How to Label Imported Food in China: 2026 Guide for Foreign Companies
1. Introduction: Why Food Labeling Compliance Matters in China
China is the world’s largest importer of food by value, with imports exceeding USD 170 billion annually. For foreign food manufacturers, gaining access to this enormous market hinges not only on product quality but also on strict adherence to China’s comprehensive food labeling regulations. Unlike many Western markets, China mandates that every imported food product carry a Chinese-language label before it can pass customs and enter retail channels. A single labeling error — a missing translation, an improperly formatted nutrition table, or a disallowed health claim — can result in detention at the border, costly rework, product recall, fines, and even blacklisting of the importing company.
This guide provides foreign exporters, compliance managers, and quality assurance teams with a comprehensive, practical roadmap to compliant food labeling under China’s 2026 regulatory framework. We cover the core standards (GB 7718, GB 28050, GB 2760), every mandatory label element, allergen and nutrition requirements, special rules for high-risk categories, the expected GB 7718 revision, and a step-by-step workflow for getting labels approved.
2. China’s Food Labeling Regulatory Framework
China’s food labeling regulations are built on a hierarchy of national standards, administrative measures, and sector-specific rules. The three foundational standards that every exporter must know are detailed below.
| Standard | Full Name | Scope | Key Requirements |
|---|---|---|---|
| GB 7718-2011 | National Food Safety Standard — General Standard for the Labeling of Prepackaged Foods | All prepackaged foods (excluding health foods, infant food, and special medical foods which have their own standards) | Mandatory label elements, language requirements, format, allergen labeling, date marking, ingredient declaration rules |
| GB 28050-2011 | National Food Safety Standard — General Standard for Nutrition Labeling of Prepackaged Foods | All prepackaged foods that bear nutrition claims or are required to display a nutrition facts panel | Mandatory nutrients (energy, protein, fat, carbohydrate, sodium), NRV percentages, format, conditions for nutrition claims |
| GB 2760-2024 | National Food Safety Standard — Standard for Uses of Food Additives | All foods containing additives | Permitted additives, maximum usage levels, labeling of additives by category and name |
In addition to these cross-cutting standards, specific product categories are governed by their own labeling rules. These include GB 13432 for prepackaged foods for special dietary uses, GB 16740 for health foods (bao jian shi pin), GB 10765-10770 series for infant formulas, and the Organic Product Certification Management Measures for organic-labeled foods. Exporters must identify which standards apply to their specific product type and ensure compliance with all overlapping requirements.
The primary enforcing agencies are the State Administration for Market Regulation (SAMR), the General Administration of Customs (GAC), and the National Health Commission (NHC), which publishes the GB standards. Label compliance is checked at multiple points: during overseas manufacturer registration (GAC Decree 248), during customs clearance document review, during physical inspection and lab testing, and during post-market surveillance by local SAMR offices.
3. Mandatory Elements on Imported Food Labels
Under GB 7718-2011, every prepackaged food imported into China must display the following ten categories of information on its label. Each element has specific formatting, placement, and content rules that must be followed precisely.
3.1 Product Name (食品名称)
The product name must accurately reflect the true nature of the food. It should be displayed prominently on the principal display panel. If a national standard, trade standard, or industry standard defines a name for the product, that standard name must be used. Fanciful or brand names are permitted only alongside the standard/true name in the same font size. For imported products, the Chinese name must match or closely reflect the original foreign name and the product’s declared contents.
3.2 Ingredient List (配料表)
All ingredients must be listed in descending order by weight or volume at the time of formulation. Additives must be declared using their approved Chinese names as listed in GB 2760, their INS numbers (international numbering system), or both. Composite ingredients (ingredients made from two or more sub-ingredients) must have their own sub-ingredients listed in parentheses. Water, processing aids, and carry-over additives may require specific treatment. The ingredient list is one of the most common sources of labeling rejections for imported foods.
