2014-03-01 GB7718-2011Question&Answer (revised)

National Health and Family Planning Commission of the People’s Republic of China

2014-02-26

I. Purpose and basis of "General Rules for the Labeling of Prepackaged Foods" revision

The labeling of food is the carrier that transmits the product information to consumers. To manage the labeling of pre-packaged foods well is an efficient means to safeguard consumer's rights and interests and to ensure the sound development of the industry, which is also the demand to realize the scientific management of food safety. According to the stipulations of the "Food Safety Law" and its implementing regulations, the former Ministry of Health organized the revised standards of the labeling of pre-packaged foods. The new "General Rules for the Labeling of Prepackaged Foods"(GB7718-2011) fully takes into consideration of the implementation of "General Rules for the Labeling of Prepackaged Foods"(GB7718-2004), refines the detailed requirements on labeling of foods in "Food Safety Law " and its implementing regulations and strengthens the scientificity and practicality of this Standard.

II. Relation between the "General Rules for the Labeling of Prepackaged Foods"(GB7718-2011) and relevant departments’ rules and normative files
"General Rules for the Labeling of Prepackaged Foods"(GB7718-2011) is the national standard for food safety, for different contents in relevant regulations and normative files, it should follow this Standard.
This Standard stipulates the general requirements on the labeling of prepackaged food. If other national standards on food safety have some specific rules, the general requirements and the specific rules should be implemented at the same time.

III. Major process of the standard revision
According to the "Food Safety Law" and its implementing regulations, and to meet the demand of food security supervision, the former Ministry of Health entrusts the Chinese Center for Disease Control and Prevention and China National Food Industry Association, etc. for the task of revising the standards by setting up the standards drafting group. The standards drafting group has organized professional research and hold seminar and expert consulting conference for many times, fully listening to the opinions from relevant departments, industry association and enterprises. And it also asked for public comments on this Standard via the websites of the former Ministry of Health and the reformed National Health and Family Planning Commission, having received over 700 messages of feedback and revising proposal. The standards drafting group analyzed the feedback one by one and timely held the special sessions to study them in order to make a further improvement on the standard text. This Standard was examined and approved at the fifth ministerial meeting of the Evaluation Committee of National Food Safety Standard. Promulgated on April 20, 2011, it officially came into force on April 20, 2012.

IV. Main content of the improvements on revised standards
(A) Application scope of the revised standard. This Standard applies to two kinds of prepackaged food: one is the prepackaged food offered to customers directly; the other is the prepackaged food offered to customers indirectly. However, it does not apply to the labeling of unpackaged food, food for immediate consumption and food to be stored and transported. 
(B) As the “Food Safety Law” requires, the Standard has modified the definitions of “Prepackaged Food” and “Production Date” and added the definition of “Specification” and the labeling way of “Specification”  .
(C) As the “Food Safety Law” requires, the Standard has added that “It should not label or imply the words of the effect as to prevent and treat diseases, nor should it express or imply the words of the effect of healthcare for non health-care food”.
(D) As the “Food Safety Law” stipulates, this Standard has refined the labeling requirements of food additives and clarified that the food additives should be labeled of the common name in the “Standards for Uses of Food Additives” (GB2760).
(E) According to the standards of Codex Alimentarius, this Standard has added the labeling requirement on carcinogen in food, so that customers can choose different food scientifically based on their own conditions.

V. On the definition of packaged food
Based on the “Food Safety Law” and the “Measures for the Metrological Supervision and Administration of Packaged Food”, this Standard refers to the previous experience to definite the “Prepackaged Food” as: the food that packaged or made in packaged materials and containers in advance. It refers the foods that are packaged or made in packaged materials and containers in advance but also have the unified labeling of mass or volume within certain limits. Prepackaged food should be prepackaged first, and then should be labeled with unified mass or volume.

VI. On the difference between labeling of “prepackaged food offered to customers directly” and “prepackaged food offered to customers indirectly”
For prepackaged food offered to customers directly, all details are labeled on the label. For prepackaged food offered to customers indirectly, the labeling must indicates the name, specification, net content, production date, guarantee period and storage conditions, other information may be not on the labeling, but they must be stated in the manual or contract. 

VII. On the conditions of “prepackaged food offered to customers directly”
First, the prepackaged food that offered to customers directly or offered by food managers (include food and beverage service); second, the prepackaged food that offered to customers and also to other food producers. The above stipulations should also be carried out for the imported prepackaged foods from importer.

