On May 22, 2025, China's General Administration of Customs (GACC) published its list of non-compliant imported food products for April 2025 (hereinafter refers to "the list"), a total of 325 batches from 39 countries and regions were denied entry, representing an 11% increase from the previous month and a 17% rise year-on-year.

Notably, after four consecutive months of decline, this figure has shown a significant rebound for the first time. Some analysts suggest that this change may be linked to external factors such as the easing of U.S. tariff policies.

The majority of non-compliant imports came from Japan (10.5%), the U.S. ranked second (10.2%), Vietnam (8.3%), and Spain (7.7%). Key reasons for import rejections included:

- Unqualified labeling 

- Discrepancy between cargo and certificates

- Non-compliance with national food standards

- Detection of animal diseases

- Registration issues of overseas food manufacturers

Caffeine Levels Not in Compliance with China's National Food Safety Standards?

According to the list, three mate-extract beverages from the German brand CLUB-MATE were denied entry due to "caffeine levels not meeting the requirements of China's national food safety standards."

CLUB-MATE products are widely sold in markets such as the United States and the European Union. According to the brand's Danish website, its beverages contain between 20 and 22 mg of caffeine per 100 ml and carry the warning label required by Regulation (EU) No 1169/2011: "High caffeine content – not recommended for children, pregnant or breastfeeding women."

*Source: website of CLUB-MATE

Are There Regulatory Limits on Caffeine Use in China?

According to the National Food Safety Standard Standard for Uses of Food Additives (GB 2760-2024) and the National Food Safety Standard General Standard for Sports Nutrition Food (GB 24154-2015), caffeine may be used both as a food additive and as a nutritional component.

As a food additive, caffeine is allowed in cola-type carbonated beverages at a maximum level of 0.15 g/kg. As a nutritional component, it is permitted in sports nutrition foods with a daily intake of 20–100 mg.

 *Source: GB 2760-2024

*Source: GB 24154-2015

Is Caffeine Content Required on Labels in China?

At present, Chinese regulations do not mandate the labeling of caffeine content. However, for Coffee Beverages, the recommended national standard Coffee Beverages (GB/T 30767-2014) advises that caffeine content should be disclosed on the product label.

*Source: GB/T 30767-2014

Pay Attention to High-Caffeine Products

Under China's Catalogue of Psychotropic Substances, caffeine—along with its salts, single-ingredient preparations, and isomers—is classified as a Class II psychotropic substance. According to Article 357 of the Criminal Law of the People's Republic of China, "narcotic drugs" refer to opium, heroin, methamphetamine (ice), morphine, cannabis, cocaine, and other addictive narcotic and psychotropic substances under state control.

ZMUni Compliance Centre reminds exporters that whether through general trade or cross-border e-commerce, products with caffeine levels significantly higher than similar items already on the Chinese market should be avoided—especially in forms such as solid beverages or compressed tablets. Extra caution is advised when the original product label includes claims like "energy-boosting" or "anti-fatigue."

To minimize compliance risks, businesses are strongly encouraged to consult with local port authorities before shipping such products to China.

With deep expertise in pre-packaged food compliance and import/export clearance, ZMUni Compliance Centre is here to support your market access journey. For tailored guidance or assistance in ensuring smooth product entry into China and beyond, contact us at info@zmuni.com.