The Food Safety Law stipulates that imported prepackaged foods should obtain compliant Chinese labels. However, language barriers, the lack of research on Chinese labeling regulations, improper product publicity and other factors often lead to non-compliance of Chinese labels, resulting in the return or destruction of imported foods by the Customs. Therefore, CIRS has sorted out some cases of common errors in Chinese labels of prepackaged general foods to help import and export enterprises better design compliant Chinese labels.
II. Common Errors in Chinese Labels
1. Error: The largest surface area is more than 35 cm2, while the mandatory labeling information is <1.8 mm in height.
Analysis: According to GB 7718, where the largest surface area of a package (container) of prepackaged food is more than 35 cm2, the minimum size of the words, symbols and numerals in the mandatory labeling information shall not be less than 1.8 mm in height. When text and numbers are set the same font size, the height of the number will be lower than that of the text. Therefore, enterprises should pay particular attention to the height of the numbers.
2. Error: The name is “apple juice drink”, but “apple juice” is bigger and more eye-catching than “drink”.
Analysis: "apple juice drink" (10% ≤content of apple juice <100%) is different from "apple juice" (content of apple juice: 100%). According to GB 7718, enterprises shall not mislead consumers by differentiating the font size.
Correct example: The product name "apple juice drink" are in the same font size.
3. Error: Ingredient names are not standard, such as “芝士” (cheese) and “盐” (salt).
Analysis: According to GB 7718, where a name or several names have been established in respect of a certain food under national, industry, or local standards, one of these names or an equivalent name shall be selected for use.
Correct example: According to current national standards, “芝士” should be labeled as “干酪” (GB 5420-2010干酪cheese) and “盐” should be labeled as “食用盐” (GB 2721-2015 食用盐edible salt).
4. Error: Maca powder is indicated in the ingredient list, but the unsuitable crowd and daily intake limit is not mentioned on the label.
Analysis: According to Approval Notice of maca powder, the food added with maca powder shall be indicated for unsuitable crowd and daily intake limit on the label and instruction book.
Correct example: This product is added with 10% maca powder, the daily intake of maca powder shall be ≤25g. It is not suitable for infants and the women in pregnancy or lactation.
5. Error: The composition of compound fermentation strains used in yogurt is not indicated in the ingredient list.
Analysis: According to GB 7718, where a compound ingredient (for which a name has been established in national, industry or local standards) constitutes less than 25% of the food, its primary ingredients are not necessary to be declared. “Compound fermentation strains” is a compound ingredient without current standard and its composition needs to be declared.
Correct example: Compound fermentation strains (Lactobacillus bulgaricus, Streptococcus thermophilus).
6. Error: Emphasis on the addition of oats in the product but the added level of oats is not indicated.
Analysis: According to GB 7718, where the label emphasizes on adding one valuable and/or characterizing ingredient, the content of the emphasized ingredients shall be declared.
Correct example: Labeled as “10% oats are added to this product”.
7. Error: "net weight" is written as "净重" but not “净含量”; The height of the net weight information does not meet the requirements.
Analysis: According to GB 7718, the net weight declaration shall be expressed containing net weight, numerals and the official unit of measurement, and it should also meet the minimum height requirements for the characters.
Correct example: When the net weight is 250mL, indicate the net weight as "净含量：250mL", and the minimum height of "净含量：250mL" should be ≥4mm.
8. Error: The product name is not presented in the prominent place of the label, and the net weight is not indicated on the same page with the product name.
Analysis: According to GB 7718, the product name shall be presented in the prominent place of the label, and the net weight and product name shall be presented on the same page of the package (container). The prominent place of the label generally refers to the main displaying page.
Correct example: Indicate the product name and net weight on the main displaying page of the label.
9. Error: The printing position of production date and expiry date is marked as "see the package" only; the date coding is not declared when the date is not printed in the order of ‘year month day’.
Analysis: According to GB 7718, where the date is indicated as “see XXX (a specific place) of the package, this specific place of the package shall be indicated (e.g., the bottom). The date coding shall be marked in the sequence of ‘year month day’, otherwise it shall be declared.
Production date (dd/mm/yyyy): see the bottom of the package
10. Error: Probiotic solid drinks (general foods) claim health function “Regulating gastrointestinal tract flora” on the label.
Analysis: According to GB 7718, non-health food shall not be declared directly or indirectly with the effect of health care.
11. Common errors in nutrition labels:
(2) The name, sequence, unit, rounding interval, and “0” threshold of energy and other nutrients do not meet the requirements of GB 28050.
(3) Hydrogenated vegetable oil is used, but the content of trans-fatty acids is not indicated in the nutrition table.
(4) Nutrition enhancers are used, but the content of them are not indicated in the nutrition table.
(5) Content claims of nutrients are indicated on the label, such as “low sugar” and “free of cholesterol”, but the content of the corresponding nutrients (such as sugar and cholesterol) are not indicated in the nutrition table.
(6) When indicating nutrients other than "energy, protein, fat, carbohydrate, sodium", the above five items are not clearly marked, such as bold marking
Analysis: The labeling of nutrition information shall comply with GB 28050. It is recommended for enterprises to adopt the format of nutrition table listed in the appendix of GB 28050.
(1) When using Chinese and foreign languages at the same time, there is no corresponding relationship between foreign language and Chinese or the foreign language is larger than the corresponding Chinese.
(2) The product hasn’t obtained organic certificate in China but illegally indicates “organic product” or other misleading expressions.
(3) Dairy products, aquatic products, bird's nest, and meat products are not indicated with the registration number of overseas production enterprises in China.
(4) The information related to the country of origin, and the agent, importer or distributor who are legally registered in China, are not indicated on the Chinese label, or the importer on the label is not filed from the Customs.
CIRS Suggestions: Related enterprises should focus on learning the labeling regulations in China and pay attention to the details when designing Chinese labels, so that economic losses caused by in-compliant labels or mislabeling can be avoided. Besides, the product shall not be introduced in a false or exaggerated way, and non-health food shall avoid making claims about health functions. The product promotion on the label should be true and accurate.
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