VIII. On the conditions of “prepackaged food offered to customers indirectly”
First, the prepackaged foods that offered to other food producers by the producer; second, the prepackaged foods that offered to restaurants as raw or auxiliary materials by the producer. The above stipulations should also be carried out for the imported prepackaged foods from importer.

IX. On the labeling conditions this Standard excludes
First, the labeling of unpackaged food; second, the labeling of food to be stored and transported, and this is helpful to offer protection and convenience in transportation; third, labeling of food for immediate consumption. In the conditions above, this Standard may be carried out as reference.

X. Production date in this Standard
“Production date” in this Standard refers to the last date that the prepackaged food comes into sale unit. Terms in the previous “General Rules for Labeling of Prepackaged Food” (GB7718-2004), like “packaged date” and “filling date”, have been unified to be “production date” in this Standard.
XI. Whether the image of actual food can be labeled when the food additives is just the relevant flavor& fragrance but not the food ingredient?
The information on labeling should be real and accurate, and it is forbidden to use the words or images that may be deceptive or lead to misunderstanding to introduce the food. If the images or words in use may lead to misunderstanding, the clear and marked illustration should be added. 

XII. On the traditional Chinese in labeling
This Standard stipulates that the word in food labeling should be the standard Chinese character, but the logo is not limited. The “standard Chinese character” refers to the characters in “Common Standard Chinese Characters Table”, and the traditional Chinese is exclusive. The corresponding traditional Chinese can be used only when the standard Chinese character is used in the food labeling as well.

XIII. On the various WordArt to modify the labeling
The various WordArt to modify the labeling include Seal Script, Clerical Script, Cursive Script, Hand Written Script, Artistic Calligraphy, Aberrant Chinese characters, Ancient Script, and so on. When these words are used, the written form should be correct, legible, and not to be confused easily.

XIV. On the corresponding Chinese and foreign languages in labeling
In the labeling of prepackaged food, foreign languages can also be used. But they cannot be larger than the Chinese characters.
As required in this Standard and other Laws, Regulations and Food Safety Standard, the forced labeling content should contain the corresponding Chinese words and foreign language.

XV. On the surface requirement of labeling: ≥10 cm2&≤35 cm2

The food labeling should label all forced information as this Standard requires. Based on the certain condition of the labeling, the character, symbols, numbers in the labeling may be lower than 1.8mm, but they should be clear and legible.

XVI. If Chinese character and letter character are both in the forced information, how to judge whether the height of word is meet to the standard of 1.8mm?
The Chinese character should be no short than 1.8mm; but for units, like kg、mL, and other forced symbols, the standard of 1.8mm should be used for the capital or “k, f, l” in them.

XVII. When the sale unit contains several packaged food for separate sale, what required for external packing (or large packing) delivered to customers directly
On the separate packaged food in this sale unit, the forced labeling information should be labeled separately. The labeling of large packing (or external packing) can be divided into the following tow:
First, the large packing (or external packing) is labeled as this Standard requires. If this sale unit includes several different kinds of foods, each kind of forced information should be labeled on the external packing, and the information in common can be labeled in unified.
Second, when the external packing (or large packing) is easier to be opened and recognized, or partial or total forced labeling information on the internal packing can be recognized clearly, the repeat information need not to be labeled on the external packing (or large packing). 

XVIII. How to label the production date and guaranteed period when the sale unit contains several packaged food with production date and guaranteed period labeled?
Choose one of the following three to label: first, the production date is labeled as the earliest date and the guaranteed period is labeled as the earliest period; second, the production date is labeled as the date that formed into sale unit and the guaranteed period is labeled as the earliest period; third, each production date and guaranteed period are labeled on the external packing separately.

X IX. On the special name indicating the actual property of food 
The special name indicating the actual property of food generally refers to the food name or food classification name stipulated in national standard, industrial standard and local standard. If there are several names for the same food, random one or the name that is not ambiguous can be chosen; if without standard, the common name or popular name should be chosen in order to help customers to understand the actual property of the food. The special name is used to indicate the innate property and features of the product, and is used to differ itself from others clearly.

XX. How to avoid the misunderstanding of product name
When the name of product in use contains words or terms that easily cause misunderstanding of the actual property, the special name of the food indicating the actual property should be labeled in the same size near the labeling. When the misunderstanding is caused by the size and color of characters, the special name of the food indicating the actual property should be labeled in the same size and color.

