Q&As on the Implementation of the Measures for the Supervision and Administration of Food Labeling

Competent Department: Department of Food Production and Operation Safety Supervision and Administration

Publication Date: August 28, 2026

I. Relationship between the Measures for the Supervision and Administration of Food Labeling (hereinafter referred to as the “Measures”) and the National Food Safety Standard General Standard for the Labeling of Prepackaged Foods (GB 7718-2025)

Answer: The Measures and the newly revised National Food Safety Standard General Standard for the Labeling of Prepackaged Foods (GB 7718—2025) (hereinafter referred to as GB 7718) will be implemented simultaneously. The two are coordinated with each other, with different focuses. As a national food safety standard, GB 7718 mainly specifies the mandatory labeling items related to food safety for prepackaged foods and the technical requirements for food labeling. On the basis of ensuring food safety, the Measures further regulate the labeling practices of prepackaged foods, food additives, and bulk foods, strengthen the supervision and administration of food labeling, and better protect consumers’ rights to know and choose.

II. How should “mandatory labeling items for prepackaged food labels shall be indicated on the outer packaging of the smallest sales unit” be understood?

Answer: All mandatory labeling items on prepackaged food labels must be indicated on the outer packaging of the smallest sales unit to facilitate consumers’ reading and identification. The following situations do not meet the requirement of indicating them on the outer packaging of the smallest sales unit: for example, for a wine box with an anti-counterfeiting mark, if the mandatory labeling items are indicated on the wine bottle, consumers must damage and remove the anti-counterfeiting mark on the wine box before they can read the mandatory labeling items. Another example is packaged drinking water in transparent packaging, where the mandatory labeling items are indicated on the inner side of the label, requiring consumers to read the mandatory labeling items through the transparent bottle body and the liquid inside the bottle.

III. How should the principal display panel of prepackaged food packaging be defined?

Answer: The same plane viewed horizontally on which the food name, trademark, and net content are displayed in the largest font on the prepackaged food packaging may be regarded as the principal display panel.

IV. The Measures stipulate that the production date and expiration date of prepackaged foods shall be specifically indicated in a separate area on the packaging. What are the specific requirements for the separate area?

Answer: A separate area refers to a specific area on the packaging where the production date and expiration date are indicated, and which does not overlap with other text, symbols, numbers, patterns, etc. indicated on the label. It is encouraged to use borders with a clear contrast against the background on the packaging to designate a specific area for indicating the production date and expiration date.

V. How should the requirement that mandatory labeling items indicated on the label have a clear contrast with the background color be understood?

Answer: Where the text, symbols, numbers, patterns, etc. used for the mandatory labeling items indicated on the label have a color contrast with the background that enables consumers to visually obtain the labeling information under ordinary consumption scenarios, the contrast may be regarded as clear.

VI. Must the production date and expiration date be indicated in black text on a white background?

Answer: Forms in which the indicated production date and expiration date have a clear contrast with the background include, but are not limited to, black text on a white background. However, black text on a white background is the easiest-to-read labeling method in various consumption scenarios, and the use of black text on a white background to indicate the production date and expiration date is encouraged.

VII. For products such as packaged drinking water in transparent packaging bottles, cans, or glass bottles, does indicating the production date and expiration date by laser etching or laser coding meet the requirement of having a clear contrast with the background?

Answer: For transparent plastic bottles, glass bottles, or cans, the production date and expiration date may be indicated using one of the following methods to facilitate clear reading by consumers: First, methods such as ultraviolet laser etching may be used so that the indicated food date has a clear color difference from the bottle cap, bottle bottom, or bottle body; second, a separate area may be reserved when designing and printing the food label, and the food date may be indicated in that separate area during the labeling process in a manner with a clear color contrast; third, carbon dioxide lasers may be used to enlarge, bold, and deepen the etching of the font of the food date on transparent bottle bodies and cans, and clear and accurate guiding wording may be indicated on the principal display panel, such as indicating “Expiration date: see bottle shoulder” on the principal display panel of packaged drinking water, with numbers having a height of 3.3 millimeters used to indicate it at the bottle shoulder.

VIII. How should guiding words for the production date or expiration date be indicated?

Answer: For guiding words for the production date or expiration date, “Production Date,” “Expiration Date,” etc. may be indicated before the specific date as guiding words, or “Production Date and/or Expiration Date: See [specific location]” may be indicated on the label as guiding words.

IX. How should the guiding wording “see a certain part of the packaging” for the production date and expiration date be described accurately?

Answer: The guiding wording for the production date and expiration date shall be indicated on the principal display panel, and the specific location indicated by it shall be easy for consumers to understand and find. Taking bottled drinking water as an example, using “see bottle body” as the guiding wording is an inaccurate description. “See bottle neck,” “see bottle shoulder,” “see bottle bottom,” or “see bottle cap” may be used as guiding wording.

