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1.Background introduction
Ø    As the world’s largest imported food market, China imported totally 38 billion US dollars food products from187 countries in 2016.
Ø   The growing China market has attracted a lot of interest from countries over the world. Meanwhile China government has, over the last years, developed a tougher and tougher regime on food regulations to regulate the market and ensure food safety.
Ø    Due to various challenges (languages, resources, information accessibility etc.), foreign SMEs learned a lot lessons and experienced big losses due to non-compliance with Chinese regulations. Actually, majority of these non-compliance could be easily prevented if SMEs have reliable regulatory information in hand.

1.1 China - world’s largest imported food market 


Source: AQSIQ—General Administration of Quality Supervision, Inspection and Quarantine of the people’s republic of China

1.2 Challenges for foreign companies
Enter to China
Ø  Different culture & language barrier
Ø  Not familiar with regulatory structure and supervision mechanism
Ø  Lose opportunities due to time consuming process
Stay in China
Ø  Not reachable for timely & accurate information
Ø  Fail to response quickly for risk & crisis
Ø  Lack of food industry network in China
 
 
1.3  Growing import refusal and on-market inspection non-compliance
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Source: AQSIQ and CFDA

2. How food products export to China

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3. China food regulation structure for imported food

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Frequent regulation update in recent years
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4. Analysis on the top import refusal reasons 

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Source: AQSIQ 
Additives, label, license and certification related non-compliance are largely NOT related with product quality or quality itself is good. And losses due these non-compliances reasons can be easily prevented by proper feasibility study and compliance control.
4.1 Food additives
1) Laws and regulations: Food Safety Law, GB2760-2014, GB 14880-2012  

2) The additive added is not approved:
      Case: Tianjin Airport Entry-Exit Inspection and Quarantine Bureau confirmed on August 2, 2016 that the XX milk calcium soft capsules involved in the labeling contained "vitamin D3".
      Results: It did not meet the "Regulations for the Use of Food Nutrition Enhancers" (GB14880-2012). No safety assessment was conducted with the health administrative department of the State Council. It violated the "Food Safety Law of the People's Republic of China" and entry was not allowed.

