ZMUni Compliance Centre

On January 24, 2024, the General Administration of Customs of China reported that 234 batches of food in December 2023 did not meet safety and hygiene requirements and were rejected at ports.

The top three reasons for food rejection were:

1. Labeling and packaging issues: 43%
2. Inspection and quarantine issues: 23%
3. Certificate or certification materials issues: 19%

A significant number of non-compliant labeling cases were identified among the food items not allowed entry. Over 40 products from Japan, weighing over 13 tons, were affected. These included pre-packaged foods like ice cream and biscuits.

Differences in food labeling requirements between China and Japan include:

• Japan does not mandate the labeling of production dates, but they need to be added for Chinese labels.
• Japan indicates salt content, whereas Chinese labels require conversion to sodium content.
• Japan differentiates between food ingredients and additives, which may affect the order of listing ingredients based on their amounts. Chinese labels should not simply copy ingredient ratios from Japanese lists. Additionally, detailed information about items like "acid regulators" and "food colorings" should be provided, specifying the food additives used.

To comply, pre-packaged food from Japan/other countries or regions (with original packaging in Japanese/other languages) must have Chinese labels when entering the Chinese market. These labels should include the product name, type, ingredients, storage conditions, production date, shelf life, country of origin, registration number in China, importer/agent/distributor information, net content, nutritional information, and other necessary details.

Common labeling errors and omissions include:

• Making health claims for regular food as if it were a health food.
• Omitting warning labels (e.g., for solid drinks, jelly, etc.).
• Failing to label new food ingredients as required (daily intake, suitable population, etc.).
• Issues with the nutritional information table (core nutrients, rounding, nutritional claims, etc.).
• Non-compliance with net content and font size specifications.

The National Health Commission of China has recently issued the "General Rules for Pre-packaged Food Labels (Draft for Solicitation of Comments)". This suggests that there may be significant changes to product labeling requirements. Please refer to previous articles for more information.