What is the purpose of marking? 
To inform the ultimate purchaser in the United States of the country in which the imported article was made. 

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Who is the ultimate purchaser? 
The ultimate purchaser is generally the last person in the United States who will receive the article in the form in which it was imported. 

If the article will be used in manufacture, the manufacturer or processor in the United States is the ultimate purchaser if the processing of the imported article results in a substantial transformation of the imported article, becomes a good of the United States under the NAFTA Marking Rules (19 CFR Part 102), or becomes a good of the United States under the textile rules of origin (19 CFR 102.21), as applicable. 

What is meant by &#;country&#;? 
Country means the political entity known as a nation. Colonies, possessions, or protectorates outside the boundaries of the mother country may be considered separate countries.

What is the country of origin? 
The country of manufacture, production, or growth of the article. 

Does altering the article in a second country change the country of origin? 
The country of origin of an article may be changed in a secondary country if one of the following occurs: 

1. If the further work or material added to an article in the second country constitutes a substantial transformation. A substantial transformation occurs if a new article with a different name, character, and use is created.
2. For a good from a NAFTA country: if under the NAFTA Marking Rules (19 CFR Part 102) the second country is determined to be the country of origin of the good; or
3. For an article considered to be a textile or apparel product (regardless of whether it is a good from a NAFTA country): if the country of origin is determined by the general rules set forth in 19 CFR Part 102.21 to be the second country. For purposes of determining whether a textile or apparel product is from Israel, the general rules in 19 CFR 12.130 apply.

Is it necessary for the words made in or product of to precede the name of the country of origin? 
The phrase &#;made in&#; is required only in the case where the name of any locality other than the country or locality in which the article was manufactured appears on the article or its container and may mislead or deceive the ultimate purchaser. The marking &#;made in (country)&#; or other words of similar meaning must appear in close proximity to, and in comparable size letters of, the other locality to avoid possible confusion. 

Use of the words &#;assembled in&#; may be used to indicate the country of origin of an article where the country of origin of the article is the country in which the article was finally assembled. &#;Assembled in&#; may be followed by the statement &#;from components of (the name of the country or countries of origin of all the components).&#;  

Should the marking be of a particular size? 
The marking must be legible. This means it must be of an adequate size, and clear enough, to be read easily by a person of normal vision.  

Where should the marking be located? 
The marking should be located in a conspicuous place. It need not be in the most conspicuous place, but it must be where it can be seen with a casual handling of the article. Markings must be in a position where they will not be covered or concealed by subsequent attachments or additions. The marking must be visible without disassembling the item or removing or changing the position of any parts.  

How permanent must the marking be? 
The article should be marked as indelibly and permanently as the nature of the product will permit. Marking that will not remain on the article during handling or for any other reason except deliberate removal is not a proper marking. 

Abbreviations and Variant Spellings  

Abbreviations that unmistakably indicate the name of a country, such as &#;Gt. Britain&#; for Great Britain or &#;Luxemb&#; for Luxembourg, are acceptable. Variant spellings which clearly indicate the English name of the country of origin, such as &#;Brasil&#; for Brazil and &#;Italie&#; for Italy are acceptable. However, it is always preferable to spell out the country&#;s name in full, because any abbreviation may be a cause for confusion.  

However, &#;E.C.&#; or &#;E.U.&#; for European Community or European Union, respectively, are not acceptable abbreviations since they do not indicate the individual country of origin of the good.  

How to Stay Compliant with China&#;s Labeling Requirements for Imported Food

This article unpacks the legal landscape, recent developments, and strategies to ensure compliance with China&#;s food labeling landscape, offering a comprehensive guide for businesses aiming to thrive in this dynamic sector.

With a population exceeding 1.4 billion people and a growing middle class with an appetite for diverse culinary experiences, China&#;s food market has become a focal point for those seeking international expansion and market diversification.

Over the past two decades, this market has undergone a significant transformation, characterized by an escalating dependence on food imports, with the country ranking as the world&#;s largest importer of various food products. This shift is underscored by a noteworthy decline in the country&#;s food self-sufficiency ratio, coupled with shifting dietary preferences that have led to increased imports of edible oils, sugar, meat, and processed foods.

Given China&#;s growing reliance on food imports and the evolving tastes of its diverse consumer base, it offers a compelling opportunity for food exporters worldwide to tap into this expanding market.

However, in light of these evolving dynamics, understanding and adhering to China&#;s food labeling regulations for imported prepackaged foods take on even greater significance. Accurate and compliant labeling is not merely a legal requirement; it is a strategic imperative. These labels serve as the bridge connecting foreign products with Chinese consumers, providing vital information about the product&#;s content, origin, and safety. Moreover, they play a pivotal role in establishing trust and credibility among Chinese consumers, who are becoming increasingly discerning and health conscious.

In this article, we delve into China&#;s food labeling regulations, identify potential legal risks, and outline practical strategies for compliance.

Legal framework for imported food labeling in China

Understanding the legal framework governing imported food labeling is crucial for businesses and investors seeking to operate in the Chinese market. China has established a comprehensive set of regulations to ensure the safety and transparency of food products available to its consumers. This section explores the key components of this legal framework.

