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A tasty Supper of labeling Regulation
Photo by Dan Gold on Unsplash
On November 2018 the new draft GB 7718 was released for public comments.
This is a key regulation for food industry, as it is the corner stone of the food labeling regulation in China.
Although the draft may be different from the final version – which may undergo last modifications subject to the public comments that will be submitted, likely in very high number – this draft needs to be already well studied by food companies and food operators.
This post wants to offer a “tasting” of the most important features of this new draft.
For all those “hungry” to know what the changes will be, let’s see what the new draft brings on the table and enjoy our meal!
ENTREE
We start with some technicalities.
Minimum fonts size for mandatory labeling has increased from 1.8 mm to 2 mm for foods with larges surface not smaller than 40 cm2 (previously 35 cm2). This may have some important impact at production level and also in the design of labels (especially for those already very dense).
Statement of ingredients containing allergenic substances also becomes mandatory – and it was about time, give the dire consequences that allergies can have!
MAIN COURSE
Now the big dishes arrive, and it is all about…. Ingredient content claims!
Basically, the new draft gives more guidelines on when the quantity of some specific ingredient should be declared in the label (i.e. “this yoghurt contains 20% of strawberries”; “this bread contains 70% of whole grain” etc..).
On the other hand, it seems that any kind of negative claim is more or less going to be banned. We have a clear ban for negative claim on additives, contaminants and any other substances: this should mean the end of any kind of “colorant-free”, “conservant-free”, even “Pesticide free” claims.
If this was not enough, we have another provision forbidding tout-court any negative claim whatsoever. Are therefore claims such as “palm-oil free” to be considered illegal under the new draft?
DESSERT – INGREDIENT REPRESENTATION
Pictures of raw materials are not allowed when the food contains only their fragrance. So if we have only strawberry flavor essence (instead than real strawberry or strawberry jam) in our yoghurt, the artwork shall not show the picture of a strawberry.
The new GB simplifies the labeling of some ingredients such as microbes used during production for fermentation purpose (“fermenting microbe” or “microbial starter”) and juices not exceeding 2% by weight and not singly present in the food (“fruit juice”, “vegetable juice”, “fruit juice concentrate”, etc... |
The meal seems big, tasty, but some dishes are indeed hard to digest.
Let’s see however how this goes, i.e. how the final text will look like.
We expect a lot of comments will be submitted to reduce the scope of those provisions forbidding negative claims, and possibly those forbidding use of pictures for ingredients of which only flavorings/essences are used.
It is not unusual to have major changes after the public comments phases – for example, let’s remember that in 2015 a draft of Implementing Regulation of Food Safety Law had been released for public comments, and it included a provision which sent the whole import-food industry into panic (basically forbidding sticker labels, thus implying that any imported food product will need to be directly printed in Chinese in the country of origin), only for such provision being deleted in the next draft circulated after.
So, our guess is that food companies shall start to re-think their labeling as if the current draft was to enter into force; however, of course, as for any implementation they should wait for the final release of the standard.
