Label Review and Translation of Prepackaged Food

According to the China Food Safety Law (2015 Version), pre-packaged food without Chinese labels or their labels not complying with the Law shall not be imported to China. However, as some enterprises are unfamiliar with the related regulations in China, many imported food are returned or destroyed due to the label problems every month.CIRS professional food regulations team is familiar with the pre-packaged food regulations and can provide comprehensive and accurate label review and translation services based on its rich experience to help companies design labels that meet national requirements to avoid unnecessary losses.

1. Reference Regulations in China

Major Regulation
Laws and Regulations	Food Safety Law (2015)
	Administrative Provisions for Label Inspection and Supervision of Imported and Exported Pre-packaged Food
	Administrative Provisions for Food Labeling
	……
Labelling Standards	GB 7718-2011 General Standard for Pre-packaged Food Labels
	GB 13432-2013 Pre-packaged Special Dietary Food Labels
	GB 28050-2011 General Standard for Pre-packaged Food Nutrition Labels
	……

2. Basic Requirements for Chinese Label

I. Where the largest surfaces area of a package (container) of pre-packaged food is more than 35 cm2, the minimum size of the words, symbols and numerals which are mandatory in the label shall not be less than 1.8 mm in height.

II. Besides Chinese, corresponding foreign languages can also be applied in the Chinese label (Except that Chinese is not mandatory for the logo, manufacturer name and address of imported food, name and address of oversea distributor, website), but the size of foreign language should not be larger than that of corresponding Chinese (except the logo).

III. Net weight and food name should be labeled on the same display layout of the package (container).

IV. Claims of disease prevention or treatment are forbidden to indicate or imply on the Chinese label, and health function claims shall not be conducted to non-health food.

3. Mandatory Information Required for Pre-packaged Common Food

S.N.	Mandatory information	Main requirements
1	Product Name	The product name should reflect the true nature of the food.
2	Ingredients	The ingredient should be listed in descending order (except the ingredient whose content is less than 2%).
3	Net Weight	Min-height of the Net Weight Character The Range of Net Weight (Q)Min-height of the Character/mmQ≤50mL; Q≤50g250mL l kg; Q>1L6
4	Storage Condition	/
5	Country of Origin	/
6	Nutrition Information	I. The mandatory items for the nutrition information are energy, protein, fat, carbohydrate and sodium. Here is a template for your reference. 营养成分表 Nutrition Information 项目/Items每100克（g）/per 100g营养素参考值%/ NRV %能量/energy千焦（kJ）%蛋白质/protein克（g）%脂肪/ fat克（g）%碳水化合物/carbohydrate克（g）%钠/ sodium毫克（mg）% II. If you use nutrition enhancers in your product, the enhanced nutrients should also be added into the table. III. As to the nutrition claim or nutrition function claims for other nutrients except 4+1 items, the claimed nutrients shall also be added into the table.
7	Importer/Distributer/Chinese Agent Information	The information includes "importer, distributor or Chinese agent name", "address", and "phone number or e-mail".
8	Production date and expiry date	I. The print order of the dates shall be confirmed. E.g., you shall confirm if they will be printed by “year/month/day” or “day/month/year” or “month/day/year”. II. Their print location shall be clearly indicated.
9	Others	I. Approval number of overseas manufacturer For dairy products, meat products, aquatic products and bird nest products, the approval number shall be indicated on the Chinese label as well. II. Other special requirements in relevant product GB standard E.g. For sterilized milk, there are several additional labeling requirements in GB 28190-2010, for instance, if the UHT milk is only made of raw bovine (or ovine) milk, the Chinese character of “纯牛（羊）奶” or “纯牛（羊）乳”shall be indicated in the main display panel, closing to the position of product name. Its font size shall be ≥ which for product name, and the font height shall be ≥ 1/5 of main display panel height.

