On December 23, 2022, the China National Center for Food Safety Risk Assessment issued the National Food Safety Standard the Labeling of Prepackaged Foods for Special Dietary Uses (draft) to widely solicit opinions from various industries and enterprises. The deadline for comments is December 29, 2022. In order to facilitate various industries and enterprises to better understand the draft, Antion interpreted the main changes for your reference.

Deleted some definitions and requirements

Deleted the definitions of "nutrients", "nutritional components" and "shall not involve the function of disease prevention and treatment". As the above contents have detailed provisions in the General Rules for the Nutrition Labeling of Prepackaged Foods, the General Standard for the Labeling of Prepackaged Foods and the Food Safety Law respectively, in order to better connect with the above regulations and standards, the draft does not repeat them.

Newly added the mandatory labeling contents

1) "Foods for special dietary uses" and corresponding category names

In order to facilitate consumers to better distinguish general food and foods for special dietary uses as well as more standardized label management by regulatory departments, the draft revised the labeling of "foods for special dietary uses" into the mandatory labeling content, and the label should also be marked with corresponding category names of foods for special dietary uses in accordance with Appendix A.

2) "Saturated fat (or saturated fatty acid)" and "sugar" in nutrition information

In addition to the labeling of energy, protein, fat, carbohydrates and sodium, a new requirement has been added to the labelling of saturated fat (or saturated fatty acid) and sugar on the nutrition information of prepackaged foods for special dietary uses (excluding infant formula and full nutritional formula for special medical purpose).

Infant formula and full nutritional formula for special medical purpose have more specific labeling methods in the corresponding standards, so the labeling on the nutrition information can comply with the relevant provisions, and the draft does not provide additional provisions.

Modified the content values and labeling requirements for fat, saturated fat, sugar and sodium

The draft modified "the actual content of energy and nutrients should not be lower than 80% of the label value within the shelf life" to "the actual content of energy and nutrients (excluding fat, saturated fat, sugar and sodium) should not be lower than 80% of the label value and the actual content of fat, saturated fat, sugar and sodium should not be higher than 120% of the label value within the shelf life".

Since the mandatory labeling of saturated fat and sugar is newly added, the upper limits on restrictive ingredients such as fat, saturated fat, sugar and sodium have been established to facilitate compliance management for nutrition label of foods for special dietary uses.

Adjusted the requirements for exemption labeling

The draft clearly modified the maximum surface area of exemption labeling of prepackaged foods for special dietary uses (excluding infant formula, infant formula for special medical purpose and food for special medical purpose) from "less than 10cm²" to "less than 20cm²". If the above exemption condition is met, only product name, net content, name and address of the manufacturer (or distributor), production date and shelf life may be marked. The size of the exemption labeling area should be consistent with GB 7718 General Standard for the Labeling of Prepackaged Foods (draft for comments).

The maximum surface area of exemption labeling of infant formula, infant formula for special medical purpose and food for special medical purpose is modified from "less than 10cm²" to "less than 40cm²". If the above exemption condition is met, only product name, net content, name and address of the manufacturer (or distributor), production date, shelf life and nutrition information may be marked.

Due to the special nature of infant formula, infant formula for special medical purpose and food for special medical purpose, the nutrition information must be mandatory and cannot be exempted.

Modified the claim contents

1) Modified the product categories for which content claims can be made

2) Modified the conditions of content claims

3) Modified "function claims" to "role claims"

Modified the categories of foods for special dietary uses

The category of infant formula excluding infant formula for special medical purpose, "older infants and young children formula" is divided into "older infants food" and "young children formula", which is connected with the newly released GB 10766 Older Infants Formula and GB 10767 Young Children Formula; "other complementary foods for infants and young children" is added to the complementary foods for infants and young children; "food for special medical purpose" is subdivided into "infant formula for special medical purpose" and "food for special medical purpose (over one year old)"; the category of "nutritional supplements" is newly added and subdivided into three categories: "complementary food supplements", "nutritional supplements for pregnant women and nursing mothers" and "nutritional supplements for other specific groups"; make a separate category for "sports nutrition food"; the categories of other foods for special dietary uses are newly added, such as "formula for weight control" and "gluten-free/low-gluten food".

Newly added appendix "Allowable Content Claims and Role Claims"

Table B.1 lists the allowable content claims in some prepackaged foods for special dietary uses, and Table B.2 lists the allowable role claims in some prepackaged foods for special dietary uses. The above related content claims and claim words are the terms listed in the GB 13432-2013 Q&As, which have been widely used in the industry, and the formal inclusion of them in the standard facilitates the better implementation of the standard by enterprises.

Through the interpretation of the above draft, Antion hopes to help foods for special dietary uses-related enterprises and industry related personnel better understand the changing trend of regulations and standards and the regulatory trend, so as to provide a reference for the next step.

Source: Antion

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