3.3 Net Content and Specifications (净含量和规格)
The net content must be declared in Chinese legal units of measurement (grams, milliliters, etc.) using the format “净含量:” followed by the quantity. For solid foods packed in liquid medium, both the total net weight and the drained weight must be stated. The font size of the net content declaration must meet minimum height requirements relative to the package surface area (specified in GB 7718 Appendix C).
3.4 Manufacturer and Distributor Information (生产者、经销者的名称和地址)
The label must include the name, address, and contact information of the foreign manufacturer or packer. In addition, the name, address, and contact details of the Chinese importer or distributor (the entity legally responsible in China) must be provided. The Chinese distributor’s information must appear in Chinese and must correspond to a legally registered company in China. Many foreign exporters use a sticker label to add this information to pre-printed packaging.
3.5 Production Date and Shelf Life (生产日期和保质期)
The production date (生产日期) and shelf life (保质期) must be clearly stated. The format must follow Chinese conventions: “生产日期: YYYY年MM月DD日” or similar. If the product has a best-before date instead of a shelf life, the label must state “保质期至: YYYY年MM月DD日” or both the shelf life duration and the best-before date. Durability dating must be unambiguous and visible. A common mistake is using only a Julian date or a format unfamiliar to Chinese inspectors.
3.6 Storage Conditions (贮存条件)
Storage instructions (贮存条件) must be provided in Chinese, such as “常温保存，避免阳光直射” (store at room temperature, avoid direct sunlight) or “冷藏保存：0–4°C” (refrigerated storage: 0–4°C). Special conditions, such as freezing requirements or humidity control, must be clearly stated.
3.7 Country of Origin (原产国)
The country of origin (原产国) must be declared. For processed foods, the country of origin is generally the country where the last substantial transformation occurred. For products with ingredients from multiple countries, the origin of the final product applies. The statement “原产国: [country name in Chinese]” is required.
3.8 Food Additive Listing (食品添加剂)
All food additives used in the product must be listed in the ingredient list with their specific functional category (e.g., 增稠剂 — thickener, 防腐剂 — preservative, 抗氧化剂 — antioxidant) followed by the specific additive name from GB 2760. Only additives approved under GB 2760-2024 are permitted. The use levels must not exceed the maximum limits specified for the food category.
3.9 Allergen Information (致敏物质)
Under GB 7718-2011, allergen labeling is recommended but not mandatory. However, the revised GB 7718 (expected to be enforced in 2025–2026) is widely expected to make allergen labeling compulsory. The current standard lists eight major allergen groups: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk (including lactose), and tree nuts. Sulfites added at levels above 10 mg/kg must also be declared. Forward-looking exporters should already include allergen declarations voluntarily to prepare for the revision.
3.10 Nutrition Facts Panel (营养成分表)
The nutrition facts panel (营养成分表) must follow the format specified in GB 28050-2011. It is required for all prepackaged foods except certain exemptions (raw meat, poultry, fish, vegetables, fruits, eggs, bottled water, tea, alcoholic beverages, and condiments with small package sizes). The panel is discussed in detail in Section 5 below.
4. Chinese Language Requirements
This is the single most important rule: all mandatory label information on imported food sold in China must be in Chinese. The Chinese text must be accurate, grammatically correct, and use simplified Chinese characters (not traditional Chinese used in Taiwan or Hong Kong). Bilingual labels (Chinese plus the original language) are permitted and common, but the Chinese text cannot be smaller in font size than the foreign text. Any claim, instruction, or declaration that appears in a foreign language must also appear in Chinese.
There is no legal requirement that labels be pre-printed in Chinese by the overseas manufacturer. It is perfectly acceptable — and very common — to apply a Chinese-language sticker label to the original foreign packaging before the product enters the Chinese market. However, the sticker must be permanent, legible, and tamper-evident. It cannot cover critical information such as the original production date or lot number. Some retailers and distributors in China prefer pre-printed labels for aesthetic reasons, and certain premium product categories (such as wine and spirits) often opt for pre-printed back labels for a more polished appearance.