3.1 Example of a Chinese label sticker for a Pre-packaged Common Food

4. Mandatory I nformation Required for Pre-packaged Special Dietary Foods

Special dietary foods in China are specially processed or formulated food that meet the special physical or physiological conditions and/or meet the special dietary needs of diseases, disorders,- include infant foods, food for special medical purposes, sports nutrition food, etc. Meanwhile, the nutrients contents are significantly different with the similar common foods. More interpretations on the importation of special dietary foods can be foundhere.

S.N.	Mandatory information	Main requirements
1	Product Name	Please kindly refer to the requirements of pre-packaged common food we mentioned above.
2	Ingredients
3	Net Weight
4	Storage Condition
5	Country of Origin
6	Importer/Distributer/China agent Information
7	Production date and expiry date
8	Nutrition Information	I. Except energy, protein, fat, carbohydrate and sodium (4+1 items), the other required nutrients in relevant GB standard shall also be indicated. The format is different with that for common food. Here is a template for your reference. 营养成分表 Nutrition Information 项目/Items每100克（g）/per 100g每100千焦（kJ）/per 100kJ能量/energy千焦（kJ）千焦（kJ）蛋白质/protein克（g）克（g）脂肪/ fat克（g）克（g）碳水化合物/carbohydrate克（g）克（g）钠/ sodium毫克（mg）毫克（mg） II. If you use some optional nutrients in your product, the added nutrients should also be added into the table.
9	Edible Method	The edible method, daily or meal intake shall be indicated.
10	Suitable Crowd	The suitable crowd of the products shall be clearly indicated on the label.
10	Others	Additional labeling requirements for each special dietary food in relevant GB standards. E.g., the specific sub-category name of cereal-based complementary foods for infants and young children shall be indicated, such as “婴幼儿高蛋白谷物辅助食品”.
11	Special requirement for infant formula milk powder and foods for special medical purpose (FSMP)	I. These two foods shall be registered under CFDA before being imported to China. And there are very specific requirements on the Chinese label during the registration. Enterprises shall pay attention to relevant regulations when preparing the Chinese label. II. More interpretations for the labeling of infant formula milk powder can be foundhere.

5. Common Mistakes for Chinese Label of Imported Foods

Once you are careless on the labeling requirements, it will be easy for you to make mistakes on the Chinese label generation. Here we listed some common mistakes of Chinese label of imported foods for your references. Please avoid making the same mistakes.

S.N.	Common mistakes
1	Claim health functions on the label for common food.
2	The size of foreign words is bigger than Chinese words.
3	The food name has not indicated the true nature of the food.
4	Claim ‘no sugar’ or ‘low sugar’, but without indicate the content of sugar in nutrition information.
5	The rounding interval and limit value of “0” for the values in nutrition information table are not complaint with GB 28050.
6	……

6. Conclusion

Chinese government attaches great importance to the Chinese label. For imported food, the Chinese label will be checked casually local China Customs. If it is not compliant, the product may be returned or destroyed. Even after the products are distributed in China market, the compliance of the Chinese label is still highly concerned by the public, especially those professional anti-counterfeit people, and a slight carelessness may lead to unnecessary trouble. Therefore, preparing a compliant Chinese label is quite important.

Chinese regulations are strict with the Chinese label, besides the basic requirements we has listed above, specific products also need to be analyzed in accordance with the specific product information, product GB standards and the demand of enterprises. Therefore, it takes time to prepare a compliant Chinese label, and relevant enterprises should be familiar with related laws and regulations.

Our Services

• Review compliance of original label/artwork;

• Review compliance of Chinese label sticker/design a Chinese label sticker;

• Translate the original label/artwork and prepare the Chinese translation;

• Formula Review

• Food Nutrition testing

• Food National Standard (GB) Compliance Testing

• Food regulatory training and consultation

Links:

• Formula Review on Prepackaged Food

• Prepackaged Food Regulatory Compliance Service

• Food National Standard (GB) Compliance Testing