China - National Food Safety Standard – General Standard for the Labelling of Prepackaged Foods (GB 7718 2025)

Region: APAC - China

Status: Final regulation – not yet effective

Summary 

GB 7718‑2025 sets out comprehensive, horizontal rules for labelling of prepackaged foods in China, covering both products sold directly to consumers and those not sold directly to consumers. It defines key concepts such as prepackaged foods, food labels, digital labels, ingredients, and production date, and then establishes mandatory label elements including food name, ingredient list, net content, producer/operator information, date labelling, storage conditions, production license number, product standard code, allergen warnings, and other legally required information.

The standard refines requirements on ingredient listing (including composite ingredients and food additives), quantitative ingredient declarations when certain components are emphasized, allergen indication, imported food labelling, and use of digital labels. It emphasizes that the attribute name must reflect the true nature of the food and restricts misleading “new,” “unique,” “transliterated,” or regional names, aligning them in font size and style with the attribute name when they could mislead consumers. Although the text is horizontal and not cocoa‑specific, it will govern how cocoa and chocolate prepackaged foods (domestic and imported) are named, how ingredients (including cocoa components and additives) are presented, and how allergen and origin information is communicated to Chinese consumers.

Scope & Applicability

• Applies to labels of prepackaged foods provided directly to consumers and labels of prepackaged foods not provided directly to consumers.

• Does not apply to storage/transport packaging that only protects food during logistics, nor to labels of bulk food and ready‑to‑eat food sold loose.

• Covers both domestically produced and imported prepackaged foods; imported products must comply with the same core labelling rules, with specific provisions on Chinese language use, ingredient list correspondence, and origin indication.

  
  

Key Requirement

• Mandatory label content for prepackaged foods includes: food name (attribute name reflecting true characteristics), ingredient list, net content, name/address/contact of producer and/or operator, production date and shelf‑life expiry date, storage conditions, food production license number, product standard code, allergen warning, and other items required by laws, regulations, and national standards (subject to specified exemptions).

• Food name: an attribute name reflecting the true attributes of the food must appear prominently; if there is a name specified in national, industry, or local standards or official naming announcements, one of those (or an essentially identical name) must be used. Other names (new, unique, transliterated, slang, trademark) may be displayed on the same panel but, if potentially misleading, must be adjacent and in the same font and colour with height not greater than the attribute name.

• Ingredients: an ingredient list is required (including for single‑ingredient foods), with ingredients named per the naming rules and listed in descending order of added amount by mass, subject to limited exceptions for ingredients ≤2%, volatilized/removed ingredients, and some composite ingredients under 25% of the food. Composite ingredients generally must show their original ingredients in brackets, unless certain conditions on standards and low use level are met.

• Food additives: must be labelled with common names in GB 2760, GB 14880, or relevant announcements, and may also be shown with functional class names; compound additives must list all additives that function in the final product, with exemptions for processing aids/enzyme preparations that have lost activity and some carry‑over additives below 25% of the food. Annex B provides example formats.

• Quantitative ingredient/claim rules: when ingredients or components are specially emphasized in the label or in the food name, their added amount or content in the finished product must be indicated; the standard also regulates “none/does not contain” and prohibits “no addition/no use” style claims except where specifically allowed.

• Date, storage, and identification: standardized formats for production date and expiry date (usually year‑month‑day), shelf‑life labelling including for small packages, mandatory storage‑condition labelling, and requirements to mark food production license number and implemented product standard code on domestic products.

• Imported foods: imported prepackaged foods must meet the same core labelling requirements (with some exceptions for license number and product standard code), ensure alignment between foreign‑language and Chinese ingredient lists, indicate importer/agent information and manufacturer registration, and clearly label country/region of origin (plus filling/sub‑packaging country when different).

• Digital labels: the standard introduces rules for digital labels (e.g., QR‑based), requiring consistency with the physical label, clarity, accessibility, integrity, and compliance with national digital standards; digital labels can be used to provide extended information but cannot undermine mandatory physical labelling.

• Allergen labelling: Annex D sets out formats for allergen indication, either via emphasis in the ingredient list (easily recognizable names, possibly bold/underlined) or via explicit allergen prompts near the list; it also addresses statements for possible indirect or trace presence during processing.

  
  

Compliance deadlines

• Issued on 16 March 2025.

• Implementation (entry into force) date: 16 March 2027, giving operators a two‑year transition to update prepackaged food labels.

• After 16 March 2027, prepackaged foods within scope are expected to comply fully with GB 7718‑2025; any overlapping or prior general prepackaged labelling standard is expected to be superseded by this version for labelling matters.

  
  

Potential impact on cocoa sector

• All prepackaged cocoa and chocolate products marketed in China (including imported branded chocolate) will need to align product naming, ingredient lists, allergen statements (e.g. milk, nuts, soy), and digital label usage with the new general rules. This can require structural changes to front‑of‑pack naming (ensuring attribute names reflect true product attributes and are not overshadowed by promotional/trademark names) as well as re‑ordering and re‑phrasing ingredient lists (especially where composite chocolate ingredients are used).

• For complex chocolate products (filled, coated, multi‑component snacks), the composite‑ingredient provisions and quantitative‑emphasis rules will affect how chocolate and highlighted ingredients (e.g. “hazelnut,” “cocoa”) must be declared and quantified, which can influence packaging design and claim strategies for cocoa‑rich products.

• Imported cocoa and chocolate products will need careful harmonization between original foreign labels and the Chinese label, ensuring every foreign‑language ingredient has a corresponding Chinese declaration and that any cocoa‑related claims or images (e.g. “extra cocoa,” origin statements) meet the emphasis and quantitative labelling rules.

• The digital label framework creates opportunities to provide richer cocoa‑sourcing, sustainability, or allergen‑management information via QR codes, but such digital content must be consistent with the physical label and cannot correct misleading or non‑compliant physical information; cocoa companies may leverage this for traceability storytelling while maintaining strict compliance.

  
  

CAA Notes & interpretations

• GB 7718‑2025 is a cross‑cutting, non‑sector‑specific labelling standard; it does not create cocoa‑specific compositional rules but sets binding horizontal requirements that will govern how all cocoa and chocolate prepackaged foods are named and labelled in China from March 2027 onward.

• Given the two‑year transition, CAA members supplying China should plan a structured label‑migration program: mapping existing Chinese labels for cocoa/chocolate products against GB 7718‑2025, identifying gaps in food name structure, ingredient declaration (including composite chocolate components and additives), allergen statements, and imported‑food particulars.

• Special attention should be paid to: (1) alignment of “chocolate” attribute names with any future or existing product‑standard naming rules; (2) use of emphasized cocoa‑related imagery and claims, ensuring required quantitative declarations are in place; and (3) management of digital labels so that origin and sustainability information for cocoa is consistent with physical labels and broader Chinese regulatory expectations.

Downloadable source

English translation (commercial) used for this brief: GB 7718-2025 English PDF. Members should rely on the official Chinese‑language text issued by the National Health Commission and the State Administration for Market Regulation for legal compliance.