Imagine purchasing food for family members who may have allergies to peanuts, milk, or wheat.
Each time consumers select a product, ambiguous statements such as "may contain allergens" compel them to conduct a "safety review" by carefully scrutinizing the ingredient list. This situation represents the daily survival challenge faced by individuals with allergies and their families.
The good news, however, is that China has taken another major step forward in food labeling management, directly targeting a long-standing concern that has caused significant distress for countless families managing food allergies.
With the issuance of the National Food Safety Standard — General Standard for the Labeling of Prepackaged Foods (GB 7718-2025), effective March 16, 2027, the labeling of allergenic substances in prepackaged foods will no longer be left to discretion. Rather, such labeling will be required to be clear, specific, and mandatory.
The Importance of Clear Allergen Labeling for Consumers
What we commonly refer to as food allergy is actually an abnormal and aggressive immune system response to certain components in food — primarily proteins. This reaction can range from mild skin itching and rashes to severe, life-threatening conditions such as difficulty breathing, throat swelling, and a sudden drop in blood pressure — a condition known as anaphylactic shock. For individuals with food allergies, the most effective defense is to completely avoid foods containing the allergens to which they are sensitive.
Therefore, the food label, as the primary channel through which consumers obtain ingredient information, must be accurate and clear. For people with allergies, a reliable food label is nothing less than a lifeline. The mandatory labeling requirement under the new national standard is designed to straighten that lifeline, making critical, life-saving information clear at a glance.
Mandatory Labeling Required for These 8 Categories of Substances
Pursuant to the revised GB 7718-2025, Section 4.12 and Appendix D explicitly delineate eight categories of substances that are most common and most frequently associated with allergenic reactions. Where such substances are incorporated as ingredients into food products, mandatory declaration shall be required:
01. Cereals Containing Gluten and Their Products
This category encompasses wheat, rye, barley, oats, spelt, or their hybrid strains, as well as products derived therefrom, including but not limited to flour, noodles, bread, biscuits, and other baked goods. Gluten is a protein complex that may trigger allergic responses in susceptible individuals. Clinical manifestations may include rash, diarrhea, and dyspnea, with severe cases potentially leading to conditions such as celiac disease.
02. Crustaceans and Their Products
These include shrimp, lobster, crab, as well as products such as peeled shrimp and shrimp powder. Certain proteins found in crustaceans may act as allergens. Consumption may trigger allergic reactions including anaphylactic shock, urticaria (hives), and angioedema. Allergic symptoms associated with crustaceans are typically pronounced and rapid in onset.
03. Fish and Their Products
These include cod, salmon, tuna, as well as products such as fish balls, dried fish, and fish sauce. The allergenic proteins found in fish are highly stable and difficult to fully eliminate even after cooking or processing. Allergic individuals may experience symptoms such as vomiting, abdominal pain, and asthma upon consumption.
04. Eggs and Their Products
These include eggs from chickens, ducks, and quails, as well as products such as egg powder and liquid eggs. Ovalbumin and yolk proteins in eggs are the primary allergenic components. Infants, young children, and some adults may be allergic to eggs, potentially leading to conditions such as allergic dermatitis, eczema, and allergic rhinitis. In severe cases, anaphylactic shock may occur.
05. Peanuts and Their Products
These include peanuts, peanut kernels, peanut butter, and peanut oil. Peanut allergy is a common and relatively severe form of food allergy, characterized by complex allergenic components. Allergic reactions may include oral allergy syndrome and anaphylactic shock. Furthermore, allergic symptoms may persist as individuals age.
06. Soybeans and Their Products
These include soybeans, yellow soybeans, soy milk, tofu, soy sauce, and fermented black beans (Douchi). Soybeans contain multiple allergenic proteins. Some individuals may experience allergic reactions such as urticaria (hives), angioedema, and bronchospasm after consumption. Furthermore, because soybean-derived products are widely used in food processing, the associated allergenic risk is often overlooked.
07. Milk and Dairy Products (Including Lactose)
These include milk from cows and goats, as well as dairy products such as milk powder, yogurt, cheese, and cream, in addition to lactose. Cow's milk protein allergy is relatively common among infants and young children. It may cause symptoms such as diarrhea, vomiting, skin rashes, and persistent fussiness. If not identified and addressed promptly, it may affect the growth and development of affected infants and children.
08. Nuts and Their Kernel Products
These include tree nuts such as almonds, cashews, walnuts, and hazelnuts, as well as their kernels, along with products such as nut butters and nut flours. The allergenic proteins found in nuts are highly stable. Allergic reactions are typically severe and may trigger serious symptoms including anaphylactic shock and difficulty breathing. Additionally, individuals allergic to nuts have a relatively high probability of lifelong sensitivity.
