Date marking serves as a critical reference for consumers to assess the freshness and edible shelf life of a food product. Its accurate and compliant labeling is directly linked to a company's regulatory compliance and the establishment of consumer trust in the marketplace.
Released in March 2025 and scheduled to take effect on March 16, 2027, the National Food Safety Standard — General Rules for the Labeling of Prepackaged Foods (GB 7718-2025) and the Administrative Measures for Supervision of Food Labeling (Order No. 100) will introduce detailed and specific requirements for date marking on prepackaged foods. These requirements are designed to ensure that date information is readily locatable, clearly legible, and easily calculable for consumers.
Food businesses will be required to systematically upgrade date marking protocols for prepackaged products. Nine key updates have been identified to help enterprises complete packaging transitions before the March 16, 2027 compliance deadline.
Order of Presentation
The date shall be clearly indicated in the order of year, month, and day.
Location of Date Marking
The date shall be placed in a designated, standalone area on the principal display panel of the packaging.
Where the date is not located on the principal display panel, the principal display panel shall bear a statement indicating the specific location where the date can be found, such as "See [specific part of package] for date."
Color Contrast
The date shall be printed in a manner that ensures clear legibility through sufficient color contrast, such as black text on a white background.
Character Height and Width Requirements
The character height of the date shall be no less than 3.0 millimeters. For packages where the largest surface area is less than 35 square centimeters, the character height shall be no less than 2.0 millimeters.
The ratio of character height to character width shall be no greater than 3.
Content of Date Marking
The production date and the expiration date of the prepackaged food shall be clearly indicated in the order of year, month, and day.
Where the shelf life is six months or longer, or the largest surface area of the package is 20 cm² or less, only the shelf life and the expiration date may be indicated.
Determination of Production Date and Expiration Date
Determination of Production Date
The production date of a prepackaged food shall be determined based on the completion of the relevant production process.
Where the smallest sales unit consists of a single layer of packaging, the date on which the packaging process is completed shall be deemed the production date.
Where the smallest sales unit consists of multiple layers of packaging, the date on which the packaging process for the layer in direct contact with the food is completed shall be deemed the production date.
Where the food is required to undergo further processing such as sterilization or fermentation after packaging, the date on which such subsequent process is completed may be deemed the production date.
Principles for Expiration Date Labeling
Where the smallest sales unit contains multiple independently packaged food items, the expiration date indicated shall be no later than the earliest expiration date among such items. Alternatively, the expiration date of each individual item may be labeled separately.
Calculation of Expiration Date: The starting point for calculating the expiration date may be designated as either the production date or the day immediately following the production date.
Exemptions from Date Marking Requirements
a. Provided that the production date is indicated, the following categories of prepackaged foods are exempt from the requirement to label the shelf life and expiration date:
Wine and alcoholic beverages with an alcohol content of 10% vol or greater;
Vinegar;
Edible salt;
Solid sugars;
Monosodium glutamate (MSG).
Where national food safety standards provide otherwise, such provisions shall prevail.
b. Provided that the lot number is indicated, wine and alcoholic beverages with an alcohol content of 10% vol or greater are exempt from the requirement to label the production date.
Voluntary Declaration of Consumption Shelf Life
To guide consumers in the proper consumption of food after purchase and to minimize food waste, a "consumption shelf life" may be voluntarily declared on the label, based on the characteristics and processing methods of the food. This date shall represent the final date by which the food should be consumed when stored under the conditions specified on the label.
How to Label Imported Foods
If the original packaging of an imported prepackaged food does not indicate the production date, the production date shall be calculated and declared based on the shelf life and the expiration date, or other relevant information shown on the original packaging. For products with a shelf life of six months or longer, only the shelf life and the expiration date need to be indicated.
REACH24H Reminder
Transition period update (June 2026): As of the date of publication, GB 7718-2011 remains the legally binding standard for prepackaged food labeling in China. GB 7718-2025 and Order No. 100 will officially take effect on March 16, 2027. Businesses are advised to use the remaining transition period to review and update their date marking practices.
Date format is now strictly required as Year-Month-Day. The previous allowance for various date formats has been adjusted. The sequence of year, month, and day must be explicitly followed when labeling dates.
The placement and color of date markings affect packaging design. Therefore, enterprises should prepare in advance and implement changes as early as possible.
Voluntary declaration of a consumption shelf life presents an opportunity, but also carries compliance risks. While this option is favorable for businesses, it must be clearly understood that the Food Safety Law prohibits the sale of any food beyond its shelf life. Declaring a consumption shelf life does not extend the legal sales period.
The consumption shelf life is not equivalent to the regular shelf life. Companies must avoid confusing these two concepts to prevent consumer complaints, challenges from food safety "strike-force" litigants, or regulatory penalties.
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