Interpretation of Major Changes in GB 7718 Draft

On 31^st Dec 2019, the National Health Commission of the People's Republic of China (NHC) released 13 national food safety standards for public comments. The due date of the public comments is 28th Feb 2020.

“GB 7718 National Food Safety Standards-General Rules for the Labeling of Prepackaged Foods (Draft)” (Hereinafter referred to as GB 7718 draft) obtains the highest attention among the 13 standards. Therefore, CIRS Group summarizes the major changes in GB 7718 draft to let enterprises understand how to design the label of the prepackaged food in the future.

1. Modify the text requirements for the label of prepackaged food.

GB 7718 draft indicates that when the maximum surface area of the package is more than 60cm2, the height of the characters, symbols, and numbers of the mandatory labeling content shall not be less than 1.8mm.

Interpretation: Based on a comprehensive consideration of reading and designing of the label, the requirement of text on the label is relaxed in the GB 7718 draft. In the current GB standard, the requirement of the maximum surface area is 35cm2, which is much less than 60cm2 required in GB 7718 draft.

2. Indicate allergens as mandatory labeling content

GB 7718 draft indicates that the allergens should be mandatory label content rather than recommended label content.

Interpretation: In the GB 7718 draft, the list of allergens is the same as the one included in the current GB 7718. Showing allergens on a label help consumers understand the food product and decrease food safety issues caused by allergens.

3. Label “date” in the order of year, month, and day

GB 7718 draft indicates that both production date and expiry date should be labeled in the order of year, month, and day.

Interpretation: Current GB 7718 doesn’t require the order of dates shown on a label. The requirement of date labeling in the GB 7718 draft is the same as “Food Label Supervision and Management Measures (Draft)”. Besides, the "Guidelines for Labeling Warning for Health Foods" has required that the production date / expiry date of health foods must be marked in the order of year, month and day. Thus, it is foreseeable that this requirement will be extended from health food to all food categories in the future.

4. Standardize the use of ingredients photos

GB 7718 draft indicates that the picture of food or ingredients cannot be shown on the label if the flavor is made by essence. For example, strawberry drinks, if the flavor is formulated by strawberry essence and the product doesn’t contain real strawberries, the picture of strawberry cannot be shown on the package.

Interpretation: Currently there is no limit on pictures used on packages. Generally, enterprises will use “the picture is only for reference” to avoid risks, but this statement can still mislead consumers. To avoid that, GB 7718 draft puts forward the requirement on pictures.

5. Manage the claims on ingredients

GB 7718 draft indicates that

1) For food additives, pollutants, and substances that are not allowed to be used in food, the claims, such as none, free, or their synonyms, cannot be shown on a label.

2) Do not use words such as "not added", "not used" and their synonyms on a label.

Interpretation: Currently there is no limit on such claims. But on the one hand, these claims harm healthy competition. On the other hand, these claims may mislead consumers. For example, “no added sugar” sounds like the product does not contain any sugar, but ingredient naturally containing sugar may be added. Therefore, GB 7718 draft intends to forbid such claims.

6. Add a separate chapter for the labeling of imported prepackaged food

GB 7718 draft indicates that

1) Country of origin (region) refers to one country (region) where the products are obtained entirely. If two or more countries (regions) are involved in the production, the country (region) that causes substantial changes in the product is the country of origin.

2) If the original label of imported prepackaged foods contains information about a suitable population, consumption amount or consumption method, this information should also be indicated on the Chinese label. Suitable population and consumption amount should meet the requirements of relevant Chinese national food safety standards.

Interpretation:

1) The definition of “country of origin” in GB 7718 draft is different from that in current GB 7718, but it is the same with “Regulations of the People's Republic of China on the Origin of Import and Export Goods”. According to GB 7718 Draft, the country of origin on the label and the certificate of origin will be uniform.

2) Currently, Chinese labels do not require a content of suitable population, consumption amount or consumption method generally. The GB 7718 draft will require it if the related information is mentioned in the original label and the relevant information should meet the Chinese regulations. This change means the requirement of the original label becomes stricter.

Summary:

To avoid misleading and misunderstanding of food labels, except for the above major changes, there are also some more detailed changes in GB 7718 draft. For example, specify the labeling requirements for bacteria and food additives. Enterprises should study the updated standard to avoid missing important information after the formal standard is released.

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