5. Nutrition Facts Panel Requirements
Under GB 28050-2011, the nutrition facts panel (营养成分表) must be presented in a standardized table format. The panel must list energy and four core nutrients as mandatory items:
| Component | Chinese Name | Unit | NRV (%) | Notes |
|---|---|---|---|---|
| Energy | 能量 | kJ (kilojoules) | Yes | Must be in kJ, not kcal (though kcal may appear alongside). 1 kcal = 4.184 kJ |
| Protein | 蛋白质 | g | Yes | Standard NRV = 60 g |
| Fat | 脂肪 | g | Yes | Standard NRV = ≤60 g |
| Carbohydrate | 碳水化合物 | g | Yes | Standard NRV = 300 g |
| Sodium | 钠 | mg | Yes | Standard NRV = 2000 mg |
In addition to the five mandatory items, the manufacturer may voluntarily list other nutrients such as dietary fiber, cholesterol, saturated fat, trans fat, sugars, vitamins, and minerals. However, if any nutrition claim is made about a nutrient (e.g., “低脂” — low fat, or “高钙” — high calcium), that nutrient must appear in the nutrition facts panel. The panel must express values both per 100 g / 100 mL (mandatory) and optionally per serving. The NRV (营养素参考值) percentage must be calculated based on the Chinese NRV values specified in GB 28050-2011, which differ from U.S. or EU reference values in several cases.
6. Sticker Labels vs. Pre-Printed Labels
Foreign companies entering the Chinese market for the first time often wrestle with the decision to apply Chinese labels via sticker or to pre-print labels during the manufacturing process. Each approach has distinct advantages and drawbacks.
Sticker Labels (粘贴标签)
- Advantages: Lower upfront cost; flexible — allows different labels for different markets from the same base product; easy to update when regulations change; does not require retooling of the production line; ideal for small trial shipments.
- Disadvantages: Potential for stickers to peel off during transport; may look less premium; can be rejected by high-end retailers; requires a reliable Chinese partner to print and apply stickers.
- Best for: First-time exporters, small-to-medium volumes, products with frequent packaging changes, and any product subject to pending regulatory revisions.
Pre-Printed Labels (预印刷标签)
- Advantages: Professional appearance; tamper-evident; no peeling risk; preferred by large retailers and e-commerce platforms; reduced labor cost for application.
- Disadvantages: Higher minimum order quantities; costly reprints if regulations change; longer lead times; requires accurate forecasting.
- Best for: High-volume products, premium brands, products with stable formulations and packaging, well-established exporters with predictable demand.
7. Special Labeling Rules for Key Product Categories
7.1 Infant Formula (婴幼儿配方食品)
Infant formula is one of the most strictly regulated food categories in China. Labels must comply with GB 10765 (infant formula), GB 10767 (follow-on formula), and GB 10769 (cereal-based complementary foods). In addition, the SAMR requires formula registration (配方注册) before products can be imported. Labels cannot include any images of infants that idealize the product, cannot claim that the product is “breast milk substitute” in a misleading way, and must include a statement that “母乳是最好的婴儿食品” (breast milk is the best food for infants). The age-stage designation must be clearly stated.
7.2 Health Foods (保健食品)
Health foods (or functional foods) require a “Blue Hat” approval (保健食品批准文号) and must display the blue hat logo and approval number on the label. Health claims are strictly limited to the 27 approved functional claim categories published by SAMR. Labels must include a disclaimer such as “本品不能替代药物” (this product cannot replace medication). Dosage instructions, target population, and contraindications must be stated clearly.
