Breaking News: China Publishes Revised Food Labeling Requirements
On March 27, 2025, China published the revised three pivotal standards and regulations governing food labeling that impact all food sectors. Specifically, the major Chinese food authorities, National Health Commission (NHC) and State Administration of Market Regulation (SAMR), on the same day, released the following standards and regulation:
- National Food Safety Standard - General Standard for the Labeling of Prepackaged Foods (GB 7718-2025)[1]
- Management Measures for Supervision of Food Labeling (“Management Measures”)[2]
- National Food Safety Standard - General Standard for the Nutrition Labeling of Prepackaged Foods (GB 28050-2025)[3]
These regulations introduce enhanced labeling requirements while allowing industry a transition period of two years to exhaust stocks, with full enforcement set for March 16, 2027.
Compared with the latest draft versions of GB 7718 and Management Measures released in June 2024, the final version includes only minor adjustments. As highlighted in our previous newsletter – Two Chinese Food Agencies Release Drafts of New Food Labeling Requirements (“CRM”)[4], several labeling details, such as font size requirements, date labeling declarations, and manufacturer information, have been shifted from GB 7718 to the Labeling Measures. Therefore, to ensure full compliance, industry stakeholders should reference both GB 7718 and the Labeling Measures, as they will be the primary regulatory sources for prepackaged food labeling in China, covering both domestically produced and imported products.
Notably, the Management Measures newly include the prohibition of claims stating that a product is “suitable for minors” unless otherwise supported by laws, regulations, national food safety standards, or industry standards. This move demonstrates the government’s tougher stance against misleading marketing practices and its commitment to protecting young consumers from potentially deceptive claims. Another new provision encourages food producers and traders to engage third-party professional institutions or experts to conduct compliance evaluations of their food labels.
At the enforcement level, SAMR and its local departments are responsible for supervising and inspecting food labeling compliance. Per Article 39 of the Management Measures, market supervision departments may assess labeling defects for prepackaged foods by evaluating multiple factors, e.g., the relevance of labeling content to food safety, the degree of subjective fault by food producers or traders, as well as the potential impact on consumers’ understanding and purchasing decisions.
In the meantime, compared with the 2024 draft of GB 7718, the most notable change involves the declaration of date marking. Specifically, the labeling of production date may now be omitted for foods with a shelf life of six months or more – a reduction from the previous threshold of one year. This adjustment aligns with China’s policy to reduce food waste.
The labeling requirements for imported foods under the draft GB 7718 remain unchanged. For example, GB 7718 requires that all labeling information visible to consumers declared on imported pre-packaged foods (including contents in a foreign language or traditional Chinese) must follow Chinese laws, regulations, and food safety standards.
It is worth noting that GB 7718 introduces pivotal revisions to current labeling practices, including the mandatory declaration of allergens and strict scrutiny over negative claims (e.g., “free…” and “not contain…”). These changes signal a stricter regulatory stance on transparency and consumer protection, which impact food manufacturers, importers, and retailers operating in China. Notably, digital labeling becomes permissible under the new GB7718, which is likely to provide flexibility to industry and allow for the use of modern technology, such as bar codes, to declare labeling information. Details in this regard have not been released.
For a more detailed analysis of GB 7718 and Management Measures, please refer to our previous CRM noted above.
In addition, China finalized its food nutrition labeling standard, GB 28050-2025, following three rounds of public consultation. Compared with the 2011 version, this new standard maintains mandatory nutrition labeling requirements for prepackaged foods sold directly to consumers, with a few exemptions, e.g., food in a package or container with the largest surface area of no more than 40 cm2 (currently 20 cm2). Food that is not distributed to consumers directly, e.g., ingredients sold for food manufacturers for further processing (B2B ingredients), can voluntarily carry a nutrition label; however, if provided, the label must comply with GB 28050.
Expanded Nutrient Declaration Requirements - The updated standard adds sugar and saturated fat (acid) as the core nutrient items whose value is subject to mandatory disclosure in the nutrition information table. The current standard only requires the values of energy, protein, fat, carbohydrates, and sodium to be declared.
New Mandatory Warning Label - To promote healthier dietary habits – particularly among children and teenagers – the standard now mandates the inclusion of the following warning statement in Chinese on nutrition labels without any exception:
– “Children and teenagers should avoid excessive intake of salt, oil, and sugar.”
Voluntary Disclosure of Key Nutrients - N-3 polyunsaturated fatty acids (or ω-3 polyunsaturated fatty acids), α-Linolenic acid, DHA, and EPA – nutrients that attract much attention in marketing – are added to the list of nutrients that can be voluntarily declared in the nutrition information table.
Revised Nutrition Claims Framework - The new GB 28050 also updates nutrition content claims, comparative claims, and nutrient function claims. For example, with regard to claims that can be made for nutrients, new claims for protein, fat, α-Linolenic acid, sugar, vitamin A, vitamin K, etc., are added.
Serving Size Guidance - The new GB 28050 follows the current practice of permitting nutrition facts to be declared either on a per 100g/mL or per serving basis. In Annex E of the GB 28050, the recommended reference serving size for 18 food categories (e.g., milk powder, beverages) is provided with corresponding instructions on how to determine the serving size of a food product.
Given that the above three standards and regulation are the primary regulatory sources in China for food labeling, companies are highly recommended to commence internal reviews of existing product labeling against these new requirements, paying particular attention to key changes such as the new mandatory allergen labeling, product claims, and date marking requirements. Further, companies should closely monitor ongoing regulatory updates, including future official interpretations and implementation guidance from relevant authorities pertaining to these labeling regulations.
Should you wish to learn more details about the labeling regulations and/or would like to discuss the food labeling requirements in China in general, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Li (li@khlaw.com), or your existing contact at Keller and Heckman LLP.
Keller and Heckman LLP represents the food industry on regulatory matters in China and across the Asia Pacific region. Please sign up for our newsletters here.
[1] http://www.nhc.gov.cn/sps/s7891/202503/03de540798e647efa49c88c05a946fb5.shtml
[2] https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2025/art_4edcff1e8d894890a012aac1e974c1ff.html
[3] http://www.nhc.gov.cn/sps/s7891/202503/03de540798e647efa49c88c05a946fb5.shtml
[4] https://www.khlaw.com/insights/two-chinese-food-agencies-release-drafts-new-food-labeling-requirements