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China - Quality Requirement for Chocolate and Chocolate Products, Chocolate with Cocoa Butter Alternatives and Chocolate Products with Cocoa Butter Alternatives (GB/T 19343 2025)

Traceability/ Labelling

10 April 2026

Region: APAC - China

Status: Final regulation – not yet effective

 

Summary

GB/T 19343‑2025 replacing GB/T 19343‑2016 is a recommended (GB/T) national standard establishes product classifications, raw‑material specifications, technical quality requirements, production and processing management, inspection rules, product naming principles, labelling/marking requirements, packaging, storage, transportation and sales conditions for chocolate, chocolate products, chocolate with cocoa butter alternatives, and chocolate products with cocoa butter alternatives. It defines key cocoa terms (cocoa butter, cocoa mass, cocoa cake, cocoa powder, cocoa butter alternatives, fat‑free cocoa solids, total cocoa solids, total milk solids) and then differentiates product categories such as dark, milk and white chocolate, various chocolate products (mixed, coated, candy‑coated) and their counterparts made with cocoa butter alternatives.


The standard links product names to underlying composition and quality criteria, including minimum cocoa‑ and milk‑solids contents, use and limits of cocoa butter alternatives, and sensory and physical requirements such as fineness. It also references national quality standards for cocoa mass, cocoa powder and cocoa butter (GB/T 20705, GB/T 20706, GB/T 20707) and includes normative appendices on determination of chocolate fineness and calculation methods, providing the technical basis for inspection and quality control in the Chinese chocolate sector.


Scope & Applicability

  • Applies to the production, inspection and sales of chocolate and chocolate products, chocolate with cocoa butter alternatives and chocolate products with cocoa butter alternatives.

  • Covers solid and semi‑solid foods with chocolate or chocolate‑like characteristics, including products where chocolate (or chocolate with cocoa butter alternatives) is mixed with, or used to coat, other foods.

  • Used as the quality basis for manufacturers, inspectors, and traders in China dealing with these chocolate categories, in combination with food safety and labelling standards.


Key Requirement

  • Product classification: chocolate is divided into dark chocolate, milk chocolate, white chocolate and other chocolate based on raw and auxiliary materials; chocolate products are divided into mixed, coated, candy‑coated and other products; parallel categories are defined for chocolate with cocoa butter alternatives and their products.

  • Definitions and raw materials:

    • Chocolate is defined as solid or semi‑solid food made from cocoa products (cocoa butter, cocoa mass, cocoa cake or cocoa powder) as main raw materials, with or without non‑cocoa vegetable fats, sugar, milk and dairy products and additives, with non‑cocoa vegetable fat mass fraction ≤ 5%.

    • Chocolate with cocoa butter alternatives uses cocoa butter alternatives as the main fat, with optional cocoa products and other ingredients, and is treated as a separate product category.

    • Cocoa mass, cocoa cake, cocoa powder and cocoa butter used must conform to their respective GB/T quality standards; other raw and auxiliary materials must comply with relevant standards.

  • Technical quality requirements:

    • Sensory requirements are specified for the chocolate component of chocolate and chocolate products (e.g. colour, structure, flavour, absence of foreign odours/defects).

    • Physical quality parameters such as fineness of chocolate are defined, with Appendix A providing reference/arbitration methods (e.g. micrometer method using liquid paraffin dispersion).

    • Additional composition and quality criteria (e.g. minimum contents, limits, and defect rules) are set out in the standard’s technical requirements and inspection rules sections.

  • Production and processing management: manufacturers must comply with quality‑management requirements (including GB/T 23822 for candy and chocolate production), and inspection rules govern lot formation, sampling, test items and determination of conformity.

  • Product naming and labels/marks:

    • Product names must correspond to the actual product classification and composition (e.g. dark chocolate vs milk chocolate, chocolate vs chocolate with cocoa butter alternatives, chocolate products vs chocolate products with cocoa butter alternatives).

    • Labelling and marking requirements ensure that use of terms such as “chocolate,” “chocolate with cocoa butter alternatives” and related descriptors accurately reflects product nature and fat composition, complementing general food‑labelling standards.


Compliance deadlines

  • Issue date: 24 January 2025.

  • Implementation date: 1 August 2026, from which GB/T 19343‑2025 replaces GB/T 19343‑2016 for the covered product categories.

  • From 1 August 2026, production, inspection and sales of chocolate and chocolate products (including those with cocoa butter alternatives) in China are expected to align with the new quality requirements, nomenclature and associated inspection rules.


Potential impact on cocoa sector

  • The standard formalizes clear boundaries between “chocolate” (≤5% non‑cocoa vegetable fat) and “chocolate with cocoa butter alternatives,” with separate product classes and naming rules, which will influence formulation strategy and product positioning in China. Products relying heavily on non‑cocoa vegetable fats must be labelled and marketed under the alternative‑cocoa‑butter categories, impacting premium perception and pricing.

  • Minimum quality criteria, raw‑material standards and technical parameters (e.g. cocoa mass/powder/butter specifications, fineness) require more stringent control of cocoa inputs and processing, likely increasing emphasis on consistent cocoa‑ingredient quality and supplier qualification.

  • For mixed, coated and candy‑coated chocolate products, classification under “chocolate products” vs “chocolate products with cocoa butter alternatives” will affect how these items are presented at retail and may interact with general and nutrition labelling rules (GB 7718‑2025, GB 28050‑2025), influencing pack design and consumer expectations.

  • International suppliers exporting into China will need to review formulations and Chinese product names for alignment with GB/T 19343‑2025 categories, especially where existing SKUs use compound coatings or significant levels of non‑cocoa vegetable fats.


CAA Notes & interpretations

  • GB/T 19343‑2025 is a quality and product‑classification standard rather than a food safety contaminant limit, but it has strong implications for how “chocolate” can be formulated and marketed in China, particularly around the distinction between chocolate and chocolate with cocoa butter alternatives.

  • CAA members should map their China‑destined chocolate portfolio against the new categories and definitions, checking non‑cocoa vegetable‑fat levels, cocoa‑solids composition, and product architecture (mixed, coated, candy‑coated) to confirm compliant naming and classification as of 1 August 2026.

  • Coordination with GB 7718‑2025 (general labelling) and GB 28050‑2025 (nutrition labelling) will be important: GB/T 19343‑2025 determines what products may legitimately use the term “chocolate” (or “chocolate with cocoa butter alternatives”) and thus underpins attribute naming and ingredient declarations on labels.


Downloadable source

English translation used: GB/T 19343‑2025 – Quality Requirement for Chocolate and Chocolate Products, Chocolate with Cocoa Butter Alternatives and Chocolate Products with Cocoa Butter Alternatives GBT19343-2025EN-P09P-H7528H-999279.pdf. For compliance and legal interpretation, companies should rely on the official Chinese‑language GB/T 19343‑2025 issued by the State Administration for Market Regulation and the Standardization Administration of the People’s Republic of China.

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