ZMUni Compliance Centre

In November 2024, the National Center for Food Safety Risk Assessment of China released a collections of FAQs, addressing 98 questions about National Food Standards.

ZMUni Compliance Centre has selected a few typical issues from the collection to share here, aiming to assist international stakeholders looking to enter the Chinese food market.

General Questions

Q: During the transition period of national food safety standards, should the original standard or the new standard be followed?

A: A transition period is typically set between the announcement and implementation dates of national food safety standards to allow adequate preparation time for food producers, operators, and enforcement parties.

During the transition period, as stipulated in the Regulations for the Implementation of Food Safety Law of the People's Republic of China, food producers may choose to continue following the old standard or adopt the new standard in advance before the implementation date. After the implementation date, food producers, food safety regulatory agencies, and testing institutions must comply with the new standard. Foods produced before the implementation date may continue to be sold within their shelf life.

Food Additive Standard

Q: How is the use of food additives in health foods managed?

A: In China, the management of health foods follows a product registration and notification system as mandated by law. The use of food additives in health foods must comply with the provisions of the Food Safety Law and adhere to the approved content specified in the health food registration certificate.

Q: How should a food additive with multiple functions or differing requirements across various national food safety standards be handled?

A: In the National Food Safety Standard for the Use of Food Additives (GB 2760), some food additives also serve as food ingredients. When used as food additives, these substances must comply with the provisions of this standard. However, when used as food ingredients, they must meet the relevant food ingredient requirements. For example:

• Polydextrose:

This substance serves as a permitted food additive in China, functioning as a thickener, leavening agent, humectant, and stabilizer, with specific usage limits outlined in GB 2760. Additionally, polydextrose is classified as a soluble dietary fiber. When used as a food additive, it must comply with GB 2760, but when used as a dietary fiber, it is considered a food ingredient and must meet the relevant regulations.

• Benzoic acid:

-When used as a preservative, it must comply with the usage limits and principles in Appendix A of GB 2760.

-When used as a food flavoring agent, it must comply with the principles and regulations for food flavors in Appendix B of GB 2760.

Regardless of its role, it must meet applicable product quality specifications.

Appendix A of GB 2760 governs the use of food additives for functional purposes in the final product, while Appendix C covers food processing aids that do not contribute functional properties to the final product. If a substance appears in both, its use must align with its function. For instance:

• Lactase:

-When used as a food processing aid, it must comply with Appendix C of GB 2760.

-When used as a food additive in flavored or fermented milk, it must comply with Appendix A of GB 2760.

• Vitamin C:

-As an antioxidant, it must comply with GB 2760.

-As a nutritional fortifier, it must follow the National Food Safety Standard for Nutritional Fortification Substances in Foods (GB 14880).

• Caffeine:

-When used as a food additive in cola-type carbonated beverages, it must not exceed 0.15 g/kg, as per GB 2760.

-When used in sports nutrition products, it must comply with the National Food Safety Standard for Sports Nutrition Foods (GB 24154-2015).

Q: How should food producers determine the functional category of an additive when it may serve multiple purposes?

A: Food additives must have a technological necessity when used in food. Producers should determine the primary functional category based on the actual purpose of the additive in the specific food product.

Q: How should foods with dual or multiple attributes be classified?

A: For foods with multiple attributes, producers should classify the product based on its primary attribute and use the relevant category for additives according to GB 2760. Voluntary standards may provide additional guidance. For example, a "fruit juice carbonated beverage" must meet the requirements for both fruit juice beverages and carbonated beverages. The use of food additives and nutritional fortifiers must comply with the standards for carbonated beverages in GB 2760 and GB 14880.

Q: What should be done when the food classification in GB 2760 differs from other classification systems?

A: Different classification systems may exist for various regulatory purposes. The classification in GB 2760 defines the scope of food additive use and should be followed when determining which additives are permissible for a particular food product. For example, non-dairy creamer is categorized under "other fats and oils" in GB 2760, but may be classified as a solid beverage in other systems. In such cases, the GB 2760 classification takes precedence for additive use.

Food Label Standard

Q: Can the ingredient label indicate "New Zealand milk powder" when the product uses milk powder from New Zealand?

A: The ingredient list should use standardized names that accurately reflect the nature of the ingredients, as specified in national or industry standards. If the ingredient originates from New Zealand, this can be highlighted in product descriptions or promotional materials. However, the ingredient label must strictly comply with regulatory requirements for accuracy.

Q: How should microbial strains used in food be labeled?

A: For general foods, it is recommended to label microbial strains according to the specific strain names listed in the List of Microorganisms Approved for Use in Food by the National Health Commission (NHC). For infant foods, the strains should be labeled as per the NHC's  List of Microorganisms Approved for Use in Infant Food. The content should be listed as “n×10⁶ CFU/g” or “n×10⁶ CFU/mL,” where "CFU" refers to colony-forming units.

Q: If the ingredients contain moisture and water is added during processing but some is lost, should the moisture loss be considered? How should water be listed on the ingredient label?

A: Water added during production must be listed in the ingredient label. For products like beverages, where water is an ingredient, it must be clearly stated. However, water lost during processing (such as through evaporation during baking) does not need to be included. Ingredients should be listed in descending order of quantity, with ingredients making up less than 2% of the product listed in any order.

Q: Can the "specification" be omitted for a single prepackaged food item?

A: For single prepackaged food items, only the "net weight" is required, although both "net weight" and "specification" may be displayed.

Q: How should the shelf life of imported food be labeled in China?

A: The shelf life of prepackaged food is determined based on production conditions, packaging materials, and storage methods. For imported food repackaged in China, the labeled shelf life must not exceed that of the original product.

Q: What does "country or region of origin" mean?

A: According to GB 7718-2011, the "country or region of origin" refers to the location where the food becomes a final product, including the place where the food is packaged or filled into containers.

Q: How should the quality grade of imported prepackaged food be labeled in China?

A: Imported prepackaged food must comply with GB 7718-2011, ensuring that the content in both the Chinese and foreign language labels corresponds directly. If the food matches an existing quality grade in China, the corresponding grade may be labeled. If it does not align with any grade, no grade should be labeled.

Q: Are refined soybean oil or peanut oil considered allergens?

A: According to GB 7718-2011, which follows Codex Alimentarius standards, soybean and peanut products are listed as allergens. However, refined oils like soybean or peanut oil, which have negligible allergenic protein content, may not always require labeling. GB 7718-2011 encourages voluntary allergen labeling to inform consumers. Producers may choose whether to label allergens outside the eight specified categories.

Q: Is it necessary to completely cover an all-English label on imported food in China?

A: No, it is not necessary. Adding a Chinese label that complies with the requirements of GB 7718-2011 is sufficient.

ZMUni Compliance Centre Reminder:

Food compliance is essential but indeed challenging especially in the Chinese market. To address these complexities, we offer one-stop solutions, including compliance check for prepackaged foods, health food registration & notification, new food ingredient & additive applications, pet food compliance, food clearance services, and more. If you need assistance, feel free to contact us at info@zmuni.com.