XXI. On whether to label the single ingredient in the list
The single ingredient should be labeled in the list of ingredients of the prepackaged food.

XXII. On how to separate the different ingredients
The ingredient labeled in the list of ingredients should be clear, recognizable and readable. Comma, semicolon and blank can be used to separate ingredients because they are easily to be recognized.

XXIII. On the definition and labeling requirements of edible packaging
The edible packaging means the packaging that is made from foods, so it can be eatable and also be used to package others. Because the packaging would be eaten with the packaged food, the list of ingredients should include the ingredients of the packaging. For the edible packaging that is in the national and industrial standards, the raw ingredients of packaging can be omitted when the addictive is less than 25% of the total mass of the prepackaged food.

XXIV. On how to label collagen casing
The collagen casing is part of compound ingredients, and the national and industrial standards for it have been issued. As “General Rules for Labeling of Prepackaged Food” (GB7718-2011) 4.1.3.1.3 stipulates, the list of ingredients of meat product can be labeled without the raw ingredient of collagen casing when it is less than the 25% of the total mass.

XXV. Which unit of measurement should be chosen when confirm the order of ingredients in the list 
According to the mass and weight of each ingredient, they are labeled one by one with the descending order. While, the ingredients whose percentage of mass (m/m) is not up to 2% will not follow the descending order.

XXVI. On how to label compound ingredients in the list
There are two ways to label the compound ingredients:
(A) If there are national and industrial standards for the compound ingredients in the food and the ingredients is less than 25% of the total mass, the raw ingredient of it is not needed in the labeling. In the compound ingredients that are less than 25% of the total mass, the food additives is not labeled since it meets to the principle of “Standards for Uses of Food Additives” (GB2760) and works not for the final food technology. But the food additives should be labeled if it works for the final food technology. The labeling way to be recommended is: add a bracket following the compound ingredients and label the common name of the food additives in this bracket, like “soybean sauce (including caramel)”.  
(B) If there are no national, industrial or local standards for the compound ingredients in the food, or the compound ingredients meeting to the national, industrial or local standards are more than 25% of the total mass, they should be labeled in the list. In addition, in the following bracket, the raw ingredient should be labeled one by one with the descending order. While, the ingredients that are not up to 2% will not follow the descending order.

XXVII. How to label some ingredients of the compound ingredients when they are the same with the ingredients in the food?
One of the following two labeling ways can be chosen: first, refer to the “Twenty-eighth Q&A (second)” to label; second, label each raw ingredient of the compound ingredients in the list and the order is due to the specific amount in the total mass of final product.

XXVIII. On how to label the common name of food additives
The common name in “Standards for Uses of Food Additives” (GB2760) should be labeled. On the labeling of one prepackaged food, all food additives can be labeled as one of the following three ways: first, all additives are labeled as their correct names; second, all additives are labeled as their functional classification and international number (INS num.). If there is no INS num. for one food additives or it includes the allergen, the specific name can be labeled; third, both the functional classification and specific name are labeled for all food additives.
For example, the food additives—“propylene glycol” can be labeled as: 1, propylene glycol; 2, thickener (1520); 3, thickener (propylene glycol).

XXIX. On the notices for labeling the common name of food additives
(A) The food additives may have one or several functions, the “Standards for Uses of Food Additives” (GB2760) list the main functions of food additives for reference. The production enterprises should label the actual functional classification of the food additives in the product. 
(B) If the “Standards for Uses of Food Additives” (GB2760) stipulate more than two names of one food additives, each one is equal as common name. Take “sodium cyclamate (also called sweetener)” as an example, “sodium cyclamate” and “sweetener” are both common name.
(C) The “glycerin fatty acid ester with single or double bonds” (oleic acid, linoleic acid(LA), linoleic acid(LNA), palmitic acid, behenic acid, stearic acid and lauric acid) can be labeled as “glycerin fatty acid ester with single or double bonds”, “stearic acid glyceride with single or double bonds” or “glycerin monostearate”.
(D) According to the labeling requirement of allergens, the source indication can be added before the common name stipulated in the “Standards for Uses of Food Additives” (GB2760). Such as, “phospholipids” can be labeled as “soybean lecithin”.
(E) The “Standards for Uses of Food Additives” (GB2760) stipulates that aspartame should be labeled as “aspartame (including phenylalanine)”.