X. Are there any special requirements for the font height of “see a certain part of the packaging” for the production date and expiration date?

Answer: The font height of the wording “see a certain part of the packaging” shall comply with the provisions of Paragraphs 1 and 2 of Article 13 of the Measures.

XI. How should the production date of foods with multiple layers of packaging be determined?

Answer: For prepackaged foods with single-layer packaging, the date on which the packaging process is completed shall be taken as the production date. For prepackaged foods with multiple layers of packaging, the date on which the packaging process that is in direct contact with the food (i.e., the inner packaging) is completed shall be taken as the production date.

After packaging is completed, that is, after the single-layer packaging process and the inner packaging process of food with multiple layers of packaging are completed, if processes such as sterilization or fermentation are still required, the date on which the corresponding process is completed may be taken as the production date.

XII. The national standards Geographical Indication Product Pu’er Tea (GB/T 22111) and Black Tea Series Standards (GB/T 32719) stipulate that Pu’er tea and black tea may be stored for a long period under appropriate conditions. How should the expiration date of such foods be indicated?

Answer: When foods such as Pu’er tea and black tea can be stored for a long period under appropriate storage conditions, the expiration date may be expressed in the form of “Long-term Storage” as the shelf life. For foods labeled in this form, under the storage conditions indicated on the label, their food safety and quality shall remain stable for a long period and comply with the relevant food safety and quality requirements of national food safety standards and applicable standards.

XIII. What is the font size for indicating net content?

Answer: The font size for indicating net content shall simultaneously comply with Article 6 of the Measures for the Supervision and Administration of Measurement of Quantitatively Packaged Goods and Article 13 of the Measures for the Supervision and Administration of Food Labeling.

XIV. How should the requirement that the ratio of font height to width shall not exceed 3 be understood when certain characters (such as I) and numbers (such as 1) are relatively narrow?

Answer: Under the Measures, the ratio of font height to width shall be determined based on the typical character occupying the largest visual space with a complete outer frame within the same font size. For Chinese characters, the character “田” shall be used; for numbers, “0” shall be used; and for letters, “o” shall be used.

XV. Do font size, color contrast, etc. for non-mandatory labeling items in food labeling also need to meet the same requirements as mandatory labeling items?

Answer: Mandatory labeling items in food labeling shall comply with the requirements of the Measures. Non-mandatory labeling items shall be easy for consumers to identify and read, and shall not deceive or mislead consumers. It is recommended to refer to the requirements for font size, color contrast, etc. applicable to mandatory labeling items when making such indications.

XVI. Where the same prepackaged food contains multiple quantitatively packaged foods, it shall indicate the specifications. Is it mandatory to indicate the word “Specifications”?

Answer: “Specifications” may be optionally used as a guiding word.

XVII. How can the names of foods of animal origin meet the requirements of Article 16 of the Measures regarding reflecting the raw materials used?

Answer: To avoid food names deceiving or misleading consumers, the Measures emphasize that food names shall reflect the true attributes of the food and truthfully indicate the raw materials used. It stipulates that for foods made from raw materials of animal origin, where the name indicates livestock or poultry meat or aquatic animal products as raw materials, such raw materials shall be the primary raw materials. Where the name indicates only one type, all raw materials used shall come from that livestock or poultry meat or aquatic animal product; where the name indicates two or more types, the raw materials used shall be listed in the name in descending order according to their added amounts. For example, when beef and pork are used as two raw materials to make meatballs, “Beef Meatballs” may not be used as the food name.

XVIII. For foods such as dumplings and steamed buns made from foods of animal origin (livestock or poultry meat or aquatic animal products) as raw materials, how should the names reflect the livestock or poultry meat or aquatic animal product raw materials?

Answer: If the names of foods such as dumplings and steamed buns indicate raw materials of animal origin, they shall be reflected in the name in descending order according to the added amounts of the raw materials of animal origin. For example, dumplings in which beef is the only raw material of animal origin used in the filling may be called “Beef Dumplings.” If shrimp and pork are used as raw materials of animal origin in the filling, and the amount of shrimp added is higher than the amount of pork added, the steamed buns may be called “Shrimp and Pork Steamed Buns.” Raw materials of animal origin used only for seasoning purposes (such as a small amount of dried shrimp used for seasoning in quick-frozen wontons) do not need to be reflected in the food name.

XIX. What forms are considered to constitute claiming in food labeling that a food is suitable for minors?

Answer: If the text or images indicated on food packaging are sufficient to mislead consumers into believing that the food is suitable for consumption by minors, it shall be regarded as claiming that the food is suitable for minors, except for trademarks. For example, using images of infants and young children on solid beverage packaging.

