On January 19, 2024, the Secretariat of the National Food Safety Standards Review Committee issued the "General Principles for the Labeling of Prepackaged Food in the National Food Safety Standard (Draft for Comments)" (hereinafter referred to as the Draft), and the deadline for soliciting comments is February 29, 2024. In view of the large changes in this draft compared with the current effective version, in order to enable the majority of food companies to understand the revision of GB 7718 as soon as possible, the highlights and changes of this draft have been sorted out for the reference of the industry.
1.Pre-packaged foods with a shelf life of 1 year or more are no longer mandatory to label the date of manufacture
The Draft Opinion revises the date labeling requirements, and the date labeling order is only year, month, and day, and prepackaged foods with a shelf life of one year or more may not be marked with the production date. Definitions of terms of shelf life and shelf life have been added to the Draft. The shelf life of pre-packaged food with a maximum surface area greater than 60cm is marked in the order of year, month and day.
It is recommended that the food in sub-packaging should be marked with the production date and packaging date of the sub-packaged food at the same time, and the shelf life should be marked with the expiration date of the shelf life, such as the shelf life date (to) 202 * year * month * day, etc.
If the production date of imported pre-packaged food is not marked on the original packaging, the production date shall be marked after estimation according to the shelf life and best before date indicated on the original packaging.
Tips: The minimum height of the date should not be less than 3mm, and the ratio of height to width should not be greater than 3:1.
2.Compound ingredients should not be expanded and should be clearly marked in the ingredient list
The draft clarifies that the compound ingredients must be reflected separately and cannot be expanded and combined with the original ingredients. Compound ingredients need to be reflected separately in the ingredient list, which can better meet consumers' right to know and facilitate supervision.
For example, if the food in the above figure uses the compound ingredient "hawthorn six substance paste", and some of the original ingredients are the same as other ingredients directly used in the food, according to the requirements of GB 7718-2011, the name of the compound ingredient can not be marked, and the relevant ingredients can be combined and calculated according to their total amount in the final product in decreasing order; The draft no longer allows this form of labeling.
Tips: According to the current GB 7718 standard Q&A Article 26, the original ingredients in the compound ingredients can be directly marked in the ingredient list. After the revision of this article, the identification of the ingredient list is more standardized, and enterprises need to respond in a timely manner.
3."Label defects" are not directly related to food safety
The draft moves formatting requirements that are not directly related to food safety, such as font, font size, font height, and maximum surface area requirements, from the body of the standard to the appendix, so that when the relevant content on the food label is inconsistent with the standard requirements, it is convenient for the market supervision department to decide whether to manage it according to "label defects".
Tips: At present, the market supervision mainly refers to Article 37 of the "Measures for the Supervision and Inspection of Food Production and Operation" to determine label defects.
4.Imported packaged food should be marked with both the country (region) of origin and the country (region) of packaging
If the draft clarifies that the country or region of filling or sub-packaging is inconsistent with the country of origin, the country or region of filling or sub-packaging shall be marked at the same time, and the ** or the name of the country or region of production of the raw materials or ingredients may also be indicated at the same time. If a peanut oil is produced in country A and imported into China after being packaged in country B, the label of the peanut oil should indicate both country A and country B.
Tips: Foods that are not allowed to be packaged in China cannot be imported into China after being packaged and produced, and at the same time, the "date labeling" part of the draft requires that foods produced by sub-packaging should be marked with the production date and packaging date of the sub-packaged food at the same time.
5.Digital labels may be a substitute for some physical label information
Digital labels belong to food labels, which are displayed by information means such as *** on food packaging. The draft clarifies that when a food enterprise uses a digital label to correctly mark the name of the food producer or trader (excluding the name of the producer registered in accordance with the law and can assume responsibility for product safety and quality), address, ** product standard code, and implementation standard number, the relevant information can only be clearly indicated on the physical label as shown on the digital label, and the specific content is exempted from being marked on the physical label.
Tips: The content displayed on the digital label should comply with the provisions of laws, regulations and national food safety standards, and should be consistent with the information displayed on the food label at the same time. When using digital labels, the relevant provisions of the standard should be complied with, and the relevant label information should be directly displayed on the first-level page after scanning the code to obtain the information, and pop-up advertisements should be avoided to interfere with consumers' reading of food label information.
6.It is recommended that prepackaged food claims be based on the science of a specific age group, physical condition and nutritional needs
The Draft adds basic requirements for food claims and divides food claims into four categories: general claims, health effect claims of food ingredients or ingredients, nutrition claims and claims of nutritional content, and health food claims. General claimsIt mainly includes characteristic claims, condition claims, comparative claims, quantitative (content) claims and sensory claims. Appendix E sets out in detail the specific classification and conditions of use of each type of claim to help food manufacturers standardize the use of these claims. Among them, claims related to food target consumer groups, such as involving specific age groups, physical conditions and nutritional needs, and there are no relevant national laws, regulations, standards and regulations and announcements issued by relevant departments, it is advisable to indicate the content of the scientific evidence on the label at the same time. Health effect claims of food ingredients or ingredients, should comply with the requirements of the "Food Safety Law" and the provisions of the relevant departments, in the absence of relevant provisions, food production enterprises shall not make their own claims on health effects; In additionNutrition claims and nutrient action claimsStrictly in accordance with GB 28050 and GB 13432; Health food claimsIn accordance with the relevant provisions of the relevant departments.
Tips: There are a lot of claim words that companies pay more attention to in the claim examples, such as:Food labels can use words such as "new" and "fresh" to describe the extent to which the time for the final processing of the food into the final product is close to the time when the food will be on the market. In addition, when claiming the health effects of food ingredients or ingredients, it is necessary to consider whether the ingredients themselves have labeling requirements, such as the "Regulations on the Management of the Catalogue of Substances that are Both Food and Chinese Medicinal Materials According to Tradition", which requires that product labeling and operation shall not claim to have health care functions and shall not involve disease prevention functions.
Conclusion
After comparison, it is found that the third version of the draft has undergone major changes compared with the current GB 7718 and the previous two drafts. The overall logic and coherence of the draft are clearer. The specific amendments of the new draft can better guide the production and design of enterprises, make it easier for consumers to read and understand, and also provide convenience for law enforcement inspections by regulatory authorities. Remind everyone to submit feedback in a timely manner as required within the specified time, and be prepared for the response to label identification.
*: Food Labeling Circle February**Dynamic Incentive Program Food Labeling