GB7718-2011 Q&A: A Compliance Guide to Prepackaged Food Labeling in China

I. Why GB7718-2011 Was Revised and What It Is Based On

Labels are the primary interface for communicating product details to shoppers. Stronger management of prepackaged food labeling therefore protects consumer rights, supports healthier industry growth, and aligns with science-driven food safety oversight. Acting under the Food Safety Law and its implementing regulations, the Ministry of Health organized a revision of the prepackaged food labeling standard. The resulting General Rules for the Labeling of Prepackaged Foods (GB7718-2011) reviews lessons from GB7718-2004, sharpens the labeling requirements set by the Food Safety Law and its implementing regulations, and strengthens the standard's scientific foundation and day-to-day applicability.

II. How GB7718-2011 Interacts With Departmental Rules and Regulatory Documents

GB7718-2011 is a national food safety standard. When a relevant departmental rule or regulatory document contains corresponding content that conflicts with this standard, the standard takes precedence.

The standard lays out general labeling requirements for prepackaged foods. If another national food safety standard provides special requirements, companies must comply with both the general rules and those special provisions.

III. How the Revision Was Carried Out

To support the Food Safety Law, its implementing regulations, and food safety supervision, the Ministry of Health tasked a drafting group formed by the Chinese Center for Disease Control and Prevention, the China National Food Industry Association, and other organizations. The group repeatedly brought experts together for research, workshops, and advisory meetings, while collecting input from relevant departments, trade associations, and businesses. A public consultation on the Ministry of Health website generated more than 700 comments and suggested changes. The drafting group analyzed each submission, held topic-specific meetings to resolve issues, and refined the text. The standard passed review at the fifth directors' meeting of the National Food Safety Standards Review Committee. It was issued on April 20, 2011, and became effective on April 20, 2012.

IV. Major Updates in the Revised Standard

(1) The scope was revised. GB7718-2011 applies to two categories of prepackaged foods: those provided directly to consumers and those not provided directly to consumers. It excludes labeling for bulk foods, foods prepared and sold on site, and food storage and transportation packaging.

(2) Following the Food Safety Law, the standard changed the definitions of 'prepackaged food' and 'production date,' and introduced a definition and labeling approach for 'specification.'

(3) Following the Food Safety Law, the standard added a rule that labels must not state or suggest disease prevention or treatment effects, and that non-health foods must not express or imply health benefits.

(4) Following the Food Safety Law, the standard made food additive labeling more detailed, requiring additives to be declared by their generic names in the Standard for the Use of Food Additives (GB2760).

(5) Drawing on Codex standards, the standard introduced recommended allergen labeling so consumers can make food choices better suited to their individual needs.

V. What Counts as Prepackaged Food

Guided by the Food Safety Law and the Measures for the Supervision and Administration of the Measurement of Quantitatively Packaged Commodities, and building on earlier label management experience, GB7718-2011 defines 'prepackaged food' as food that has been prepackaged or made in packaging materials or containers in predetermined quantities. The definition also covers food prepackaged or made in packaging materials or containers in predetermined quantities that bears a uniform mass or volume indication within a certain quantity limit. Two conditions matter: the food must be prepackaged, and the package must carry a uniform mass or volume indication.

VI. Labeling Differences: Direct-to-Consumer vs. Non-Direct-to-Consumer Prepackaged Foods

A: For prepackaged foods provided directly to consumers, every required item must appear on the label. For prepackaged foods not provided directly to consumers, the label must include the food name, specification, net content, production date,

— Reposted from China Packaging Network (pack.cn); original link: http://news.pack.cn/show-362090.html