Sandra Huang

New Imported Food Label Regulation for Mainland China-Duty Is On Importers

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The responsibility of ensuring that labeling complies with Chinese standards is on importers and overseas exporters. Authorities will review the labels via pre-market and post-market monitoring systems. Several points need to be taken.

For enterprises importing food to China (overseas exporters), the submission of labeling materials to border ports are changed. They need to prepare the following files and record labels for 2 years.

  1. Chinese label as the label sample, and original label with translation.
  2. Supportive files for claims, certificate, award, legal production area, geographic indication, stressed component, and nutrition information.
  3. Commitment letter by enterprise.
The commitment letter is the concrete form of responsibility shift. In the letter, the enterprises should guarantee the labels in market consist with the label recorded at port, and ensure their compliance. In addition, enterprises shall promise if the labels do not comply with regulations or standards, the enterprise will actively recall the products.

Border ports will only ensure importers submit all materials as required, and then record the submitted labels on the information platform.

In the spot inspection at border port, the authority should check the label is in Chinese and same with the submitted label.

If the products in any link are reported for substandard labels, the authority will implement stringent supervision on involved importers till they have no violation for 12 months or continually import 60 batches of food with qualified labels.

Exhibits, samples, foods sold in tax-free stores, inside consumption for embassies or foreign staffs of enterprises are waived for label supervision. The items for exhibitions, however, are required for temporary registration. The label will be examined via that registration process.