How to Label Your Food Products for China: Complete Compliance Guide
1. The Regulatory Framework for Food Labels in China
Food labeling in China is governed by a hierarchy of mandatory national standards (GB standards) enforced by the State Administration for Market Regulation (SAMR) through local Market Regulation Bureaus, and by the General Administration of Customs (GAC) through the China Inspection and Quarantine (CIQ) at ports of entry.
The three foundational GB standards are:
| Standard | Title | Covers | Last Updated |
|---|---|---|---|
| GB 7718-2011 | National Food Safety Standard — General Rules for the Labeling of Prepackaged Foods | Mandatory information elements, format, language, and presentation of labels | Revised 2025 (effective June 2026) |
| GB 28050-2011 | National Food Safety Standard — General Rules for Nutrition Labeling of Prepackaged Foods | Nutrition information table format, NRV values (National Nutrient Reference Values), nutrient declaration requirements | Revised 2025 (effective January 2027) |
| GB 13432-2013 | National Food Safety Standard — Labeling of Foods for Special Dietary Uses | Additional labeling requirements for infant foods, health foods, FSMP, and sports nutrition | Current edition |
In addition, product-specific GB standards may impose additional labeling requirements. For example, GB 10765 (infant formula) requires a prominent statement that “breast milk is the ideal food for infants.”
2. The 12 Mandatory Label Elements
Every imported prepackaged food product sold in China must bear a Chinese-language label containing the following 12 elements:
- Product Name (食品名称): Must accurately reflect the true nature of the product. Cannot use a “fantasy name” that misleads consumers about the product’s composition or character. GB 7718 requires the product name to be displayed in the most prominent font size on the principal display panel.
- Ingredient List (配料表): All ingredients listed in descending order by weight at the time of formulation. Compound ingredients (e.g., “chocolate coating”) must be accompanied by their own ingredient breakdown in parentheses. Water added in processing must be declared.
- Net Quantity / Volume (净含量): Must be stated in metric units (g, kg, mL, L). For liquid products, volume must be used; for solid products, weight. Drained weight must be declared for products in brine, syrup, or oil.
- Manufacturer Information (生产者信息): Name, address, and contact information of the overseas manufacturer as registered with GAC. Must match exactly the information on the GAC registration certificate.
- Importer / Distributor Information (进口商/经销商信息): Name, address, and contact information of the Chinese entity responsible for importation. Must match the JY (Food Business) License holder name and address.
- Production Date and Shelf Life (生产日期和保质期): Must be clearly printed in the format YYYY-MM-DD or DD/MM/YYYY. “Shelf Life” (保质期) must indicate the duration (e.g., “12 months”) with the “best before” or “use by” date accordingly.
- Storage Conditions (贮存条件): Must be stated in Chinese (e.g., “常温保存,避免阳光直射” — store at room temperature, avoid direct sunlight). Temperature range must be specified for refrigerated/frozen products.
- Country of Origin (原产国): The country where the food was produced, processed, or underwent substantial transformation. Must be clearly stated (e.g., “原产国:法国”).
- GAC Registration Number (境外生产企业注册号): The 18-character GAC registration number of the overseas manufacturing facility (e.g., “C12345678901234567”). Must match the GAC Decree No. 248 registration certificate.
- Food Standard Code (产品标准号): The applicable GB standard code for the product category (e.g., “GB 19295” for frozen pastries). For products where no specific GB standard exists, a qualified enterprise standard (Q/ standard) may be used.
- Food Production License Number (食品生产许可证编号): For domestic products, the SC license number. For imports, the GAC registration number may serve as the production license reference. This field is mandatory on the Chinese label per SAMR requirements.
- Nutrition Information Table (营养成分表): A standardized table format per GB 28050 showing energy, protein, fat, carbohydrate, sodium (mandatory core nutrients), plus any other nutrients for which a claim is made. Format and NRV values are strictly specified.
3. Nutrition Labeling Requirements (GB 28050)
3.1 The Mandatory Nutrition Table Format
The nutrition information table must follow this exact format and include, at minimum, the 5 core nutrients plus energy:
| 项目 Items | 每100克/毫升 Per 100g/mL | 营养素参考值% NRV% |
|---|---|---|
| 能量 Energy | XXXX kJ | XX% |
| 蛋白质 Protein | X.X g | XX% |
| 脂肪 Fat | X.X g | XX% |
| 碳水化合物 Carbohydrate | X.X g | XX% |
| 钠 Sodium | XX mg | XX% |
Additional nutrients must be declared if a claim is made about them (e.g., “high in calcium” requires calcium content and NRV% in the table). Optional nutrients that may be voluntarily declared include dietary fiber, vitamin A, vitamin C, calcium, iron, and zinc.
