must reflect true attributes According to Order No. 100, food names must reflect the true attributes of the food. Specific requirements include: For foods made from food materials of animal origin, where the name reflects raw materials of livestock or poultry meat or aquatic products of animal origin, such raw materials shall be the main raw materials. Where the name reflects only one kind, all raw materials used shall come from that kind of livestock or poultry meat or aquatic products of animal origin; where the name reflects two or more kinds, the raw materials used shall be listed in the name in descending order of addition amount. Plant-derived imitation animal foods (such as plant meat) must be labeled with prefixes such as "imitation", "vegetarian" or "a certain plant". Where the flavor is prepared only with essences, it must be labeled as "a certain flavor" or "a certain flavor profile". Impact on enterprises: Categories such as meat products and imitation meat products need to focus on checking whether food names truthfully reflect the raw materials used and the ordering by addition amount. 07 Digital labels formally incorporated into the rules GB 7718-2025 incorporates digital labels (QR codes and other information-based means) into the standard specifications for the first time. Consumers can scan QR codes with mobile devices such as mobile phones to obtain food label information. Where digital labels are also used to label matters that should be labeled on prepackaged foods, the label information displayed on the prepackaged food packaging may be simplified. The content of digital labels cannot be tampered with, and modifications are traceable. Order No. 100 stipulates: Where QR codes and other digital labels are used on food packaging to display food label content at the same time, the content shall comply with the provisions of laws, regulations and national food safety standards, and shall be consistent with the label information displayed at the same time on the food packaging. Impact on enterprises: Digital labels provide a new path for information expansion for small-package products, and can be given priority consideration for foods with a relatively small maximum packaging surface area.
08 Strengthening corporate primary responsibility and online food sales labeling Order No. 100 adds two important requirements: (1) Strengthen corporate primary responsibility Food producers and operators shall be responsible for the authenticity, accuracy and legality of the food labeling they provide, and shall designate specific institutions or personnel to review and check the food labeling. Food producers and operators are encouraged to select third-party professional institutions or professional technicians to conduct compliance evaluations of the food labeling they provide. (2) Strengthen online food sales labeling Online sales of prepackaged foods shall publish on the main sales page food label information such as the food name, net content, ingredients or ingredient list, shelf life, product standard code, storage conditions, producer name and address, and registration or filing information for special foods, and third-party platforms need to strengthen monitoring of labeling compliance. Impact on enterprises: Enterprises must establish an internal label review mechanism and designate responsible departments and personnel. At the same time, enterprises that sell products through e-commerce platforms must ensure that the label information displayed on the online main page is consistent with the physical packaging. Recommendations for enterprises 1 Start label compliance reviews as soon as possible. Check existing labels item by item against the new standards and the new Measures, focusing on: whether the "1+6" nutrition labeling is complete (required by GB 28050-2025); whether the labeling of the production date and shelf-life expiry date is compliant — independent area, obvious contrast, font height; whether allergenic substances are labeled; whether food names reflect true attributes; and whether any prohibited label content exists. 2 Comprehensively check against all requirements of Order No. 100. Do not focus only on the two standards GB 7718 and GB 28050; each provision of the Measures for the Supervision and Administration of Food Labeling must also be checked item by item to ensure full compliance. 3 Plan the transition period reasonably. Enterprises should complete label design updates and the consumption of old-version packaging in an orderly manner before March 16, 2027. For foods produced before the implementation date, if their labeling content violates the prohibitive provisions of the above regulations and standards, they shall not continue to be sold; if their labeling content does not violate the prohibitive provisions of the above regulations and standards, they may be sold until the shelf-life expiry date. For example, if a food label contains "zero addition", it shall not continue to be sold. Source | Production Safety Supervision and Management Division of the Provincial Bureau
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