XXX. On creating the item of “food additives” in the ingredients list 
The ingredients list should include all the actual food additives, but creating the item of “food additives” is not compulsive. Enterprises on food production should select random labeling in the Appendix B.

XXXI. Can they be labeled together when the two or more additives have same function?
When two or more additives in the food have same function, they can be labeled separately with the specific name; also can be labeled like functional classification first and the specific name or international number (INS num.) is labeled in the following bracket. Example: it can be labeled as “carrageenan, guar gum”, “thickener (carrageenan, guar gum)”, or “thickener (407, 412)”. If there is no INS num. for one additive, the specific name can be labeled as well. Example: “thickener (carrageenan, sodium polyacrylate)” or “thickener (407, sodium polyacrylate)”.

XXXII. On the labeling of compound food additives
Every food additive that works for certain function in the final product should be labeled in the ingredient list one by one. 

XXXIII. On the labeling of the auxiliary materials in food additives
The auxiliary materials in food additives is not need to labeled when it’s not for the certain function in the final product.

XXXIV. On the labeling of processing aids
It needs not to label the processing aids.

XXXV. On the labeling of enzyme preparations
If the enzyme preparation has lost its activity in the final product, it’s not labeled; if it is still active in the final product, it should be labeled in the certain position of ingredients list based on the relevant stipulation and the certain amount in the production or processing of foods.  

XXXVI. On the labeling of food nutritional fortification substances in foods
The food nutritional fortification substances in foods should be labeled as the name in “Standard for the Use of Nutritional fortification Substances in Foods” (GB14880) or the announcement of previous Ministry of Health.

XXXVII. On the labeling of ingredients used as both food additives or nutritional fortification substances and other auxiliary material
When an ingredient can be used both as food additive or nutritional fortification substance and other auxiliary material, it should be labeled as its function in the final production. When used as food additive, it should be labeled as the name stipulated in “Standards for Uses of Food Additives” (GB2760); when used as nutritional fortification substances in foods, it should be labeled as the name stipulated in “Standard for the Use of Nutritional fortification Substances in Foods” (GB14880); when working as other auxiliary material, it should be labeled as it specific name. Such as, monosodium glutamate (sodium glutamate) is both seasoning and food additive. When used as food additive, it should be labeled as sodium glutamate; when used as seasoning, it should be labeled as monosodium glutamate. Others can be used as both food additives and nutritional fortification substance in foods, like riboflavin, Vitamin E, polydextrose, and so on. When used as food additives, they should be labeled as the names stipulated in “Standards for Uses of Food Additives” (GB2760); when used as nutritional fortification substances in foods, they should be labeled as the names stipulated in “Standard for the Use of Nutritional fortification Substances in Foods” (GB14880);

XXXVIII. On the labeling of the strains in foods
The “Announcement about ‘List of Strains Used in Foods’ issued by General Office of Ministry of Health” (supervised and issued by General Office of Ministry of Health (2010) No.65) and No. 25 Announcement issued by previous Ministry of Health in 2011 stipulate the list of strains used in foods and foods for younger babies separately. If the strains stipulated above are used in the prepackaged food, they should be labeled as the name stipulated in “General Rules for Labeling of Prepackaged Food” (GB7718-2011), and the number and amount of the strain may be labeled on the prepackaged foods as well. Since January 1, 2014, enterprises on food production should label the relevant strains on the prepackaged food. The current labeling of prepackaged foods sold before January 1, 2014 can be still used until the end of guaranteed period.

XXXIX. On the situation of labeling ingredients and elements with fixed quantity
First, if the labeling or instruction emphasizes certain ingredients or elements that are valuable and featured in the food, the additive amount or percentage should be labeled at the same time; second, if the additive amount of the emphasized certain ingredients are lower or even zero, the amount in final product should be labeled as well.  

XL. On the situation of labeling ingredients and elements without fixed quantity
When the ingredients and elements are just mentioned to indicate the actual property of the food, but not to be emphasized, their additive amount or percentage in the final product needn’t to be labeled. Also, the fixed quantity labeling is not needed when they are emphasized for the flavor of food.

