On April 17, 2026, the China National Center for Food Safety Risk Assessment released the National Food Safety Standard for the Labeling of Prepackaged Special Dietary Foods (Draft for Public Comment) (hereinafter referred to as the “Draft”), with a deadline for comments set for June 6, 2026. To help companies better understand the design requirements for the labeling of prepackaged special dietary foods, CIRS Group has compiled a summary of the key changes in this draft for reference, based on the draft and its compilation notes.
1. Clarification of Labeling Requirements for the Name of Special Dietary Foods
The Draft explicitly states that the name of special dietary foods must include the phrase “特殊膳食用食品(Special Dietary Food)” and must display the corresponding specific name of the special dietary food on the same label. This requirement helps consumers more clearly distinguish special dietary foods from general foods.
2. Addition of Mandatory Items in the Nutrition Facts Panel
Compared to the current standard, the nutrition facts panel for special dietary foods now requires the inclusion of “饱和脂肪（或饱和脂肪酸）(saturated fat (or saturated fatty acids) )” and “糖(sugars)”. Given that special dietary foods have stricter nutritional requirements than general foods and that their target consumers are more concerned about nutrient content, this revision aims to ensure consumers’ right to know while aligning with GB 28050-2025.
3. Clarification of “Serving Size” Labeling
The draft explicitly states that “when serving size is used, the mass or volume of each serving must be indicated on the same label panel,” further clarifying the labeling requirements for “serving size” while maintaining consistency with GB 28050-2025.
4. Revision of Permissible Tolerance Ranges for Nutritional Components
Due to the addition of mandatory labeling requirements for saturated fat and sugar, the draft has differentiated and adjusted the permissible tolerance ranges for nutritional components. It requires that, within the product’s shelf life:
1) The actual content of energy and nutritional components [excluding fat, saturated fat (or saturated fatty acids), sugar, and sodium] shall not be less than 80% of the declared value;
2) The actual content of fat, saturated fat (or saturated fatty acids), sugar, and sodium must not exceed 120% of the declared value;
3) And must comply with the requirements of the relevant product standards.
5. Revised Requirements for Claims
(1) For infant formula and infant formula for special medical purposes, the scope of ingredients subject to claim restrictions in the current standard has been expanded from essential ingredients to all nutrients. It is now required that “no content claims or functional claims regarding nutrients shall be made for infant formula and infant formula for special medical purposes.”
(2) The term “含量 (content)” in the conditions for content claims has been revised to “含量标示值(declared content value)”. The requirement states that “content claims may be made when the declared content value of energy or a nutrient meets the minimum value specified in the relevant product standard, the minimum value permitted for fortification, or the content requirements in Table B.1,” facilitating better label management and standard compliance for enterprises.
6. Adjustment of Special Dietary Food Categories
1) “Formula for older infants and toddlers” has been split into “Formula for older infants” and “Formula for toddlers.”
2) A “Nutritional Supplement” category has been added, which is further subdivided into complementary food supplements, nutritional supplements for pregnant women and breastfeeding mothers, and nutritional supplements for the elderly.
3) “Sports Nutrition Foods” has been listed as a separate category.
4) “Special Dietary Foods for Individuals with Gluten Intolerance” and other categories have been added to the “Other” category.
Summary
In addition to the major changes mentioned above, the draft revision of GB 13432 includes numerous adjustments and refinements, such as changing “functional claims” to “effect claims” and refining the instructions for use of infant formula for special medical purposes and formula for special medical purposes. Once revised, this standard will also better align with labeling standards such as GB 7718-2025 and GB 28050-2025. Once the official final version of the standard is released, companies should carefully review the provisions to ensure no important details are overlooked. If you have any questions regarding the labeling design requirements for prepackaged foods for special dietary uses or require any assistance, please feel free to contact the Food Division of CIRS Group.
About CIRS Food Division
Established in 2012, the Food Business Division of CIRS Group has helped over 1,000 food companies globally in achieving one-stop compliance solutions. CIRS offers a full range of regulatory services, including but not limited to China novel food applications, synthetic biology-derived foods, U.S. GRAS notices, EU novel food applications, 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.
