The State Administration for Market Regulation (SAMR) and the National Health Commission (NHC) jointly published the final text on 15 March 2025, following a four-year revision process that began in 2021. Foreign food manufacturers and importers now face a tight 168-day window to redesign labels, reformulate ingredient lists, and clear existing stock before penalties apply.
Non-compliance carries fines of up to RMB 50,000 per product SKU under Article 125 of the Food Safety Law (食品安全法 shípǐn ānquán fǎ), plus mandatory product recalls. Customs clearance delays at major ports such as Shanghai, Shenzhen, and Tianjin have already increased by an estimated 22% year-on-year for goods without updated labels, according to SAMR enforcement data from Q1 2025.
The new standard introduces mandatory allergen labeling for 14 categories, up from the previous 8 categories under GB 7718-2011. Milk, eggs, peanuts, tree nuts, soybeans, wheat, fish, and shellfish are joined by sesame, mustard, celery, buckwheat, lupine, and molluscs — a reflection of evolving allergy patterns in the Chinese population, which has seen a 3.2x increase in reported food allergies among children under 14 since 2015, per a 2024 Peking Union Medical College study.
Text size requirements have tightened: the minimum font height for production date, expiration date, and ingredient lists is now 1.8mm, up from the previous advisory standard of 1.2mm. This affects approximately 65% of imported food labels in current circulation, which SAMR found to use fonts below the new threshold during a 2024 audit of 12,000 SKUs across 34 customs checkpoints.
Key Changes in the New Labeling Standards
The GB 7718-2025 revision consolidates three previous SAMR circulars — 2019 No. 72, 2021 No. 10, and 2023 No. 14 — into a single, enforceable standard. Foreign executives must understand four structural changes that directly impact label production costs, shelf-life management, and legal liability.
Mandatory bilingual labeling: All mandatory label information must appear in Chinese (中文 zhōngwén). Foreign-language text is permitted only as supplementary translation and must not exceed the font size of the Chinese version. Misalignment between the two versions — a common compliance gap in 2024 SAMR inspections — is now treated as a labeling violation, with penalty fines applicable per SKU.
Net quantity placement: The net quantity declaration (净含量 jìng hánliàng) must now appear in the same visual field as the product name on the principal display panel. Previously, it could appear on the back or side panel. Non-compliant layouts trigger automatic rejection at customs inspection, adding 14–21 days to clearance times, per Shanghai Customs data.
Expiration date format and clarity: Dates must follow the ISO 8601 format (YYYY-MM-DD) and must be printed with a minimum font height of 1.8mm. Laser-printed or embossed dates — widely used by European and Australian exporters — must be legible without magnification. SAMR estimates 30% of imported date codes currently fail this legibility test.
Ingredient declaration hierarchy: All ingredients added during processing, including processing aids that leave residues above 0.1 mg/kg, must now be listed. Previously, processing aids below 0.5 mg/kg could be omitted. This change alone affects 20,000+ imported food SKUs that use enzyme treatments, clarifying agents, or anti-foaming agents, according to the China Import-Export Food Association (CIEFA).
Allergen Labeling Requirements Expanded
The allergen labeling expansion from 8 to 14 categories represents the most operationally complex change for foreign food companies. The new mandatory disclosure list under GB 7718-2025 Section 4.3 includes:
| Allergen Category | GB 7718-2011 (Previous) | GB 7718-2025 (New) | Change Type |
|---|---|---|---|
| Milk (乳 rǔ) | Mandatory | Mandatory | Unchanged |
| Eggs (鸡蛋 jīdàn) | Mandatory | Mandatory | Unchanged |
| Peanuts (花生 huāshēng) | Mandatory | Mandatory | Unchanged |
| Tree nuts (树坚果 shù jiānguǒ) | Mandatory | Mandatory | Unchanged |
| Soybeans (大豆 dàdòu) | Mandatory | Mandatory | Unchanged |
| Wheat (小麦 xiǎomài) | Mandatory | Mandatory | Unchanged |
| Fish (鱼 yú) | Mandatory | Mandatory | Unchanged |
| Shellfish (贝类 bèilèi) | Mandatory | Mandatory | Unchanged |
| Sesame (芝麻 zhīmá) | Voluntary | Mandatory | New mandatory |
| Mustard (芥末 jièmò) | Voluntary | Mandatory | New mandatory |
| Celery (芹菜 qíncài) | Voluntary | Mandatory | New mandatory |
| Buckwheat (荞麦 qiáomài) | Voluntary | Mandatory | New mandatory |
| Lupine (羽扇豆 yǔshàndòu) | Not required | Mandatory | New category |
| Molluscs (软体动物 ruǎntǐ dòngwù) | Not required | Mandatory | New category |
The inclusion of lupine and molluscs is notable because these are rarely processed in Chinese domestic food manufacturing but appear frequently in imported products — lupine flour in European baked goods and molluscs in Mediterranean seafood sauces. SAMR specifically targeted these gaps after a 2023 incident where a Shanghai consumer experienced anaphylaxis from undeclared lupine in an Italian pasta product.
Cross-contamination warnings remain voluntary under GB 7718-2025, but SAMR strongly recommends “May contain [allergen]” statements where shared equipment is used. Companies that omit such warnings and face a contamination incident now assume strict liability — a shift from the previous negligence-based standard. Legal experts at the China Food Law Association estimate this could increase liability exposure by up to 400% per incident, given the strict product liability framework under the PRC Civil Code.
Implementation Timeline and Compliance Deadlines
The compliance timeline under GB 7718-2025 follows a phased structure that foreign executives must map precisely against production lead times, shipping schedules, and inventory rotation cycles.
Phase 1 (1 September 2025): All new production must comply fully with GB 7718-2025. Goods produced on or after this date must carry the new label format, including the expanded allergen list, 1.8mm minimum font height, and bilingual net quantity placement. This applies to both domestic production and imported goods at the point of manufacture.
Phase 2 (1 March 2026): End of the grace period for existing inventory. Goods produced before 1 September 2025 but still in the distribution chain — including in transit, at customs, or on retail shelves — may be sold through to the consumer without re-labeling, provided they carry compliant labels under the previous GB 7718-2011 standard. After this date, all products in the Chinese market must meet the new standard, regardless of production date.
Phase 3 (1 September 2026): Full enforcement begins for all products, including goods with long shelf lives (e.g., frozen foods, canned goods, and dried products with shelf lives exceeding 12 months). SAMR has indicated it will conduct a nationwide inspection blitz during Q4 2026, targeting 50,000+ retail locations across all 31 provinces. Non-compliant products found during inspections will be subject to seizure, fines, and public naming on SAMR’s blacklist (黑名单 hēimíngdān).
Foreign food exporters should note that customs clearance risk is highest between September 2025 and March 2026, because inspectors at ports will encounter a mix of old-standard and new-standard labels. SAMR has trained 4,200 customs officers on the new standard since January 2025, but inconsistency in enforcement across ports is expected. The Shanghai Customs College has recorded 18% variance in inspection pass rates for new-standard labels across different ports during pilot testing in Q2 2025.
Cost implications are significant. Re-labeling a typical imported food SKU — including graphic design, translation certification, printing, and artwork re-approval — costs between RMB 12,000 and RMB 25,000 per variant, according to a 2024 survey by the American Chamber of Commerce in Shanghai. For a company with 200 SKUs, this translates to a one-time compliance cost of RMB 2.4 million to RMB 5 million (approximately USD 330,000 to USD 690,000). Packaging material waste adds another 15–20% to these figures, depending on minimum order quantities at printing vendors.
Next Steps for Foreign Food Executives