4.2 Label
According to the relevant laws and regulations and standards, labeling requirements in China are summarized as 6&10, which means 6 principles and 10 factors for food labeling, more details please see the below:
4.2.1 Six principles
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1) Accuracy &Authenticity
Reflect the true nature of the product actually without false information, exaggeration, not misleading and cheating.
2) Scientificity
Have scientific basis, no propaganda violating science as superstition and pornography, etc., and do not belittle other foods.
3) Different from medicine & health food
Do not perform the propaganda of having prevention, treatment and health care functions either expressed or implied.
4) Simplified Chinese
Simplified Chinese must be used, other language fonts shall not be greater than the corresponding Chinese characters.
5) Legible, striking and lasting 
Separated from the food, the character height must be greater than 1.88 mm, the character of net content shall be higher.
6) Comprehensiveness
All label factors of corresponding food shall be identified.
4.2.2 Ten factors
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1) Product name
Ø The special name reflecting the true nature of the food shall be clearly indicated on the prominent place of the food label.
Ø When labeling the “Coined name”, “Fanciful name”, “Transliterated name”, “Brand name”, “Folk name” or “Trade name”, the name complying with the provisions of 4.1.2.1 in GB7718-2011 shall be indicated on the same display panel.
Ø There shall appear on the label either before or after the name of the food, such additional words or phrases as necessary to avoid misleading or confusing the consumer in regard to the true nature, physical condition of the food, or method of preparation of the food; for example dried, concentrated, reconstituted, cured, fried, powdery, granular and etc.
2) Ingredients list
Ø The ingredient slist shall be titled “Ingredients” or “Ingredients list”;
Ø All ingredients shall be listed in descending order of their quantity added in the process of production or preparation of the food; those ingredients constituting less than 2% of the food may not be listed in descending order;
Ø Where the sweeteners, preservatives, coloring agents were directly used in food, the specific name shall be indicated under the food additives items of list of ingredients;
Ø Where other food additives were used, the specific name, type or code shall be indicated.
The labeling of compound ingredients in the ingredients list can be divided into the following two conditions:
Ø If the compound ingredients added directly to food have nationals, industrial or local standards and their added amount constituting less than 25% of the food, there is no need to indicate the original ingredients of the compound ingredients. In the case of the compound ingredients constituting less than 25% of the food, if there is any food additive in the above-mentioned compound ingredients, and the food additive complies with the carry-over principle stated in GB 2760 and serve no technological functions in the final product, then the food additive needs not be indicated, but the food additives in compound ingredients shall be indicted if they served technological functions in the final product. Recommended labeling method: add parentheses after the name of the compound ingredient, with the generic name of the food additive in parentheses, eg “Soy sauce (with caramel color)”.
Ø If the compound ingredients added directly to food have no national standards, industrial standards or local standards, or this compound ingredient has the national standard, industrial standard or local standard with the added amount constituting less than 25% of the food, the name of the compound ingredients shall be indicated on the list of ingredients followed by parentheses, and the original ingredients of the compound ingredients shall be indicated in the descending order of the addition amount, and ingredients with addition amount less than 2% the shall not be arranged in descending order.
3) Net content
Quantitative prepackaged food shall be indicated with net content, the labeling of net content shall be composed by net content, figures and legal units of measurement. Such as “Net content: 450 g”, or “Net content: 450 g”;
The net content of food in the packaging (container) shall be indicated according to legal units of measurement of the “Administrative measures for the supervision of the quantitative prepackaged commodities” as follows:
Ø Liquid food, by volume L (1) (liters), mL (ml) (milliliter);
Ø Solid food, by mass-g (g), kg (kg);
Ø Semi-solid or sticky food, by mass or volume.
The net content shall be in the same display panel as the food name in the packaging or container.
In the case of a solid food packed in a liquid medium, and the solid matter is the major ingredient of the food (such as canned pear in syrup), in addition to indicating net content, the drained (solid) content shall also be indicated in mass or mass fraction.
4) Product standard
Prepackaged food (excluding imported prepackaged foods) that are produced domestically and sold domestically shall be indicted with the standard code and serial number of the product.
5) Production date& shelf life
Ø Date labeling shall be clear without paste-over, supplement, or amendment.
Ø Where production dates and shelf life of many single prepackaged foods in the same prepackage are indicated, the shelf life indicated in the outer package means the shelf life of the single prepackaged food which shall expire first of all. The production date indicated in the outer package means the production date of the single food produced at the earliest or the date on which the outer package becomes a marketable product; the production date and the shelf life of each single prepackaged food may be declared in the outer packaging as well.
Ø The date coding shall be indicated in the sequence of the year, month and day. If not indicated in this sequence, the sequence of date coding shall be indicated clearly.
6) Storage conditions
7) Enterprise information
Name, address and contact information of food producer of prepackaged food shall be indicated. The place of origin of food shall be indicated, and the place of origin shall be expressed in prefecture-level region according to the administrative division. Name and address of producer who is capable of taking the responsibility for safety and quality of products shall be legally registered.
For imported prepackaged food, the name of the country or region (such as Hong Kong, Macao and Taiwan) of origin, and the name and address of the agent, importer or distributor registered by law in the People's Republic of China, shall be indicated.
8) Nutritional table
Technical requirements of nutritional information:
Labeling forms
Table title “Nutritional information” + “Box table”
Labeling contents
Items, per 100 g (ml), NRV%, at least 1 + 4 items (energy / calories, protein, fat, carbohydrates, sodium)
Nutrition claims
Content claims
A claim that describes the level of energy or nutritional t content in a food product, such as “Contains”, “High”, “Low’, or “none”. The nutritional contents listed in Table C.1 in Annex C of GB28050-2011 can be claimed, and the corresponding requirements shall be met.
Comparative claims
A claim after comparing with the energy value or nutritional content of the same type of food well known to consumers, such as “Increasing”, “Decreasing” and so on. The condition of comparative claim is a difference of> 25% in energy value or nutritional content with reference food
Functional claims of nutritional content
Claims that a nutritional component can maintain the normal growth, development and normal physiological functions of the human body, the same product can simultaneously have functional claims on two or more ingredients complying with the requirements. One or more of the corresponding standard terms of functional claims can be chosen according to the nutritional characteristics of food only when the energy or nutritional content complying with the requirements and conditions of Annex C nutritional claims in GB28050-2011.
9) Number of food production license
The food produced domestically shall be indicated with the number of food production license.
10) Labeling requirements of other standards, laws and regulations
Ø Irradiated food: the label of a food which has been treated with ionizing radiation or ionizing energy shall be indicated with “irradiated food” in close proximity to the name of the food. Any ingredient which has been treated with ionizing radiation or ionizing energy shall be indicated in the list of ingredients.
Ø Genetically modified food or food containing statutory genetically modified as raw materials: the biological labeling of genetically modified such as “Genetically modified XX food” or “Food with genetically modified XX food as raw materials” shall be indicated.

