On April 11, 2025, we hosted a free Chinese webinar on the key points and considerations in health food labels. Because many questions were raised during the webinar, we have collected them and made a Q&A summary below.
Q1: Does the shelf life need to be indicated on the principal display panel (PDP), or is it acceptable to indicate “see [specific part] of the packaging” on the PDP? How is the PDP specifically defined?
A: The definition of the principal display panel can be referenced from GB 7718-2011 and its implementation guide.
GB 7718-2011: Principal display panel — the panel of the prepackaged food packaging or container that is easily observed.
Implementation guide of GB 7718-2011: “Easily observed panel” refers to the most prominent part of the packaging or container that does not require intentional searching. For example: the largest side of a rectangular package/container, any side of a cube-shaped package/container, a side surface of a cylindrical or near-cylindrical package that is viewable at eye level, or the circumference or lid of a flat-round package — all qualify as “easily observed panels”. Therefore, packaging of the same size may have more than one display panel. The most important principle in determining the PDP is that it must be large enough to accommodate the required labeling content. Under this principle, the largest surface area should typically be selected as the PDP.
Q2: For the nutrition facts table, does the unit have to be written as “每100克(g)”? Or can it just be written as “每100克”?
A: Yes, that's ok.
Q3: If the only sugar in the carbohydrate content is lactose, can the sugar be labeled directly as lactose?
A: According to GB 28050-2025, “sugar” and “lactose” must be labeled separately. Therefore, you cannot directly label sugar as lactose.
Q4: Which regulation should be followed when labeling new food ingredients?
A: Since new food ingredients are typically not sold directly to consumers, labeling should follow the requirements in GB 7718-2025 for prepackaged foods not directly provided to consumers.
Q5: According to section 8.1.1, is it prohibited for imported food packaging in foreign languages or Traditional Chinese to indicate “no added [specific food additive] ”?
A: Yes, such labeling is not permitted.
Q6: If a company chooses to implement the new standards ahead of the official date, must this be indicated on the label?
A: Yes, early implementation is allowed and can be indicated on the label. According to Article 13 of the Implementation Guide of the Food Safety Law of the People's Republic of China: After a food safety standard is announced, food producers and operators may implement it before the official enforcement date and publicly disclose that they have done so.
Q7: Must the production date and expiration date be on the PDP? Can they be printed on the bottom of the bottle instead?
A: If the date is not printed on the PDP, it must state “See [specific part] of the packaging” to indicate where the date is located.
Q8: For regular foods, is it necessary to separately label net content and specification on the PDP?
A: No separate labeling is required. Specification information can be included within the net content label, such as “ Net content: 200g (40g×5)”.
Q9: For compound ingredients, is it necessary to label the components of their own compound ingredients? Is it required even if these sub-ingredients are not standardized?
A: No, it is not required to list the sub-ingredients of compound ingredients, regardless of whether they have standards.
Q10: For imported foods sold domestically, can the Chinese label use “经销商(distributor)” as a heading, or must it only use “进口商、代理商 (importer/agent)” ?
A: According to section 8.3 of GB 7718-2025, imported prepackaged foods must indicate the name, address, and contact information of the importer/agent. The term “distributor” is not specified and should not be used as a labeling heading.
About Us
Established in 2012, the Food Business Division of CIRS Group has helped over 1,000 Chinese and international food companies achieve one-stop compliance solutions. CIRS offers a full range of regulatory services covering novel food applications, synthetic biology-derived foods, US GRAS notice, EU novel food application, health food registration, and food for special medical purposes (FSMP).
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
Further Information
China Tightens Food Label Regulations: Bans "No Food Additives" Claims and Boosts Transparency
China New Labeling Regulations for Health Food: How Should Labels Be Displayed?
