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Food labeling requirements for imported prepackaged foods will welcome new changes

Views: 1     Author: Site Editor     Publish Time: 2024-02-22      Origin: Site

On January 19, 2024, the Secretariat of the National Food Safety Standards Review Committee released drafts for comments on four national food safety standards including the 'National Food Safety Standards for Prepackaged Food Labeling General Principles (Draft for Comments)'. The time triggered heated discussions in the industry.1

Food labels are the carrier that conveys product information to consumers.Proper management of prepackaged food labels is an effective means to safeguard consumer rights, ensure the healthy development of the industry, and implement scientific supervision.In recent years, more and more imported frozen products (meat, aquatic products, fruits) are imported in the form of pre-packaged food. Therefore, for the majority of frozen food lovers, GB 7718 cannot be ignored.

Regarding the content related to imported pre-packaged foods in this revision of the standard, Youdingte Research Institute will lead you to sort out the issues that are of most concern to importers such as how imported food labels are currently supervised, what adjustments will be made to the revised standard requirements, etc. Fan!


1. Labeling regulatory requirements for imported prepackaged foods


Article 97 of the 'Food Safety Law of the People's Republic of China' stipulates that imported prepackaged foods and food additives should have Chinese labels; if there should be instructions in accordance with the law, they should also have Chinese instructions.Labels and instructions should comply with the provisions of this Law and other relevant laws and administrative regulations in my country and the requirements of national food safety standards, and state the origin of the food and the name, address, and contact information of the domestic agent.Prepackaged foods that do not have Chinese labels or Chinese instructions or whose labels and instructions do not comply with the provisions of this article shall not be imported.


In April 2019, the General Administration of Customs issued Announcement No. 70 of 2019 (Announcement on Matters Concerning the Inspection, Supervision and Management of Imported and Exported Prepackaged Food Labels).Starting from October 1, 2019, the label filing requirements for first-time imported prepackaged foods will be cancelled.As one of the food inspection items, imported prepackaged food labels are inspected by the customs in accordance with the provisions of laws and administrative regulations related to food safety and import and export commodity inspection.

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The announcement clearly stated: 'Importers shall be responsible for reviewing whether the Chinese labels of their imported prepackaged foods comply with my country's relevant laws, administrative regulations and national food safety standards. Those that fail the review shall not be imported.'

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In addition to the general Chinese labeling requirements, there are other regulations that require special attention to imported prepackaged foods.


Article 30 of the 'Import and Export Food Safety Management Measures' stipulates that for imported fresh frozen meat products, the internal and external packaging should have firm, clear and easily distinguishable labels in Chinese and English or in Chinese and the exporting country (region), indicating the following content : Country (region) of origin, product name, production enterprise registration number, production batch number; the outer packaging should indicate specifications, origin (specific to the state/province/city), destination, production date, shelf life, storage temperature, etc. in Chinese , the destination must be marked as the People's Republic of China, and the official inspection and quarantine mark of the exporting country (region) must be added.


For imported aquatic products, the internal and external packaging should have strong, clear and easily distinguishable labels in Chinese and English or in Chinese and the exporting country (region), indicating the following: trade name and scientific name, specifications, production date, batch number, shelf life and storage conditions. , production methods (marine fishing areas, freshwater fishing countries or regions, aquaculture), production areas (marine fishing areas, freshwater fishing countries or regions, countries or regions where aquaculture products are located), and all production and processing enterprises involved (including fishing vessels, processing Ship, transport ship, independent cold storage) name, registration number and address (specific to the state/province/city), and the destination must be marked as the People's Republic of China.


The Chinese labels of imported health foods and special dietary foods must be printed on the minimum sales package and must not be affixed.


Article 15 of the 'Regulations on the Registration and Management of Overseas Production Enterprises of Imported Foods of the People's Republic of China' stipulates that when a registered enterprise exports food to China, it shall mark the registration number in China or the country (region) on the inner and outer packaging of the food. Registration number approved by the competent authority (Note: This requirement applies to food exported to China produced from January 1, 2022).


The implementation of the new model for prepackaged food label supervision is to implement the State Council's requirements for deepening the reform of 'delegating power, delegating power, delegating power, optimizing regulation, and optimizing services', simplifying the import procedures for prepackaged food, reducing the burden on enterprises, and further improving the efficiency of port customs clearance.