"Cereals, Crustaceans, Fish, Eggs, Peanuts, Soybeans, Milk, Nuts" — these eight major allergens have been included in the new national standard's "Mandatory Warning List."
If any of these are on your allergy list, be sure to take an extra look at the label the next time you're at the food counter!
What Constitutes "Clear Labeling"?
Under the requirements of the new national standard, allergen labeling will no longer be a matter of arbitrary wording. To ensure that allergen information becomes a highlighted priority on food labels, the new standard provides several recommended labeling methods designed to enhance clarity and distinguishability (see Appendix D for details).
01. Use Bold or Underlining in the Ingredient List
The most direct approach is to use prominent formatting — such as bold or underlining — to highlight the names of allergenic substances within the dense text of the ingredient list. This allows consumers to quickly capture critical information at a glance.
02. Provide a Dedicated Allergen Statement Adjacent to the Ingredient List
In addition to highlighting allergenic substances within the ingredient list, a dedicated statement may be placed in close proximity to the ingredient list. Using lead-in phrases such as "Allergen Information" or "Food Allergens," this statement clearly lists the allergenic substances that are present or may be present in the product.
Cross-Contamination Risks Also Require Attention
In addition to intentionally added ingredients, cross-contamination during production presents another major risk for allergic consumers. For example, if a production line is used to manufacture a product containing peanuts and then switched to produce a peanut-free product without thorough cleaning, trace amounts of peanuts may inadvertently be introduced.
In response to this concern, the new national standard (Section 4.12.2) adopts an approach that encourages voluntary advisory labeling. Appendix D.3 provides examples of such statements, including: "This product may contain trace amounts of..." and "This production line also processes foods containing..."
Partial Exemptions
It is worth noting that not all ingredients derived from or processed from allergenic sources require allergen risk labeling.
The new national standard also takes into account scientific evidence and practical considerations. Certain ingredients that have undergone extensive processing and are theoretically free of allergenic proteins are granted exemptions (see Appendix D.4):
Soybean and Peanut Derived Products: Refined soybean oil, refined peanut oil, soybean-derived peptides, phospholipids, vitamin E, phytosterols, phytosterol esters and phytostanol esters, xanthan gum.
Cereal Derived Products: Starches, dextrins, glucose syrups, refined vegetable oils derived from cereals.
Aquatic Product Derived Products: Chitin, chitosan oligosaccharides, fish gelatin, refined fish oil, DHA derived from fish oil.
Milk Derived Products: Lactitol.
These exemptions are based on scientific assessment, meaning that these ingredients, under normal conditions, do not trigger allergic reactions.
Other Exemption Circumstances (Appendix D.5):
For products where a single ingredient constitutes the allergenic substance, if the product name already clearly specifies the name of that allergenic substance, duplicate labeling may be exempted.
Edible alcohol and distilled spirits.
REACH24H Reminder
With the March 16, 2027 implementation deadline for GB 7718-2025 fast approaching, food businesses should begin their compliance preparations now. Review your ingredient sourcing across all eight allergen categories, update label designs to meet the new clarity requirements, and train your teams on the mandatory labeling standards before the transition takes effect.
REACH24H's Advice for Consumers
The implementation of GB 7718-2025 on March 16, 2027, will significantly reduce the difficulty for allergic individuals in identifying risks. However, as consumers, we still need to:
Familiarize ourselves with the eight major allergens: Cereals (gluten-containing), Crustaceans, Fish, Eggs, Peanuts, Soybeans, Milk, and Nuts.
Develop the habit of carefully reading food labels, paying particular attention to the ingredient list and the allergen information section.
Understand the meaning of "may contain" advisory statements and make judgments based on our own level of allergy sensitivity.
REACH24H's Advice for Food Businesses
For food businesses, the implementation of the new national standard GB 7718-2025 is not merely a compliance obligation; it also represents a strategic window of opportunity to reshape and enhance corporate competitiveness.
Enterprises need to implement precise control across the entire value chain, from raw material sourcing to production. This requires a comprehensive, end-to-end upgrade covering a series of interconnected processes: thoroughly reviewing all ingredients, updating label designs, optimizing production workflows to minimize cross-contamination risks, and strengthening employee training.
This initiative serves both as an opportunity to elevate quality control standards and as a turning point for building consumer trust. When a package of crackers clearly states, "This production line has processed nut-based ingredients," the quality control capability it conveys is far more convincing than any advertisement boasting "artisan craftsmanship."
Not sure where to start? Our regulatory experts are ready to help.
Email: customer@reach24h.com
