Major Revision of GB 7718-2025 for Imported Prepackaged Foods: New China Prepackaged Food Labeling Requirements Every Overseas Food Factory Must Know

The National Food Safety Standard: General Standard for the Labeling of Prepackaged Foods (GB 7718-2025) was released in 2025 and will officially take effect on March 16, 2027.

For overseas food manufacturers and Chinese importers, this is not just a minor adjustment. It completely redefines what qualifies as imported prepackaged food and what information must be displayed on labels.

The new regulation will particularly impact two categories of products that previously followed the “bulk food” approach:

• Imported nuts and confectionery products sold by weight
• Individually packaged imported cakes and bakery products

1. Expanded Definition: Overseas Factories Can No Longer Avoid Prepackaged Food Regulations for Weighed or Individually Packaged Products

Under the previous version (GB 7718-2011), products were mainly judged based on whether they were “pre-quantified and labeled with a unified net content.”

As a result, large packages of imported nuts and individually wrapped bakery products were often treated as bulk goods when repacked or sold domestically.

The new standard officially includes foods that are:

“Pre-packaged or produced in packaging materials and sold by measurement (by weight or by unit)” within the scope of prepackaged foods.

Imported Snacks Sold by Weight

Imported large bags of nuts or gummies from overseas → repacked into smaller bags and sold by weight in China → from 2027 onward, classified as imported prepackaged food and must carry Chinese labels.

Individually Packaged Imported Cakes and Bakery Products

Individually sealed cakes produced overseas or by domestic contract manufacturers, as well as cookies sold by individual units → must comply with prepackaged food labeling requirements.

⚠️ Products weighed and packed after purchase at the sales site, and freshly prepared catering products, are not considered prepackaged foods. However, products that are “sealed before weighing and sale” are considered prepackaged foods.

Impact on Overseas Food Factories

Even if you only ship large packages to China and the domestic distributor performs the repackaging, as long as the final product is: “pre-packaged + sold by measurement,”

the entire supply chain may be subject to prepackaged food compliance requirements.

2. Dedicated Chapter for Imported Products: Overseas Factories Must Pay Attention to 4 Additional “China-Specific” Requirements

For the first time, GB 7718-2025 introduces a dedicated section for imported prepackaged foods.

The requirements are as strict as those for domestic products, with additional mandatory obligations:

1. Country/Region of Origin + Country of Filling/Repackaging

When multiple countries are involved, the country of origin is determined by the “country where the last substantial transformation takes place.”

If filling or repackaging is conducted overseas, both the:

• Country of origin
• Country of filling/repackaging

must be indicated on the label.

2. Overseas Enterprise Registration Number

The overseas manufacturer’s registration number in China or the official registration number issued by the exporting country must be printed on the Chinese label (in accordance with GACC Order No. 280).

3. Chinese Importer/Agent Information

The name, address, and telephone number of the domestic importer or agent must be provided. An email address alone is not sufficient. The importer/agent is the responsible entity for compliance.

4. Complete Consistency Between Chinese and Foreign Labels

Chinese and foreign labels must correspond accurately.

If certain information is not shown on the foreign label but is mandatory under Chinese regulations (such as allergens or saturated fat), it must be added to the Chinese label.

If the original label only shows “Best Before,” the production date must be calculated and added through supplementary labeling.

3. Updated Compliance Red Lines: Overseas Formulas Must Be Rechecked and Labels Redesigned

“No Added / Zero / Free From” Claims Are Strictly Restricted

Common overseas marketing phrases such as:

• “No Added Sugar”
• “No Added”
• “Sugar Free”

must be removed unless the product has been scientifically tested to meet the requirements and the actual content is clearly declared.

8 Major Allergens Must Be Highlighted in Bold or Underlined Format

High-risk categories include:

• Nuts
• Dairy products
• Eggs
• Gluten-containing products

Western-style bakery products and mixed nuts are particularly affected.

8 Major Allergen Categories

1. Cereals Containing Gluten and Their Products

Including: Wheat, rye, barley, oats, spelt wheat, and related hybrid varieties

Examples:

• Flour
• Bread
• Biscuits
• Noodles
• Beer
• Soy sauce containing wheat

2. Crustaceans and Their Products

Including: Shrimp, lobster, crab, crayfish, etc.

Examples:

• Shrimp paste
• Crab powder
• Shrimp products
• Crab sticks

(Shellfish are not included and remain voluntary labeling.)

3. Fish and Fish Products

Including all edible fish.

Examples:

• Fish paste
• Fish sauce
• Canned fish
• Fish meal

(Fish gelatin and refined fish oil are exempt.)

4. Eggs and Egg Products

Including: Chicken, duck, goose, and quail eggs

Examples:

• Whole egg powder
• Mayonnaise
• Cakes
• Egg-washed bakery products

5. Peanuts and Peanut Products

Including:

• Peanuts
• Peanut butter
• Crushed peanuts
• Non-refined peanut oil

(Peanut is classified separately and is not considered a tree nut.)

6. Soybeans and Soy Products

Including: Soybeans, black beans, green beans

Examples:

• Tofu
• Soy milk
• Soy sauce
• Soy protein
• Miso

(Refined soybean oil and soy lecithin are exempt.)

7. Milk and Dairy Products (Containing Lactose)

Including: Cow’s milk and goat’s milk

Examples:

• Milk powder
• Cheese
• Cream
• Yogurt
• Whey protein
• Lactose

8. Nuts and Nut Products

Tree nuts include:

• Walnuts
• Almonds
• Cashews
• Hazelnuts
• Pistachios
• Macadamia nuts
• Pecans
• Pine nuts
• Chestnuts

(Peanuts are excluded.)

Dual Date Requirement: Production Date + Expiration Date

Production date and expiration date must follow the strict format:

Year-Month-Day

However, under certain conditions, only the expiration date may be required.

Either of the following conditions allows the manufacturer to omit the production date and only display: Shelf Life + Best Before/Expiration Date

1. Shelf Life ≥ 6 Months

Examples:

• Canned foods
• Cooking oils
• Most vitamins and fish oil products

For long shelf-life products, the production date has limited significance for freshness evaluation.

2. Maximum Package Surface Area ≤ 20 cm²

Examples:

• Small stick packages
• Mini bottles
• Small gummy candy packages

Due to limited label space, only the expiration date may be displayed.

Nutrition Labeling GB 28050-2025

The “1+6” mandatory nutrition labeling system now requires the addition of:

• Saturated fat
• Sugar

Imported snacks must also comply.

4. Digital Labels: A Compliance Solution for Small Imported Packages

For imported snacks with a maximum package surface area of ≤20 cm², the physical label may only need to display:

• Product name
• Net content (or “sold by measurement/weight”)
• Expiration date
• Storage conditions

Other required information can be provided through a QR-code-based digital label.

The first-level webpage must directly display the complete Chinese label without pop-up windows.

For overseas factories, this provides a low-cost compliance transition solution.

5. Three Actions Overseas Factories Should Take Now

1. Review China-Bound SKUs

Products requiring reassessment include:

• Weighed and repacked nuts
• Individually packaged cakes
• Small-package candies

All should be reviewed according to imported prepackaged food requirements.

2. Provide a “Compliance Master Label” to Chinese Importers

The label version should:

• Remove prohibited “zero addition” claims
• Add allergen information
• Prepare saturated fat and sugar testing data
• Confirm China registration numbers

3. Use the Two-Year Transition Period to Update Packaging

Replace old packaging materials with the 2027-compliant version to avoid:

• Product returns due to non-compliant labels
• Professional consumer claims (“professional anti-counterfeiting” actions)

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