2. Interpretation of the 'Highlights' of the Revision of Import-related Requirements


1. Attention should be paid to the modification of the definition of prepackaged food.


Unify the scope of prepackaged food in the food standard system, include prepackaged food sold by measurement and weighing into the scope of prepackaged food, and modify the definition of specifications to connect with the definition of prepackaged food.


The so-called prepackaged food refers to food that is prepackaged or made into packaging materials or containers.Including pre-quantified packaging and pre-quantified food made in packaging materials and containers and with uniform quality, volume and length markings within a certain quantitative limit.It also includes food that is prepackaged or prepared in packaging materials and containers and sold by measurement and weighing.


2. 'Label defects' must not be directly related to food safety.


In line with the provisions of Article 148 of the 'Food Safety Law', formatting requirements that are not directly related to food safety, such as font size, font size, font height, and maximum surface area requirements, are moved from the standard text to the appendix, Food Label When the relevant content above is inconsistent with the standard requirements, it is convenient for the market supervision department to decide whether to manage it according to 'label defects' and reduce unnecessary administrative costs and industry burdens.


3. Add new labeling requirements for imported food.


The preparation instructions for the 'National Food Safety Standards for Labeling of Prepackaged Foods' (Draft for Comments) mention that in accordance with the management needs of the customs department, regulations on the labeling content of imported prepackaged foods have been added (see Part 8 of the standard for details, attached) , to facilitate the implementation of various requirements of this standard for imported foods.


For Chinese labels on imported prepackaged foods, there should be a one-to-one correspondence between the Chinese and foreign languages ​​of the mandatory labeling content.The content expressed in other foreign languages ​​or traditional Chinese characters that can be seen on the label should have a corresponding relationship with the standard Chinese characters (except for trademarks, producers and addresses of imported foods, names and addresses of foreign operators, and website addresses), and should comply with GB 7718 Article 4 , the requirements of Chapter 5.

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4. The labeling of the importer/agent shall be based on the actual responsible party.


Taking into account the differences in the business entities of imported food, it is stipulated that imported pre-packaged food should be marked with the name, address and contact information of the importer/agent. The labeling of the importer/agent should be marked according to the actual responsible entity.In line with the 'Regulations of the People's Republic of China on the Registration and Management of Overseas Production Enterprises of Imported Food' and the 'Regulations of the People's Republic of China on the Origin of Imported and Exported Goods', in accordance with the requirements of the customs department, imported food has been added to indicate the registration number of overseas production enterprises in China or the country or region where it is located. Requirement for registration number approved by the competent authority.


5. Imported prepackaged foods with a shelf life of not less than 1 year are no longer required to indicate the production date.


For imported foods that do not have a production date marked, the best before use date, shelf life and other information can be estimated and then marked.Imported food also stipulates that the shelf life is not less than one year, and the production date does not need to be marked.


6. Imported packaged foods should be marked with both the country of origin (region) and the country (region) of packaging.


The opinion draft clarifies that if the country or region of filling or repacking is inconsistent with the country of origin, the country or region of filling or repacking should be marked at the same time, and the source of the raw materials or ingredients or the name of the country or region of production can also be marked.If a peanut oil is produced in country A, packaged by country B and imported to China, the label of the peanut oil should indicate both the country of origin A and the packaging country B.


Warm reminder: Food that is not allowed to be repackaged in China cannot be imported into China after repackaging. At the same time, the 'Date Marking' part of the opinion draft requires that food produced in repackaging should also be marked with the production date of the repackaged food. , packing date.


3. Enterprises pay attention to standard revision trends and make timely adjustments


GB 7718 'General Principles for Prepackaged Food Labeling' is a mandatory national food safety standard that implements the food labeling provisions of the 'Food Safety Law'. It is also a general standard that regulates labeling requirements for all food categories.This third version of the draft for comments has been long-awaited and has undergone major changes compared with the current GB 7718 and the previous two versions of the draft for comments.


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The deadline for soliciting feedback on this standard revision is February 29, 2024. Imported food companies are hereby reminded to pay close attention to the revision of the standard and log in to the National Food Safety Standards Management Information System to submit feedback online in a timely manner.At the same time, it is also recommended that importers and friends take the initiative to request the original product labels and related certification materials from exporters or production companies before importing pre-packaged foods, complete the design and production of Chinese labels in advance, and strive to complete the certification of qualified Chinese labels before the products enter the country. Adding stickers will help improve the efficiency of product customs clearance.


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