China - National Standard on Food Safety – National Label Standard for Prepackaged Food (GB 28050 2025).

Region: APAC - China

Status: Final regulation – not yet effective

Summary 

GB 28050‑2025 sets out China’s horizontal framework for nutrition labelling of prepackaged foods, specifying how energy and nutrient information and related claims must be presented on nutrition labels. It defines core terms such as nutrition label, nutrition information table, energy, nutrients, nutrient reference values (NRV), nutrition claims, nutrient effect claims, and serving reference values, and then prescribes basic principles, mandatory and optional nutrition labelling content, and standardized wording and formats.

The standard requires prepackaged foods to carry a nutrition information table and regulates the use of nutrition content claims, comparative claims, and nutrient effect claims, including standardized phrases for nutrients like protein, fat, sugar, dietary fibre, sodium, vitamins, and minerals. It also establishes rounding rules, NRV values and use, conditions and synonyms for claims (e.g. “low,” “free,” “source,” “high”), exemptions for certain foods from mandatory nutrition labelling, and recommendations on serving‑size reference values. While not cocoa‑specific, it directly affects how cocoa and chocolate products declare energy, macronutrients, sugars, and other nutrients, and how they can communicate nutrition and nutrient‑function messages in the Chinese market.

Scope & Applicability

• Applies to nutrition labels of prepackaged foods directly provided to consumers.

• For prepackaged foods and storage/transport packages not directly provided to consumers, if nutrition labels are used, they must follow this standard.

• Nutrition labels are considered an integral part of prepackaged food labels and must comply with this standard whenever present, including for imported prepackaged foods.

  
  

Key Requirement

• Nutrition labels must be truthful, objective, and not exaggerated; they must not mislead consumers or overstate nutritional effects.

• Nutrition information table:

  • Must be presented clearly, eye‑catchingly, and durably in a “block table” format (with specified exceptions) and titled “Nutrition Information Table.”

  • Energy and nutrient contents must be expressed as specific values per 100 g, per 100 mL, and/or per edible part; if per serving is used, the mass/volume per serving must be indicated on the same page.

• Language: nutrition labels must use standardized Chinese characters; any concurrently used minority or foreign languages must be consistent in meaning and not exceed the height of Chinese characters.

• Mandatory nutrition labelling content (unless exempt under the standard) includes energy and key nutrients specified via NRV, expressed with correct units, NRV percentages, and rounding rules as per Appendix A and Appendix B.

• Nutrition claims:

  • Content and comparative claims (e.g. “contains,” “source,” “high,” “low,” “free,” “increase,” “decrease”) must meet the conditions and use the terms listed in Appendix C.

  • Nutrient effect claims must use standardized wording from Appendix D (e.g. for energy, protein, fats, sugar, dietary fibre, sodium, vitamins, minerals) and must not go beyond the health‑effect scope allowed.

• Exemptions: certain categories of prepackaged food are exempt from mandatory nutrition labelling requirements per Section 7, though voluntary nutrition labelling, if used, must still comply with the standard.

  
  

Compliance deadlines

• Issue date: 16 March 2025.

• Implementation date: 16 March 2027, from which prepackaged foods within scope must meet GB 28050‑2025 for nutrition labelling.

• During the transition, existing products may follow the previous nutrition‑labelling standard, but operators should plan to align all labels with GB 28050‑2025 by the implementation date.

  
  

Potential impact on cocoa sector

• All prepackaged cocoa and chocolate products sold in China will need to present their nutrition information tables and any nutrition or nutrient‑function claims in line with GB 28050‑2025, which may necessitate updates to panel layout, nutrient lists, units, NRV % calculations, and rounding.

• Use of claims such as “source of fibre,” “high fibre,” “low sugar,” “no added sugar,” “reduced sugar,” or statements about energy, fats, or minerals (e.g. calcium, magnesium) on cocoa and chocolate products will be strictly conditioned by the values and terms in Appendix C and Appendix D, potentially affecting existing marketing and front‑of‑pack messages.

• Imported chocolate brands will need to ensure that translated Chinese nutrition labels (including NRV calculations and any claims) match GB 28050‑2025’s definitions and claim conditions, which may differ from Codex or other jurisdictional rules.

• For cocoa products used as indulgent yet “better‑for‑you” offerings (e.g. high‑cocoa dark chocolate with fibre or minerals), compliance with standardized nutrient‑effect phrases could both constrain free‑form wording and create clearer, harmonized messages that can be leveraged consistently across portfolios.

  
  

CAA Notes & interpretations

• GB 28050‑2025 is a horizontal nutrition‑labelling standard; it does not introduce cocoa‑specific composition requirements but sets the framework for how cocoa and chocolate products can present and claim nutrition information in China from March 2027.

• CAA members should map existing nutrition labels for cocoa/chocolate products (domestic and imported) against the new requirements—particularly energy units, nutrient lists, NRV %, claim conditions, and standardized nutrient‑effect statements—and plan a phased artwork and specification update program ahead of the 2027 deadline.

• Coordination between GB 28050‑2025 and GB 7718‑2025 will be critical: the former governs nutrition labelling and related claims, while the latter sets general label requirements; cocoa and chocolate labels destined for China must comply with both in an integrated way.

  
  

Downloadable source

English translation used: GB 28050‑2025 National standard on food safety – National label standards for pre‑packaged food GB 28050-2025 English PDF. For legal purposes, companies should rely on the official Chinese‑language GB 28050‑2025 text issued by the State Administration for Market Regulation and the National Standardization Administration.