On March 27, 2025, China's National Health Commission (NHC) and the State Administration for Market Regulation (SAMR) jointly issued three landmark food labeling regulations: the National Food Safety Standard — General Rules for the Labeling of Prepackaged Foods (GB 7718-2025), the National Food Safety Standard — General Rules for Nutrition Labeling of Prepackaged Foods (GB 28050-2025), and the Administrative Measures for Supervision of Food Labeling.
The following analysis covers the five most critical changes introduced by these regulations: date marking, allergen labeling, nutrition labeling, NRV adjustments, and ingredient addition and claims.
Date Marking
Date Format
Year-Month-Day sequence required. Both the production date and the expiration date of shelf life must be labeled. Note the prescribed date order and the consumption shelf life, which indicates the final safe consumption date.
Latest Requirement: The production date and the expiration date of the shelf life of prepackaged food shall be clearly marked in the order of year, month, and day.
Exemptions: For products with a shelf life of six months or longer, or where the largest surface area of the packaging is no greater than 20 cm², only the shelf life and the expiration date of the shelf life may be indicated. Furthermore, to help prevent food waste, a consumption shelf life may be voluntarily indicated based on the specific characteristics and processing techniques of the food.
REACH24H Reminder
The date sequence is now mandated as Year-Month-Day. Importers are likely to encounter challenges in reformatting date labeling to comply with this requirement. For limited production runs or globally standardized products, overseas manufacturers may be reluctant to accommodate such adjustments; therefore, enterprises should make timely strategic decisions regarding label compliance.
The option to voluntarily indicate a "consumption shelf life" presents a potential advantage for food businesses. However, it is important to note that the Food Safety Law expressly prohibits the sale of food beyond its labeled expiration date. Indicating a consumer storage period does not constitute an extension of the authorized sale period. Enterprises must clearly understand that the "consumption shelf life" is distinct from and not equivalent to the mandatory "expiration date of shelf life." Failing to distinguish between these concepts may lead to consumer confusion, complaints, fraudulent claims, or regulatory enforcement actions.
Date Area
Must be placed in a distinct, clearly contrasting area, preferably on the principal display panel of the packaging.
Latest Requirement: According to the Administrative Measures for Supervision of Food Labeling, the date of production and the expiration date must be marked within a distinct, dedicated area on the packaging. If this date area is not located on the principal display panel, the principal display panel must bear a clear indication such as "See date on [specific part of package]." Furthermore, the date must be presented in a clearly contrasting format, such as black text on a white background.
REACH24H Reminder
While this change enhances consumer accessibility to date information, it necessitates adjustments to packaging artwork design and coding/marking equipment. Enterprises are strongly advised to plan and implement these changes as early as possible to ensure compliance.
It is also important to note that date marking is not considered a minor defect subject to leniency. Non-compliance in this area poses a significant risk of consumer litigation or fraudulent claims. Early standardization is essential to mitigate regulatory and reputational risk.
Allergen Labeling: From Voluntary Recommendation to Mandatory Requirement
Latest Requirement: To reduce the incidence of food allergies in China and enhance the health protection afforded by food labeling, the declaration of eight major allergen categories has become mandatory.
REACH24H Reminder
Currently, only a minority of food labels in the market voluntarily declare allergen information. The transition from a voluntary recommendation to a mandatory requirement means that most existing food labels will require revision. Enterprises are advised to conduct an early review of their current labeling practices, identify all applicable allergens, and ensure that allergen information is declared in a standardized manner. Furthermore, attention must be paid to the placement of this information: allergen declarations must appear within or immediately adjacent to the ingredient list.
Nutrition Labeling
Latest Requirement: The mandatory nutrition declaration has been expanded from the previous "1+4" format (energy + four core nutrients) to a "1+6" format. This revision adds saturated fat and sugar as mandatory labeled nutrients. Additionally, the statement "Children and adolescents should avoid excessive intake of salt, oil, and sugar" is now a mandatory declaration and must appear directly below the nutrition facts table.
REACH24H Reminder
With the addition of saturated fat and sugar as mandatory nutrients, enterprises that do not currently have established nutrient profiles for their products may obtain the required values either through testing using current and valid standard methods, or through calculation based on credible data derived from the formulation and ingredient composition.
The inclusion of these two additional nutrients, along with the mandatory advisory statement beneath the nutrition facts table, will require additional label space. Enterprises with limited label surface area or those that rely on affixing Chinese labels post-importation should address these layout implications at the earliest opportunity.
NRV Adjustment: Potential Downgrade of Nutrient Content Claims
Latest Requirement: Certain Nutrient Reference Values (NRVs) have been updated in accordance with the revised Dietary Reference Intakes for Chinese Residents. These adjustments primarily affect vitamins and minerals.
REACH24H Reminder
Changes to NRVs will directly impact the NRV% values displayed on labels and may result in a downgrade of nutrient content claims. A product that previously qualified for a "rich in" or "high in" claim may no longer meet the threshold under the revised NRVs. Enterprises are advised to assess these impacts promptly and take appropriate action — either by reformulating the product or revising the label claim.
Case in Point: Vitamin D
The NRV for Vitamin D has been revised from 5 μg to 10 μg. For a product containing the same absolute amount of Vitamin D, the NRV% will therefore be reduced by half compared to the 2011 edition.
Consider a solid beverage containing 1.5 μg of Vitamin D per serving:
Under the 2011 NRV (5 μg): The NRV% would be 30%, satisfying the claim requirement for "High in Vitamin D" or "Rich in Vitamin D."
Under the 2025 NRV (10 μg): The NRV% drops to 15%, which only qualifies for the claim "Contains Vitamin D."
This example underscores the need for enterprises to promptly evaluate their product portfolios. Where maintaining a "high in" claim is commercially important, product reformulation may be necessary; otherwise, label claims must be adjusted to accurately reflect the new NRV-based calculation.
Ingredient Addition and Claims
Latest Requirement: The revised standard clarifies that mentioning an ingredient or component in the food name constitutes special emphasis, thereby requiring a quantitative declaration of that ingredient. For products where the flavor is derived solely from food flavorings or essences, only illustrations or graphics other than real photographs of the actual ingredient or food may be used. In such cases, a visible statement such as "Graphic for Flavor Reference Only" must be placed immediately adjacent to the image. Furthermore, the use of claims such as "not added," "not used," and their synonyms is explicitly prohibited.
REACH24H Reminder
For products where the flavor profile is derived primarily from flavorings or essences — particularly those utilizing vivid packaging graphics to emphasize a specific flavor characteristic — enterprises should adopt abstract or stylized graphic designs rather than realistic depictions of the actual ingredient. If a product's name emphasizes a specific ingredient, the quantitative content of that ingredient must be declared in the ingredient list. The use of claims such as "not added," "not used," and their synonyms must be strictly avoided.
Final Advisory for Importers
REACH24H wishes to draw particular attention to a critical overarching requirement. Upon the enforcement of the revised standards, all visible labeling content on imported prepackaged food — including but not limited to foreign-language or traditional Chinese characters, the affixed Chinese label, and any accompanying explanatory materials — must fully comply with China's laws, regulations, and national food safety standards. Importers who rely on affixing Chinese labels post-importation are strongly urged to plan for these changes well in advance to mitigate the risk of clearance delays or rejection at the port of entry.
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