"White Peach Oolong Tea" penalized for containing no actual white peach. "Sour Milk Drink" — is it fermented milk or merely a beverage? "Beef Meatballs" found to consist primarily of pork. These recurring controversies over food product naming underscore the critical importance of regulatory compliance in this area.
Released in March 2025, 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) introduce a significantly more stringent regulatory framework governing the naming of conventional foods. Both regulations are scheduled to take effect on March 16, 2027, replacing the current GB 7718-2011 standard. Businesses have until that date to achieve full compliance.
This article examines the new regulatory requirements and provides an in-depth analysis of the naming rules applicable to conventional foods from the following five dimensions.
Use of the Preferred Attribute Name
The name indicating the true nature of the food shall be prominently displayed on the food label in a conspicuous position.
The name shall be selected from those specified in national standards, industry standards, local standards, or names published in official regulatory announcements.
The name used shall be one that is not likely to be misunderstood or cause confusion.
Considerations When Using Novel or Coined Names
Names such as "coined names," "fanciful names," "transliterated names," "regional colloquial names," or "brand names" may be displayed on the same presentation panel as the food's true attribute name.
Where any such name contains text or wording that is likely to mislead consumers or cause confusion regarding the true nature of the food, a clarifying statement shall be displayed in close proximity to the attribute name on the same presentation panel. Such clarifying statement shall be presented in a font and color identical to that of the attribute name, and its character height shall not exceed that of the attribute name.
Considerations When Ingredients Are Referenced in the Food Name
Where an ingredient or component is referenced in the name of a food, the quantity of such ingredient or component added, or its content in the finished product, shall be declared.
For foods manufactured from animal-derived raw materials, where the food name indicates the presence of livestock meat, poultry meat, or aquatic animal products, such raw material(s) shall constitute the primary ingredient(s) of the food.
Where the name references only one such raw material, all of the corresponding ingredient used in the food shall be derived exclusively from that specific type of livestock meat, poultry meat, or aquatic animal product.
Where the name references two or more such raw materials, the raw materials used shall be listed in the food name in descending order of their quantity added.
For foods manufactured from plant-derived raw materials that are intended to imitate or resemble animal-derived foods, the food name shall be prefixed with or include designations such as "Imitation," "Plant-Based," "Vegetarian," or "[Name of Plant]."
Considerations When Using Flavorings and Flavor Enhancers
Where a food contains no added quantity of a particular ingredient, and the flavor of such ingredient is derived solely from the use of food flavorings or flavor enhancers, and further where such ingredient flavor is referenced in the food name, the food name shall be prefixed with or include designations such as "[Flavor] Flavored" or "[Flavor] Taste."
Where the flavor of a particular ingredient or food is derived solely from the use of food flavorings or flavor enhancers, only pictorial representations other than photographs of the actual referenced ingredient or food shall be permitted. Any such pictorial representation shall be accompanied by a conspicuous statement in close proximity, such as "Image for Flavor Reference Only."
Prohibited Practices
Food labeling shall not include any of the following:
Claims relating to the prevention or treatment of diseases;
False, deceptive, misleading, or exaggerated descriptions;
Content contrary to scientific consensus, public order and good morals, or that promotes feudal superstition;
Designations such as "Specially Supplied," "Exclusively Supplied," or "Internally Supplied" for Party or government organs or the military;
Any other content prohibited by laws, regulations, rules, or national food safety standards;
Health benefit or function claims — whether explicit or implied — on the labels of foods other than health foods;
Statements declaring or implying suitability for consumption by minors, in the absence of a legal basis under laws, regulations, rules, national food safety standards, or industry standards, where such statements would deceive or mislead consumers.
REACH24H Recommendation
As the primary vehicle for conveying product information to consumers, the food name must accurately communicate the core characteristics and ingredient composition of the product, while strictly adhering to all applicable regulatory requirements.
REACH24H Reminder
As of June 2026, GB 7718-2011 remains the legally binding standard. GB 7718-2025 and the Administrative Measures for Supervision of Food Labeling will officially take effect on March 16, 2027. Businesses are advised to use the current two-year transition period (March 2025 – March 2027) to review and update their labeling practices accordingly. Proactive compliance now will help avoid last-minute reformulation costs and enforcement risks when the new rules become mandatory.
We recommend that food manufacturers take the following steps during the transition period:
Audit existing product names against the new naming rules — identify any products whose names may be non-compliant under GB 7718-2025;
Review ingredient disclosure practices — ensure that any ingredient referenced in a product name is supported by proper quantity declarations and primary-ingredient verification;
Update labeling artwork and packaging in phases to avoid supply chain disruption, prioritizing products closest to the compliance deadline;
Monitor enforcement trends — regulatory authorities may begin issuing guidance and conducting inspections ahead of the March 2027 deadline.
Regulatory References
1. Food Safety Law of the People's Republic of China
2. Regulations on the Implementation of the Food Safety Law of the People's Republic of China
3. Administrative Measures for Supervision of Food Labeling (Order No. 100 of the State Administration for Market Regulation)
4. National Food Safety Standard — General Rules for the Labeling of Prepackaged Foods (GB 7718-2011) — Currently in force; to be superseded by GB 7718-2025 on March 16, 2027
5. National Food Safety Standard — General Rules for the Labeling of Prepackaged Foods (GB 7718-2025) — Effective March 16, 2027
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