To be noted, the food labeling requirements introduced in this article applies mainly for food imported through general trade. In some contexts such as that of cross-border e-commerce trade, the labeling requirements may vary depending on the type of products being imported and the special trade model. For example, food sold to Chinese consumers through cross-border e-commerce platforms might be exempted from attaching the Chinese label on the package of the product, though relevant information still needs to be provided on the webpage. In addition, there have been discussions about potential exemptions for certain low-risk or small-scale cross-border e-commerce transactions.

China Food Safety Law

The cornerstone of food safety regulations in China is embodied by the China Food Safety Law. Enacted in and subsequently amended, this law sets out the fundamental principles and requirements for food safety management in the country. It addresses various aspects of food production, distribution, and labeling.

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Key provisions of the China Food Safety Law related to food labeling include:

• Labeling requirements: The law specifies that food labels must provide accurate and comprehensive information to consumers, including ingredient lists, nutrition facts, and allergen information.
• False or misleading claims: Provisions in the law prohibit false or misleading claims on food labels, ensuring that consumers are not deceived by inaccurate marketing.
• Product origin: The law mandates the disclosure of the product&#;s place of origin, which is of particular importance to Chinese consumers who are increasingly concerned about food safety and quality.

National standards for food labeling in China

As part of the Customs clearance process, every food product entering China is obligated to feature labeling exclusively in simplified Chinese characters. China has instituted a comprehensive framework of regulations delineating precise specifications for the labeling of food and beverage products within its borders. These regulations encompass diverse facets, as summarized in the table below.

To facilitate compliance with these regulations, China has devised national standards offering comprehensive directives for food labeling. These standards serve as indispensable guidelines for businesses to ensure that their labeling practices align with Chinese requirements. A selection of pivotal national standards pertaining to food labeling is presented in the table below.

In general, a label must provide the following:

• The standard name of foodstuff;
• List of ingredients as a percentage;
• Name and address of manufacturers, local agent, or distributor;
• Production date, best before, end date, and guidance for storage;
• Country of origin;
• Quality grade;
• Code of national standard/industry standard for the production; and
• Special contents, if any.

As label standards in China are subject to change, foreign businesses and investors are advised to consult experts to ensure compliance with the updated label requirements.

Recent developments and emerging trends in nutrition labels

The existing national standard for nutrition labels on prepackaged food in China, GB-, has undergone multiple revisions since to adapt to evolving requirements in food nutrition labeling. In , the Professional Committee of the National Food Safety Standards Review Committee convened to assess and endorse the new draft of GB -20×× National Food Safety Standard General Principles for Nutrition Labels for Prepackaged Food (hereafter referred to as the &#;new draft&#;).

In the table below, we present a summary of the significant revisions featured in the draft that directly impact food labeling regulations in China and anticipate future trends in this field.

 

Key Changes in the New Draft of the National Food Safety Standard General Principles for Nutrition Labels for Prepackaged Food

Item Details A redefined scope of application The revised standards explicitly broaden their scope to encompass nutrition labels on packaged foods and packaging meant for storage and transportation, not intended directly for consumers. This modification primarily addresses nutrition labels on certain B2B product packaging, ensuring that the draft standard applies consistently. Clarification for pre-packaged food labeling Compared to the previous draft under review, the new version distinctly outlines that the nutritional labeling content for imported pre-packaged foods must adhere to the provisions within this standard. Enhancement of label content The &#;Draft&#; introduces two additional mandatory labeling elements: saturated fat (acid) and sugar. Consequently, the mandatory labeling content shifts from 1+4 (energy + protein, fat, carbohydrate, sodium) to 1+6 (energy + protein, fat, saturated fat (or saturated fatty acid), carbohydrate, sugar, sodium). Clarification of sugar definition The revised draft provides explicit reference to the definition of sugar in Codex, United States, and European Union regulations, aligning with the international understanding of sugar. It specifies that the sugar listed on a nutrition label should encompass the sum of monosaccharides and disaccharides, excluding sugar alcohols. Warning messages Warning messages have been incorporated, requiring pre-packaged foods to include clear labels such as &#;Children and adolescents should choose foods high in salt, fat, and sugar in moderation.&#; This addition aims to promote a healthy lifestyle and endorse the &#;Three Reduce&#; dietary action policy&#;reducing salt, oil, and sugar. Revised requirements for energy and nutrient content claims

• The draft introduces several changes to requirements for energy and nutrient content claims as well as comparison claims.
• Energy claims, such as &#;NO CALORIES,&#; will be treated the same as a claim of &#;NO ENERGY.&#;
• Requirements and claims for n-3 polyunsaturated fatty acid have been added.
• Specific claims for dietary fiber have been outlined, including &#;Source of soluble dietary fiber (or monomer),&#; &#;Contains soluble dietary fiber (or monomer),&#; and &#;High or rich in soluble dietary fiber (monomer).&#;
• The claim of &#;Low protein&#; has been removed, along with the restriction on the claim of &#;No saturated fat.&#;
• The restriction condition for &#;degreasing&#; has been revised to require that other dairy products meet the corresponding national food safety standards.
• The restriction for &#;Low saturated fat&#; has been modified to a saturated fat energy ratio of &#;10%.
• The item &#;Carbohydrate (sugar)&#; has been separated into distinct entries for &#;Sugar&#; and &#;Lactose,&#; with corresponding content requirements and restrictive conditions remaining unchanged.

