Chinese food labels: settled before production, not at the port

Most exporters plan the Chinese label as a translation task with a printing cost attached, and assume the physical form is theirs to choose. For ordinary prepackaged food that assumption mostly survives. For health food it does not, and the rule that breaks it is one sentence in the Administrative Measures on Import and Export Food Safety (海关总署令第 249 号), article 30: the Chinese label on imported health food must be printed on the smallest sales package and may not be applied as a sticker.

For health food, then, a container already manufactured and packed, with beautifully produced Chinese stickers waiting at destination, cannot be brought into conformity by applying them. The correction is a reprint at origin. Ordinary prepackaged food is not in that position. Where a non-safety labelling defect is found, technical treatment under customs supervision before release is available in some cases — but it is slow, it is expensive, and it is not guaranteed.

The same article carries a second requirement that surprises people: on imported health food the Chinese characters must be larger than the foreign-language text. Not equal in size. Larger.

Who is responsible for getting this right

The importer, explicitly, and before the goods travel. The importer must check for itself that the Chinese label on prepackaged food conforms to Chinese law and to the food safety national standards — GB 7718, GB 28050 and GB 2760 among them — and must not import where that check fails. Labelling is one of the inspection items customs applies, and when a consignment is selected for examination the importer produces the conformity evidence, the original label, its translation, the Chinese label artwork and any supporting material.

The workable sequence is therefore: label decided → conformity checked → goods produced → goods shipped. Reversed, the check happens at a Chinese port, which is the most expensive place to discover the answer.

What every prepackaged food label must carry

Under article 67 of the Food Safety Law:

• Name, specification, net content and production date
• Shelf life
• Ingredient list or composition, with additives named as the national standard names them
• Producer’s name, address and contact details
• Production licence number
• Product standard code
• Storage conditions

The introductory word for the ingredient list is itself prescribed: ordinary foods use 配料 or 配料表; fermented products whose raw materials change during production — wine, soy sauce, vinegar — may use 原料 or 原料与辅料; additives and health foods may use 成分 or 配料.

Where imported food differs from domestic

Imported prepackaged food is exempt from stating the producer’s name and address, but must instead state:

• The country or region of origin
• The name, address and contact details of the agent, importer or distributor legally registered in China

This is one of the few places where the regulations are lighter on imports, and it exists because the Chinese-registered entity is the one a consumer or a regulator can actually reach. That entity has to exist before the label can be finalised — which makes the importing arrangement a labelling question and not only a customs one.

Two exemptions are worth knowing. Shelf life need not be stated on alcoholic drinks above the specified alcohol content, vinegar, edible salt, solid sugars and monosodium glutamate. And on very small packages, where the largest surface of the packaging falls under the specified area, only product name, net content and the producer’s or distributor’s name and address are required.

Special dietary foods carry more, not less

Infant formula, infant supplementary foods and foods for special medical purposes (GB 13432-2013) must additionally state:

• Energy, protein, fat, carbohydrate and sodium, plus any nutrient the product standard requires, expressed per unit and per portion, with fortified nutrients declared
• Daily or per-meal intake, the preparation or reconstitution method, and the intended population
• Storage conditions before opening and, where relevant, after opening

Sports nutrition foods (GB 24154-2022) add their own. The words sports nutrition food must form part of the product name; intended population and consumption limits must be stated; and health-food function claims such as enhances immunity are not available to them, because those belong to registered health foods only. Medical claims are prohibited outright, and nutrient reference values are expressed as NRV percentages. Producing facilities register with CNCA for a five-year term, and the registration file includes GLP laboratory reports.

Health foods: the blue hat and a closed list of claims

Health food is a defined regulatory category (GB 16740-2014), not a marketing description: food that claims and possesses a specific health function, or that supplies vitamins and minerals; intended for a defined population; adjusting bodily function; not for treating disease; and causing no acute, sub-acute or chronic harm.

Twenty-seven health functions may be claimed and no others. They are:

• immunity support;
• blood-lipid, blood-glucose and blood-pressure support;
• antioxidant and memory support;
• relief of visual fatigue;
• lead excretion;
• throat comfort;
• sleep improvement;
• lactation support;
• relief of physical fatigue;
• hypoxia tolerance and radiation protection support;
• weight reduction;
• growth and development;
• bone density;
• nutritional anaemia;
• chemical liver injury protection;
• acne and chloasma reduction;
• skin moisture and skin oil improvement;
• gut flora regulation;
• digestion support;
• laxation and gastric mucosal protection.

A claim outside the list is unavailable whatever evidence stands behind it.

Products carry the blue hat mark with an approval number, and each approval number corresponds to exactly one product; both are checkable on the SAMR site at samr.gov.cn. Label content — trademark, product name, production date, shelf life — must agree with the registration or filing record. The product’s instructions must state both the suitable and the unsuitable population; pregnant women, nursing mothers and children are the three that appear most often in the unsuitable list.

Registration and filing run on two tracks: filing for vitamin and mineral supplements using ingredients on the health food raw material catalogue, and registration for products with a specific function or using ingredients outside it. A first-time import registration takes around twelve months through technical review, while a change to an existing filing typically completes in one to three working days. For a first import, that twelve-month figure is the number that should shape the commercial plan, not the freight transit time.

Additives: a whitelist, and a rule about what arrives by accident

China regulates additives on a whitelist — only what is approved may be used, and only within the approved scope and quantity. The standard is GB 2760, and the 2024 edition replaced the 2014 edition on 8 February 2025. Any specification written before that date is worth re-checking.

The provision that catches formulators is the carry-over principle: an additive reaches the finished product not by direct addition but through an ingredient that already contains it. Two forms are recognised — the additive is permitted in the ingredient and acts there, or it is permitted in the finished product and is carried in on the ingredient. Authorities routinely ask the producer or importer to evidence a carry-over within a set period, and failure to produce that evidence in time is treated as unlawful additive use. The pack is worth assembling before it is requested.

Two points of scope. The same additive can be permitted in one country and prohibited in another on necessity rather than safety grounds — benzoyl peroxide as a flour whitener is permitted in the United States and prohibited in China. And the recurring problem areas in trade are colourants, preservatives and sweeteners, with over-dosing and use outside the permitted scope as the two failure modes.

Food contact articles have their own label rules

Tableware, kitchenware, containers and packaging fall under the GB 4806 series, and three defects recur in customs supervision:

• A superseded standard code. Disposable plastic tableware still printed with GB 4806.7-2016 where GB 4806.7-2023 now applies.
• Missing safety and use limits. A standard code alone, with no conditions of use — not microwave safe, maximum temperature — leaves the user to guess.
• Missing origin on imports. A label carrying only the Chinese importer’s details, without the country of origin and the overseas manufacturer in Chinese.

The practical control is a pre-shipment label review: check the original artwork and the Chinese label together, before declaration, against country of origin, the Chinese agent or importer’s details, the conformity statement and the use restrictions.

Genetically modified ingredients

Agricultural GM organisms on the national labelling catalogue carry mandatory prominent labelling. Direct processed products are marked as GM-processed or as made from GM material; where processing has left no detectable GM content, the label says exactly that. Where packaging cannot carry the statement — display sales, unpackaged bulk, goods in containers, imported unpackaged GM organisms — it is made by display board, sign, or a note on the declaration itself.

The short version

For ordinary prepackaged food the Chinese label is a compliance document that has to be settled before production. For health food it is also a printing decision that cannot be reversed at the border: printed on the smallest sales package, never applied as a sticker, with Chinese type larger than the foreign text. Anyone planning a first health food shipment into China should confirm that one point before the packaging is ordered.