3.2 Important Changes in GB 28050-2025 (Effective January 2027)
The 2025 revision of GB 28050, which will take full effect on January 1, 2027, introduces several changes that importers should begin preparing for now:
- Updated NRV values: Vitamin D NRV increased from 5 µg to 10 µg; Vitamin E NRV increased from 14 mg to 18 mg; Potassium NRV introduced at 2000 mg
- Front-of-pack (FOP) labeling: A new mandatory FOP symbol indicating whether a product is “high” (red), “medium” (yellow), or “low” (green) in fat, saturated fat, sugar, and sodium. This is a significant departure from the current back-of-pack-only approach.
- Trans fat declaration: If trans fat exceeds 0.3g per 100g/mL, it must be declared separately in the nutrition table. Products containing partially hydrogenated oils must declare trans fat even below this threshold.
- Sugar thresholds: Stricter definitions for “low sugar” (< 2g/100g, down from 5g) and “no added sugar” (no sugars added at any point in processing, including as a component of compound ingredients).
4. Allergen Labeling Requirements
GB 7718 requires the declaration of 8 major allergen categories. Unlike some jurisdictions that require a separate “Contains:” statement, China’s approach requires the allergen to be declared in the ingredient list itself, typically by bolding or using a separate reference statement at the end of the ingredient list.
| # | Allergen | Chinese Name | Commonly Found In |
|---|---|---|---|
| 1 | Wheat (gluten-containing grains) | 小麦(含麸质的谷物) | Bread, pasta, cookies, crackers, soy sauce |
| 2 | Eggs | 蛋类 | Bakery, pasta, mayonnaise, sauces |
| 3 | Milk (dairy) | 乳制品 | Chocolate, bakery, sauces, processed meats |
| 4 | Peanuts | 花生 | Snack foods, sauces, confectionery |
| 5 | Soybeans | 大豆 | Sauces, tofu, texturized vegetable protein, lecithin |
| 6 | Tree nuts | 坚果类 | Confectionery, bakery, snack mixes, pesto |
| 7 | Fish | 鱼类 | Sauces, stock, surimi, Worcestershire sauce |
| 8 | Shellfish | 甲壳类 | Sauces, soup bases, flavorings, stock |
Additionally, the following allergens are recommended for voluntary declaration per GB 7718 guidance: sesame, lupin, mollusks, mustard, celery, and sulfites (> 10 mg/kg). Many importer best-practice guides now recommend declaring these voluntarily to reduce liability risk.
5. Label Format and Design Requirements
5.1 Language Requirements
- All mandatory label elements must be in Chinese characters (简体中文). Pinyin (phonetic) may be added as supplementary text but cannot substitute for Chinese characters.
- Foreign language text is permitted as a supplement, but must correspond accurately to the Chinese text and cannot be larger or more prominent than the Chinese equivalents.
- Units must be in metric system (g, kg, mL, L, kJ, mg, µg).
5.2 Font Size and Legibility
- All mandatory Chinese text must be legible (minimum font size: 1.8mm for labels up to 20 sq cm, 2.0mm for labels 20–80 sq cm, 2.5mm for labels over 80 sq cm).
- The product name must be in the largest font on the principal display panel.
- Nutrition information table minimum font size: 1.8mm.
- Text must contrast sufficiently with the background. Reverse print (white on dark background) must maintain readability.
5.3 Label Format
- Pre-printed labels: Labels can be pre-printed by the overseas manufacturer directly on the packaging, or applied as a sticker label in China before distribution.
- Sticker labels: Allowable. Must be securely affixed and not easily removable. The sticker must cover the entire original language label or be clearly supplementary to it. Stickers applied in China must comply with all GB 7718 requirements (no “sticker over old label” that obscures mandatory information).
- Co-branding: If a Chinese distributor’s brand is added, the original manufacturer must still be declared.