7.3 Alcoholic Beverages (酒类)
Imported alcoholic beverages must comply with GB 2757 (distilled spirits) or GB 2758 (fermented alcoholic beverages). Labels must declare the alcohol content as % vol in Chinese. For wines, the vintage, grape variety, and appellation may be declared if substantiated. Health warnings such as “过量饮酒有害健康” (excessive drinking is harmful to health) are required. Imported beer, wine, and spirits must provide a Chinese back label covering all mandatory elements.
7.4 Organic Products (有机产品)
To use the term “有机” (organic) on a label in China, the product must be certified by a China Organic Certification body approved by the Certification and Accreditation Administration (CNCA). Foreign organic certifications (USDA Organic, EU Organic, JAS, etc.) are not sufficient on their own — the product must also carry the China Organic Certification logo and the 17-digit organic code. Without this, the word “有机” cannot appear on the label, even if the product is organically certified in its home market.
7.5 GMO Foods (转基因食品)
China has strict mandatory labeling requirements for genetically modified organisms (GMOs). Any food product containing GMO ingredients must be clearly labeled as “转基因” (genetically modified) or “含转基因成分” (contains GMO ingredients). China uses a “positive list” approach for approved GMOs. Even trace amounts of unapproved GMOs can result in product detention and destruction. For products from countries that produce GMO crops (soybean, corn, rapeseed, cottonseed, papaya, etc.), non-GMO certification is often required even if the GMO content is below the threshold used in other markets.
8. GB 7718 Revision: What to Expect in 2025–2026
The long-awaited revision of GB 7718 has been under development for several years and is expected to take effect in late 2025 or early 2026. The draft revision (GB 7718-20XX) circulating for public comment includes several significant changes that foreign exporters must prepare for:
- Mandatory allergen labeling: Allergen declaration will change from recommended to mandatory. The list of required allergens is expected to expand to include 10+ categories.
- Digital labeling: Permission to use QR codes or other digital means to supplement label information, though all mandatory elements must still appear physically on the package.
- Clearer ingredient declaration rules: More detailed requirements for declaring composite ingredients and additives.
- Increased font size requirements: Minimum font sizes for mandatory declarations may be increased to improve readability.
- Date marking: Stricter rules on the format and placement of production dates and shelf life.
- Industry-specific annexes: New annexes covering labeling rules for specific product categories such as wine, chocolate, and condiments.
9. Common Labeling Mistakes and How to Avoid Them
Based on analysis of customs rejection data and compliance audits, here are the most frequent label errors made by foreign exporters:
| # | Mistake | Why It Happens | Solution |
|---|---|---|---|
| 1 | Incorrect NRV values or missing NRV column | Copying from US/European nutrition panel without converting to Chinese NRV | Use a verified NRV calculator; have the panel reviewed by a Chinese regulatory consultant |
| 2 | Missing or incorrect Chinese importer information | Assuming the distributor’s info can be added later or omitted | Ensure every label includes the full legal name and address of the registered Chinese importer |
| 3 | Improper additive names or unapproved additives | Using trade names or INS numbers without the GB 2760 Chinese name | Cross-reference all additives against the latest GB 2760 list; use only approved functional category + name format |
| 4 | Production date not in Chinese format | Using Western date format (MM/DD/YYYY or DD/MM/YYYY) | Always use “YYYY年MM月DD日” or “YYYY/MM/DD” format |
| 5 | Missing country of origin or incorrect Chinese name | Assuming origin is obvious, or using a translated name not officially recognized | Use the official Chinese country name from the GAC country code list |
| 6 | Health claims without Blue Hat approval | Using functional claims (e.g., “supports immunity”) on regular food products | Only permitted for registered health foods; use only descriptive claims on regular foods |
| 7 | Inconsistent translation of product name | Translating the product name differently on different parts of the label | Standardize the Chinese product name across all label elements and customs declarations |
| 8 | Organic claims without China Organic certification | Assuming foreign organic certification is accepted in China | Obtain CNCA-recognized organic certification before making organic claims |
10. Consequences of Non-Compliance
The consequences of non-compliant food labeling in China can be severe and should not be underestimated. The regulatory enforcement environment has become significantly stricter since the 2015 Food Safety Law amendments and the implementation of GAC Decree 249 in 2022.