XX. The National Food Safety Standard Standard for the Use of Food Nutrient Fortifiers (GB 14880-2012) and relevant Q&As stipulate the permitted varieties and amounts of nutrient fortifiers in formulated milk powder (limited to milk powder for children) and corresponding liquid products. If milk powder for children and corresponding liquid products use nutrient fortifiers in accordance with GB 14880, can this serve as a basis for “claiming suitability for consumption by minors”?

Answer: Where enterprises produce and operate corresponding products claiming that they are suitable for consumption by children in accordance with the permitted varieties and amounts of nutrient fortifiers specified in the National Food Safety Standard Standard for the Use of Food Nutrient Fortifiers (GB 14880-2012) for formulated milk powder (limited to milk powder for children) and corresponding liquid products, this complies with the provisions of Article 8 of the Measures for the Supervision and Administration of Food Labeling.

XXI. Where a food production license specifies multiple production addresses, how should they be indicated?

Answer: Where a food production license specifies multiple production addresses (i.e., one license with multiple addresses), one of the following methods may be used for indication: First, only the actual production address of a certain food specified on the license may be indicated; second, all addresses specified on the license may be indicated, with letters or numbers on the packaging used as codes to indicate the actual production address; third, a combination of physical labels and digital labels may be used, such as indicating on the physical label one of the addresses specified on the license that is convenient for consumers to contact, while indicating the other addresses specified on the license by means of digital labels, and using letters or numbers on the packaging as codes to indicate the actual production address.

XXII. Where a group and its wholly owned subsidiaries each undertake part of the production processes to jointly produce food, how should the producer information be identified on the label of the prepackaged food?

Answer: For food jointly produced by a group and its wholly owned subsidiaries, with each undertaking part of the production processes, where the group company assumes full responsibility for quality and safety, the group company may be indicated as the producer on the label, while the subsidiary undertaking part of the production process may be indicated as a co-producer by means of a digital label.

XXIII. When multiple producer information is indicated, how can the requirement that “the actual producer information shall be easy to identify” be met?

Answer: When multiple pieces of producer information are indicated, it shall be ensured that consumers can easily identify the actual producer. For example, each producer’s information may be indicated in separate lines, with consecutive letters or numbers used as codes before the producer information to distinguish them.

XXIV. How should the warning statement area and warning statement on health food labels be set up?

Answer: The warning statement area and warning statement on health food labels may specifically refer to the Guidelines for the Labeling of Warning Statements on Health Foods. However, where the maximum surface area of the smallest sales unit of a health food is less than 35 square centimeters, the area of the warning statement may not be subject to the limitation stipulated in the Guidelines for the Labeling of Warning Statements on Health Foods that “the area occupied by the warning statement area shall not be less than 20% of the surface on which it is located.” The labeling of the warning statement, such as font, color difference, and font height, shall still refer to the Guidelines for the Labeling of Warning Statements on Health Foods.

XXV. What is the significance of the labeling requirements imposed by the Measures on packaging of health foods that directly contacts the food (non-smallest sales unit)? How should it be properly labeled?

Answer: When the smallest sales unit contains multiple independent packages or multiple layers of packaging, after the outer packaging is labeled in accordance with the requirements of the Measures regarding the smallest sales unit, indicating information such as the product name, production date, and expiration date on the packaging that directly contacts the food can effectively prevent consumers from being unclear about the product attributes or whether the product has expired after removing the outer packaging, thereby avoiding potential risks and hazards. According to the Measures, the packaging that directly contacts the food shall indicate the product name, net content and specifications, production date and expiration date, consumption amount, and method of consumption. Such packaging that directly contacts the food is inner packaging and is not the smallest sales unit packaging. When labeling, enterprises shall ensure that it is easy for consumers to identify and read, reasonably determine the font size according to the actual area and layout of the inner packaging, and may also refer to the relevant requirements for mandatory labeling items on the outer packaging of the smallest sales unit.

XXVI. Is it necessary to indicate allergenic substances on health food labels?

Answer: From the perspectives of fully protecting consumers’ right to know, safeguarding the food safety of people with allergies, and improving product information transparency, health foods containing allergenic ingredients shall, in accordance with the Guidelines for Health Food Notification (Trial) and relevant national food safety standards, proactively and completely indicate information alerting consumers to allergenic substances, helping consumers clearly identify risks and make rational purchasing choices.

XXVII. If the name of a health food product is “XXX Brand Codonopsis and Astragalus Oral Liquid,” does this constitute a special emphasis on the addition or presence of one or more ingredients or components, and is it necessary to indicate the added amount of Codonopsis or Astragalus or its content in the finished product?

Answer: According to the Administrative Measures for the Registration and Notification of Health Foods, the name of a health food consists of a trademark name,

Reference

https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/spscs/art/2026/art_9a2980ad60f7459aab4d6f5b9902767b.html