5. Classic labeling cases for learning 

5.1 Cases concerning imported products
Case1: imported food products contain ingredients which may not be added by laws, regulations or standards in China, but it has the conformity certificate document issued ingredients contain fish liver oil.
Handling principles: the product violates the current laws and regulations in China. The conformity certificate document issued by CIQ are contrary to the laws, regulations and standards and cannot be used as the basis for the determination of the product's legal rights.
Case2: The content of imported food label is suspected of violating the current laws, regulations or food safety standards in China, but it has the conformity certificate document issued by the CIQ. For example, the nutrition information of products does not meet the national standards.
Handling principles: In the case of imported food labels, if the legality of the product label cannot be identified after investigation and evidence collection according to the relevant laws and regulations, the CIQ shall be required to conduct inspection and quarantine on the imported food. If the food production and trade enterprise can provide the import inspection and quarantine report of conformity, it can be concluded that the label of the involved product label is legal.

5.2 Cases concerning new food raw materials
Case: Adding one or more new food raw materials which are not included in the “Chinese Pharmacopoeia”, medicinal and edible list, and do not belong to new food raw materials approved by the state in food, such as American ginseng, senecio cineraria, peach blossom and crabshell hydrolysate.
Handling principles: according to the “Review measures of safety for new food raw materials”, the key to the determination is whether the food has a history of more than 30 years in food production and trade in Sichuan. If so, it can be identified as compliance.

5.3 Cases concerning the nutritional contents
The handling principles of declared value of food nutritional content table not complying with the provisions of “General Rules for Nutrition Labeling of Prepackaged Foods” (GB28050-2011):
Ø The determination of the accuracy of declared value of nutritional label shall be based on the method of determining the label value of the enterprises;
Ø Because the food nutritional content is unstable, it will change according to the season, origin and transportation conditions. Therefore, it is acknowledged that there may be some discrepancies between the detected values of nutritional contents. It is suggested that the involved product batches and other batches (a total of more than three batches) shall be conducted with entrustment inspection under permitted conditions to comprehensively determine whether the products in question are in conformity with the provisions;
Where there are large differences between detected figures and label declared value, the enterprise shall promptly analyze and correct deviation.

6. Our service 

Service
Content
Consultation of product compliance
Ø Confirmation of standard
Ø Consultation of ingredient compliance
Ø Consultation of the usage of additives, et. 
Service of label compliance
Ø Review on food label compliance
Ø Chinese label design of imported pre-packaged food
Ø Compliance of imported/exported food
Consultation service of other regulations & standards
Ø Self-build the standards & regulations database to
Ø Standards & regulations comparison,
Ø Confirmation on the validity of the standards & regulations,
Ø Analysis & interpretation of the provisions of standards & regulations in-depth interpretation services
Ø Tailor-make solutions of standards & regulations 

 Remarks: All of the above documents originally from Foodmate, please indicate our source if reprint. 

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