Non-compliant factors for food products vary, but common ones include: overuse or misuse of a certain ingredient in the product, missing or incorrect labeling on the product, and exceeding standards for heavy metals or pesticide residues, etc.
This mainly involves three aspects of compliance: product formula compliance, label compliance, and product quality compliance.
I. Formula Compliance
Food products must adhere to the relevant food safety standards. These standards stipulate that the formulation of food products should not include non-food raw materials, nor should they contain chemical substances outside of approved food additives or other potentially harmful materials. The overuse or misuse of food additives is strictly prohibited. The use of recycled food as raw materials is also forbidden. While the addition of pharmaceuticals to food is not allowed, the inclusion of substances that have traditionally served both as food and Chinese medicinal materials is permissible.
When checking whether a certain ingredient is compliant, what sources of information can be used as a basis for compliance? Below are some commonly used bases for compliance for your reference:
Type | Basis |
Ordinary Food Ingredients | Search for substances mentioned in existing food standards, letters and announcements issued by the competent authorities, and existing general limit standard catalogs. |
New Food Ingredients | Approval Announcement: Released by the National Health Commission; Termination of review announcements, divided into three situations: (1) Reviewed as ordinary food or substantially equivalent to ordinary food; (2) Substantially equivalent to the announced new food ingredients; (3) Other situations where the review is terminated (specific conclusions need to be discerned whether it is approved) |
Ingredients for Both Food and Medicine | List of items that are both food and medicine - (NHC [2002] No. 51) and its supplementary announcements |
Food Use Strains | List of Strains Suitable for Food Use List of Strains Suitable for Infant and Toddler Food Use |
Food Additives | GB 2760 National Food Safety Standard for the Use of Food Additives and its supplementary announcements GB 14880 National Food Safety Standard for the Use of Food Nutrition Fortifiers and its supplementary announcements |
The Food Safety Law stipulates that prepackaged food should have labels on the packaging.
The requirements for food labels are stipulated by multiple regulations and standards. These include general rules for labels (such as GB 7718, GB 28050, GB 13432), specific product standards, and additional special requirements for supervision (such as the food overseas production enterprise registration number required by the General Administration of Customs).
Special dietary foods have significantly different label requirements from ordinary foods: special dietary foods include infant formula foods, special medical purpose formula foods, infant supplementary foods, supplementary food nutrition supplements, sports nutrition foods, and so on.
Prepackaged Food | General Labeling Rules | Product Standards | Additional Regulations |
Food (except for special dietary foods) | GB 7718 National Food Safety Standard General Rules for Labels of Prepackaged Foods GB 28050 National Food Safety Standard General Rules for Nutrition Labels of Prepackaged Foods | GB 7101 National Food Safety Standard Beverages" GB 7099 National Food Safety Standard Pastries, Bread... | Announcement of the State Administration for Market Regulation on Strengthening the Quality and Safety Supervision of Solid Beverages (No. 46 of 2021) Regulations on the Registration Management of Overseas Production Enterprises of Imported Food in the People's Republic of China ... |
Special Dietary Foods | GB 13432 National Food Safety Standard Labels for Prepackaged Special Dietary Foods | GB 10765 National Food Safety Standard Infant Formula Foods... | Technical Guidance Principles for the Specification of Infant Formula Milk Powder Product Formula Registration Labels (Trial) Regulations on the Registration Management of Overseas Production Enterprises of Imported Food in the People's Republic of China ... |
III. Product Quality Compliance
Food products should comply with food safety standards. The food safety standards here mainly include general standards and product standards.
General Standards | Product Standards |
GB 2761 National Food Safety Standard Maximum Levels of Mycotoxins in Food GB 2762 National Food Safety Standard Maximum Levels of Contaminants in Food GB 2763 National Food Safety Standard Maximum Residue Limits for Pesticides in Food GB 29921 National Food Safety Standard Maximum Levels of Pathogenic Bacteria in Prepackaged Food ... | GB 7101 National Food Safety Standard Beverages GB 7099 National Food Safety Standard Pastries, Bread GB 10765 National Food Safety Standard Infant Formula Foods ... |
Our Services
ZMUni offers the following food compliance-related services for businesses:
• Review of food formulations
• Review, translation, and creation of food labels
• Import customs clearance services
• Customized compliance training
• Customized compliance consulting
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