- Product Detention at Customs: Non-compliant labels are the most common reason for imported food to be held at customs. The product will be placed in a bonded warehouse pending re-labeling or re-export. Storage and handling fees accumulate quickly.
- Forced Re-Labeling: If the violation is correctable (e.g., a missing sticker label), customs may allow supervised re-labeling at the importer’s expense. However, this requires a licensed facility and GAC supervision.
- Product Recall: If non-compliant products have already entered the market, SAMR can order a mandatory recall. The recall process involves public notification, logistics, disposal, and reporting — all at the importer’s cost.
- Administrative Fines: Fines under the Food Safety Law range from RMB 50,000 to RMB 2,000,000 depending on the severity and nature of the violation. Repeat offenses attract maximum penalties.
- Blacklisting: Serious or repeated violations can result in the foreign manufacturer or Chinese importer being placed on a public blacklist (失信名单). Blacklisted entities face increased inspection rates, longer clearance times, and potential suspension of import privileges.
- Reputational Damage: In the age of social media, a food safety incident related to labeling (such as undisclosed allergens) can cause irreparable brand damage in the Chinese market.
11. Practical Workflow for Getting Labels Approved
To minimize the risk of label rejection, follow this proven six-step workflow adopted by successful food exporters to China:
- Pre-Ingress Compliance Review: Before printing any labels, compile all product information (ingredients, additives, nutritional data, manufacturer details, origin) and have the label draft reviewed by a qualified Chinese regulatory consultant or a third-party label compliance service. Many international testing companies (SGS, Bureau Veritas, Intertek) offer China label review services.
- Cross-Reference Against GB Standards: Verify every element against GB 7718, GB 28050, and GB 2760. Check that all additives are on the approved list, NRV percentages are correctly calculated, and no prohibited claims are made.
- Translation Quality Assurance: Have the Chinese translation performed or verified by a native Chinese speaker with food industry knowledge. Machine translations are unreliable for regulatory text. The Chinese name of the product should also be checked for cultural appropriateness and trademark conflicts.
- Sample Label Submission (Optional): Some customs districts (e.g., Shanghai, Guangzhou, Tianjin) allow pre-submission of label content for review before the physical product arrives. While not a formal approval, this can flag obvious issues early. Check with your importer or customs broker.
- Print a Small Test Batch: For sticker labels, print a small batch and have the Chinese importer apply them to a test shipment. This allows you to identify application issues (peeling, misalignment, poor adhesion) before scaling up.
- Maintain a Label Change Log: Keep a detailed record of every label version, including the effective date and the regulatory change that prompted the revision. This is invaluable for audits and for tracking compliance across multiple SKUs.
12. Conclusion
Navigating China’s food labeling regulations is one of the most challenging yet essential aspects of exporting food to the Chinese market. The combination of detailed technical standards, mandatory Chinese-language requirements, and strict enforcement creates a compliance landscape that demands careful attention and specialized expertise. However, the rewards are substantial: China’s food import market continues to grow, and consumers increasingly seek high-quality imported products with transparent, accurate labeling.
By understanding the requirements of GB 7718-2011, GB 28050-2011, and GB 2760-2024; by ensuring every mandatory label element is present and correctly formatted; by preparing for the upcoming GB 7718 revision; and by following a systematic label approval workflow, foreign companies can significantly reduce the risk of customs detention, protect their brand reputation, and build a sustainable import business in China. When in doubt, invest in professional label compliance review — the cost of prevention is always lower than the cost of a customs rejection.
China Gateway 360 — Knowledge Hub for Foreign Businesses Operating in China. This guide is for informational purposes and does not constitute legal advice. Consult with qualified legal and regulatory professionals for product-specific compliance decisions.
