On March 16, 2025, the National Health Commission and the State Administration for Market Regulation issued three core documents: GB 7718-2025 "General Rules for Pre packaged Food Labeling", GB 28050-2025 "General Rules for Nutrition Labeling", and General Administration Order No. 100 "Measures for the Supervision and Administration of Food Labeling". The three new regulations will be officially implemented on March 16, 2027, and all old labeling rules will be abolished.
This article breaks down the six core changes of date labeling, ingredient list, nutritional content, promotional claims, font standardization, and violation penalties in one go. Food production, OEM, and e-commerce enterprises can directly compare and rectify them through self-examination.
1, The overall framework of the new regulations: two sets of national standards+one regulatory regulation, three in one control
1. GB 7718-2025 (Technical Bottom Layer)
Standardize the unfolding rules for all text, ingredients, dates, allergens, and composite ingredients on labels, replacing the old national standard of 2011.
2. GB 28050-2025 (Nutrition Labeling Special)
The mandatory nutrition labeling has been upgraded from "1+4" to "1+6", with the addition of mandatory labeling for saturated fat and sugar, and clear compliance boundaries for zero sugar, no sugar, and no additives.
3. General Administration Order No. 100 "Measures for the Supervision and Administration of Food Labeling" (Enforcement Penalty Layer)
Clear font size, layout position, prohibition of promotional words, sampling and judgment standards, and fine rules are the direct basis for market supervision and law enforcement.
2, GB7718-2025 Core Disruptive Changes (Label Layout Must be Changed)
1. The date annotation has been fully upgraded, and the expiration date must be indicated
Uniformly label the production date and expiration date in the order of "year, month, day"; The shelf life has become a voluntary labeling item;
Exemption exception: If the shelf life is ≥ 6 months and the packaging area is ≤ 20cm ², only the shelf life and expiration date can be marked;
Hard layout requirements: set up independent annotation areas for production date and expiration date; If it is not on the main display surface, it must be marked on the front with "see packaging XX position";
2. Major changes to ingredient list rules (including principles and key points for composite ingredients)
Single ingredient food must be labeled with an ingredient list, and the old regulations can be exempted and the rules can be cancelled;
Composite ingredient unfolding judgment: Without national/industry standards/landmarks (only enterprise standards), regardless of the addition ratio, all ingredients must be unfolded completely; There is a national standard and the addition is less than 25%, which can be simplified;
Food additive labeling: Compound additives must list all ingredients that have a process effect; The principle of substitution requires meeting four conditions simultaneously to be exempted from bidding;
Special emphasis must be placed on a certain ingredient (such as high linolenic acid, zero sucrose), and the content of that ingredient must be labeled simultaneously.
3. Mandatory labeling upgrade for allergenic substances
The 8 major categories of allergens (wheat, soybeans, milk, eggs, nuts, fish, crustaceans, sesame), whether or not brought in, must be clearly indicated as long as the finished product contains them, and small text hiding is prohibited.
4. Claiming to set a red line for 'no addition, zero addition'
Without legal basis, the use of synonymous terms such as "do not add, do not include, zero" is prohibited; If declaring 'no XX', specific substances must be listed and supported by testing data; It is strictly prohibited to label "zero addition" in a vague manner.
3, GB28050-2025 New Nutrition Labeling Regulations (mandatory update for all products starting from 2027)
1. Mandatory labeling project upgrade: 1+6 standard configuration
Energy, protein, fat, carbohydrates, sodium (original)+saturated fat, sugar (new mandatory label), if one is missing, the label is unqualified;
2. All products shall calculate NRV% uniformly; Saturated fat NRV=20g;
3. The quantitative standard for "sugar free, zero sugar" has been tightened: only sugar with a value of ≤ 0.5g per 100g can be labeled, and trehalose is included in the sugar value;
4. Pilot implementation of warning signs for high sugar, high salt, and high fat will be implemented, and warning labels will be mandatory in the future.
4, Regulatory Red Line of State Administration Order No. 100 (Enterprises are the easiest to fall into pitfalls)
1. Prohibited content for annotation
Prohibit words such as "special supply, exclusive supply, internal supply, military exclusive use";
Ordinary food is strictly prohibited from implying therapeutic or health benefits;
Without national standards, it is not allowed to label it as "suitable for children and infants";
The absolute language of 'most, first, completely no additions' will be comprehensively and strictly punished.
2. Font and Foreign Language Standards
The font size of foreign languages and Pinyin shall not exceed the corresponding standard Chinese characters; Mandatory information must be clearly labeled in Chinese;
3. Relaxation of origin labeling (favorable for food enterprises)
Cancel the mandatory requirement for labeling the origin of ordinary food; Only when there are special regulations marked in the national standard or industry, do they need to be labeled.
4. Refine the annotation rules for commissioned processing
The names and SC numbers of the commissioning party and the commissioned production party must be clearly marked, and the order must not deliberately confuse consumers.
5, Penalty Standards for Violations (Order No. 100+Dual Constraints of Food Safety Law)
1.General label defects: ordered to rectify within a specified period of time;
2.Mandatory items with false, misleading, or missing labels: fine of 5000 to 30000 yuan;
3.Serious circumstances and repeated warnings: production suspension for rectification, revocation of SC production license;
4.Serious violations will be included in the blacklist of serious dishonesty under Order No. 128, and multiple departments will jointly punish them. Bidding and loans will be restricted
6, Enterprise phased rectification action plan (to be completed by March 2027)
Phase 1: Before September 2026
1.Sort out all on sale and in design labels, check the date font height, ingredient list expansion, and allergen labeling;
2.Re calculate the nutritional composition table and update the saturated fat and sugar NRV% according to the 1+6 items;
3.Thoroughly investigate promotional phrases such as "zero additives, pure natural, and no anti-corrosion", and remove non compliant claims
Phase 2: Before December 2026
1.New version label sampling for inspection, completed internal compliance review;
2.Replace the coding equipment to ensure that the font height and contrast meet the standards for production date and expiration date;
3.Establish a ledger for raw material additives, follow the principle of accounting input, and standardize the labeling of composite ingredients.
Phase 3: Before March 2027
Old inventory labels will be cleared during the transition period, and all products manufactured after March 16, 2027 will use the new version of compliant labels. The continued use of old labels is prohibited.
7, Summary of high-frequency misconceptions and pitfalls in the industry
1. Misconception: If the composite ingredient is less than 25%, all additives inside do not need to be labeled
Correction: Exemption can only be granted if all four requirements of GB2760 are met simultaneously. If the additive has anti-corrosion and coloring effects on the finished product, it must be labeled;
2. Misconception: Trehalose is not considered sugar and can be labeled as 0 sugar at will
Correction: GB28050-2025 specifies that sugar contains 5 types of monosaccharides, and trehalose is included in the sugar content. If it exceeds the standard, it cannot be labeled as sugar free
3. Misconception: Old labels can be used until inventory runs out
Correction: Food produced after March 16, 2027 must comply with the new regulations; Previously produced inventory products can be sold until the end of their shelf life.
Conclusion and Summary
The new food labeling regulations in 2027 are not minor adjustments, but a restructuring of the entire industry labeling system. From date coding, ingredient list logic, nutritional ingredient list to promotional language, there are all new hard standards.
Completing label revisions and establishing compliance review mechanisms in advance is necessary to avoid the risks of sampling fines, delisting, and breach of trust penalties; Compliance labels are both a regulatory bottom line and a long-term competitive advantage trusted by consumers.