6. Product-Specific Labeling Requirements
6.1 Infant Formula
- Must include the statement “母乳是婴儿最理想的食品” (Breast milk is the ideal food for infants)
- Stage classification (0–6 months, 6–12 months, 12–36 months) must be clearly marked
- Age-appropriate warnings about preparation and storage
- Cannot use images of infants or idealized representations
6.2 Health Foods (保健食品)
- Must display the “蓝帽子” (Blue Cap) health food approval symbol
- CFSA registration number: “国食健注G/J+Year+Serial” (domestic/imported)
- Approved health function claims only (from the CFSA approved claim list)
- Must state: “本品不能代替药物” (This product cannot replace medicine)
- Daily consumption amount and method of use
- Target population and “not suitable for” groups
6.3 Alcoholic Beverages
- Alcohol content must be declared as % vol (e.g., 13.5%vol)
- Mandatory warning: “过量饮酒有害健康” (Excessive drinking is harmful to health)
- If < 0.5% alcohol by volume: cannot be labeled as “beer,” “wine,” or “liquor”
- Nutrition information table required if the product contains > 10% juice or has added sugar
7. Label Approval Process
While China does not have a nationwide pre-approval system for general food labels (unlike the CFSA registration system for special foods), the following best-practice process is recommended:
- Initial draft (2 weeks): Prepare the Chinese label design based on the original-language label. A professional translation service with food labeling specialization should handle the translation to avoid terms that CIQ would reject.
- Internal compliance review (1 week): Verify every mandatory element against GB 7718, GB 28050, and any product-specific standards.
- Third-party label audit (1 week): Engage a SAMR-accredited label review agency (e.g., SGS China, Bureau Veritas China, Intertek China) to conduct a formal compliance audit. Cost: ¥500–2,000 per SKU.
- Pre-submission to local SAMR (optional, 2–4 weeks): Some municipal SAMR offices will pre-review label designs on a voluntary basis, providing a non-binding compliance opinion before the label goes to print.
- CIQ clearance verification: The first shipment provides the ultimate compliance test. Retain the CIQ clearance notice for future reference. If CIQ identifies any label issue, correct immediately and update the label for subsequent shipments.
8. Common Label Compliance Failures
| Failure Type | Frequency | Typical Issue | Consequence |
|---|---|---|---|
| Incorrect translation | 35% | Ingredient name mistranslated; brand name uses incorrect characters; romanticized vs. scientific ingredient name confusion | Detention until corrected; product may need relabeling at importer’s cost |
| Missing mandatory elements | 25% | GAC registration number omitted; storage conditions missing; IOR address incomplete | Product detained; may be returned or destroyed if correction is not feasible at port |
| Nutrition table errors | 20% | Wrong NRV values; kJ/kcal confusion; missing mandatory nutrients; incorrect decimal placement | Corrective label must be applied; product released after reinspection |
| Food additive compliance | 12% | Additive not listed in GB 2760; exceeding maximum use level; additive name doesn’t match GB 2760 terminology | Product considered adulterated; seized and destroyed; importer may face significant fines |
| Allergen omission | 8% | Wheat/gluten not declared; undeclared milk in chocolate; soy not listed as lecithin | Level I recall risk; consumer compensation claims; regulatory penalty |
9. Label Transition Roadmap for 2026–2027
With GB 28050-2025 taking effect in January 2027, now is the time to plan your label transition:
| Timeline | Action |
|---|---|
| Q3 2026 | Complete GB 28050-2025 gap analysis for all your product labels |
| Q4 2026 | Design new format labels with FOP symbols; run pilot production runs with new labels |
| Q1 2027 | Begin transitioning all new production to GB 28050-2025-compliant labels |
| Q2 2027 | Complete transition for all products; cease production of old-format labels |
| Q3 2027 | Last date for old-label inventory to clear CIQ (up to 6-month lead time for some imports) |
10. CG360 Label Compliance Services
CG360’s Food Labeling Compliance team helps food importers get their labels right every time:
- Chinese label design and GB 7718/28050 compliance review
- Ingredient translation with additive GB 2760 cross-reference
- Nutrition table calculation and NRV verification
- Pre-submission label audit by SAMR-accredited reviewers
- CIQ detention response and label correction management
- Multi-SKU label management systems
Contact our Labeling Compliance team at food@china-gateway360.com for a free initial label compliance assessment.
Disclaimer: This guide is for informational purposes only and does not constitute legal advice. Label compliance requirements are specific to product type and jurisdiction. Always engage qualified regulatory professionals for label approval.
Sources: GB 7718-2011; GB 28050-2011/2025; GB 13432-2013; GB 2760-2024; SAMR Food Labeling Guidance (2025 Edition); GAC CIQ Label Inspection Guidelines; SGS China Label Compliance Report 2025.
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