Legal risks for imported food labeling

Language and translation challenges

As illustrated in the related national standards and relevant regulations, Chinese labeling requirements for imported food products are rigorous and non-negotiable. Businesses must adhere to the following aspects of Chinese labeling requirements:

• Language: All labeling information must be provided in simplified Chinese characters, the official script of China. Dual-language labeling (e.g., Chinese and English) is permissible, but the Chinese text must take precedence in terms of prominence and legibility.
• Content: Labels must include key information, such as product name, ingredient list, net weight or volume, shelf life, storage conditions, and usage instructions.
• Font size: The font size should be legible and meet specified requirements to ensure consumers can easily read the label.

Accurate translation of food labels is paramount to prevent misunderstandings and legal issues. Common translation challenges include:

• Cultural nuances: Translating names, claims, or descriptions can be challenging due to cultural differences. Phrases that are acceptable in one language may have a different connotation in another.
• Regulatory terminology: Understanding and correctly translating regulatory terms and requirements specific to food labeling in China is crucial.

Compliance with Chinese Standards

Several aspects key aspects of compliance with the Chinese standards for food labeling and regulations include:

• Ingredient declaration: China requires detailed ingredient declarations on food labels, and this can be challenging for imported products. Businesses must accurately list all ingredients, including additives and flavorings, in descending order of predominance by weight.
• Nutritional labeling: China mandates nutrition labeling on prepackaged foods. As such, businesses exporting food products to China should provide accurate information on energy, protein, fat, carbohydrates, and other nutrients in accordance with the national standards.
• Allergen information: Failure to disclose allergen information can pose significant risks. Businesses must clearly identify and highlight the presence of common allergens such as peanuts, milk, soy, and wheat in the ingredient list.

Misleading or false information

Making misleading or false claims on food labels can lead to consumer deception and regulatory consequences. Therefore, it is vital for producers to ensure all product claims, such as health benefits or quality attributes, are substantiated and comply with Chinese regulations.

Additionally, accurate product origin labeling is another crucial point. Misrepresenting the origin can result in legal issues

Non-compliance consequences

When it comes to imported food labeling in China, non-compliance with regulations can carry hefty consequences that extend beyond mere legalities.

Penalties and fines

One of the most immediate and tangible consequences of non-compliance is the imposition of penalties and fines. These financial penalties can vary widely, depending on the severity of the violation. In practice, they may range from thousands to millions of yuan.

Product recall and seizure

In cases of severe non-compliance or when public health and safety are at risk, regulatory authorities in China possess the power to order the recall and seizure of non-compliant products. This action is not only swift but also carries severe consequences.

A product recall can be financially devastating. It involves the removal of the product from the market, often resulting in not only the loss of revenue but also the cost of managing the recall process. Moreover, it can damage a company&#;s reputation and consumer trust, making it challenging to rebuild consumer confidence.

Access restrictions

Persistent non-compliance can lead to more far-reaching consequences, including access restrictions. This means that the business may face significant hurdles when attempting to export its products to China or may even have its products removed from the market entirely.

These access restrictions can have profound implications for a company&#;s long-term market presence. Challenges in exporting products to China limit growth potential and may necessitate a reassessment of market strategy. Furthermore, having products removed from the market can result in loss of market share, eroded brand reputation, and potential damage to investor confidence.

Strategies to mitigate legal risks

Navigating the intricate landscape of imported food labeling in China requires a proactive approach that encompasses a variety of strategies to ensure compliance and safeguard against legal risks. We list a few best practices in this regard:

• Stay informed and adapt: The regulatory landscape in China is dynamic and ever-evolving. Keeping abreast of the latest labeling regulations is foundational. Regularly review and update your knowledge base to ensure that your product labels remain fully compliant with the most current requirements.
• Leverage local expertise: Engage the services of local experts who possess a deep understanding of Chinese regulations. Their insights, ability to interpret nuances, and familiarity with the intricate regulatory framework can prove invaluable
• Ensure precise translation: Accurate translation of your product labels is another critical aspect of compliance. Employ professional translation services specializing in food labeling to guarantee precise and culturally appropriate translations. Recognize that inaccuracies in translation can lead to misinterpretation and potential legal complications.
• Comprehend key terms: Familiarize yourself with key regulatory terms and phrases specific to Chinese food labeling. This understanding enables effective collaboration with translation professionals, ensuring that your labeling remains accurate and fully compliant.
• Navigate pre-market approvals: If your product requires pre-market approvals or certification, collaborate closely with Chinese authorities to expedite the process. Be well-prepared to furnish all necessary documentation and information promptly.
• Swift response to non-compliance: In the event of discovering any labeling non-compliance issues, address them swiftly. Report potential non-compliance to regulatory authorities promptly, demonstrating a commitment to rectifying errors and maintaining transparency.

 

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