XLI. On the labeling of sulfur dioxide in wine
According to the stipulations of “General Rules for Labeling of Prepackaged Food” (GB7718-2011) and “Fermented Alcoholic Drink and Its Integrated Alcoholic Beverages” (GB2758-2012), the wine including food additive--sulfur dioxide is allowed to indicate sulfur dioxide or micro-sulfur dioxide in its labeling before August 1, 2013; but if it is produced or imported after August 1, 2013, it should be labeled with sulfur dioxide or micro-sulfur dioxide as well as the specific amount.

XLII. On the labeling of vegetable oil in the ingredients list
One of the following two ways can be chosen to label the vegetable oil as food ingredient:
(A) Label the specific source of the vegetable oil, such as: palm oil, soybean oil, refined soybean oil, sunflower seed oil, and so on. And the names stipulated in the corresponding national, industrial or local standards are OK. If there are two or more sources for the vegetable oil in use, these sources should be labeled in descending order.
(B) Label it as “vegetable oil” or “refined vegetable oil”, and arrange its position in the list of ingredients based on the total amount.

XLIII. On the labeling of edible flavor& fragrance
In the ingredients list of the foods with edible flavor or fragrance, the flavor &fragrance can be labeled as the common names, “edible flavor”, “edible fragrance”, or “edible flavor &fragrance”.

XLIV. On the labeling of spice, the spice class or compound spices as food ingredients  
(A) If the addition percentage of one spice or spice extract is over 2%, their specific names should be labeled.
(B) If the addition percentage of one spice or spice extract (single or total) is not over 2%, the specific names can be labeled in the list of ingredients. Also, they can be labeled as “spice”, “the spice class” or “compound spices” in the list of ingredients.
(C) When the addition percentage of compound spices is over 2%, the labeling way is the same as the way of compound ingredients.

XLV. On the labeling of dried fruit and preserved fruit in the ingredients list
(A) If the total addition amount of various dried fruit and preserved fruit is not over 10%, each specific name can be labeled in the list of ingredients. Or, they can be labeled as unified “preserved fruit” or “dried fruit”.
(B) If the total addition amount of various dried fruit and preserved fruit is over 10%, the specific name of each dried fruit and preserved fruit should be labeled.

XLVI. On the labeling of net mass
The labeling of net mass consists of three parts: net mass, number, and the legal unit of measurement. The net mass should be labeled at the same side of the packaging where food name is labeled. The height of all letters (as L, k, g) should meet the requirements in 4.1.5.4 of this Standard. Between “net mass” and the following numbers, blank or colon can be labeled to separate them. The “legal unit of measurement” includes unit of volume and mass. Unit of mass is the only choice for solid foods. Unit of volume or unit of mass can be chosen for foods that in the state of liquid, semisolid and viscous.

XLVII. The labeling of net mass for prepackaged foods as gift or promotion
The net mass for prepackaged foods in gift or promotion should be labeled as this Standard stipulates. Net mass for sale and net mass for gift can be labeled separately, and the total net mass of both parts is labeled and the net mass for gift is labeled in proper way. Such as, “net mass 500g, 50g for gift”, “net mass 500+50g” or “net mass 550g (including 50g for gift)”.

XLVIII. On the quantity labeling of solid content in unclear solid-liquid phase
The major prepackaged foods are foods in solid content and solid-liquid phases. The quantity of drained matters (solid contents) should be labeled as the form of mass or mass percentage near the position of “net mass”.
The main edible ingredients of foods in semi-solid, viscous, and solid-liquid phase are unclear to distinguish because of the suspension or mixture. So, there is no quantity of drained matter (solid content) labeled for the prepackaged foods in solid-liquid phase. As the native features, the prepackaged foods may be in different state (solid or liquid) with different temperatures or conditions, which belongs not to solid-liquid phase foods. Such as: honey, edible oil and other products.

XLIX. On the labeling of specification
Since the specification of single prepackaged food is just its net mass, the specification is not need to label specially and Appendix C.2.1 is the reference for detailed labeling; when several prepackaged foods in same kind are included, Appendix C.2.3 is the reference for the detailed labeling of net mass and specification; when several prepackaged foods in different kinds are included, Appendix C.2.4 is the reference for the detailed labeling of net mass and specification.
To label “specification”, the actual word “specification” is not in compulsive requirement.

L. On the place of origin in the Standard
The “place of origin” refers to the actual place to produce the foods and it’s to supplement the place of producer in certain conditions. If the place of producer is the actual origin of the product, or the producer is in the same city as legal representative, the “specification” is not in compulsive requirement. The “specification” should be labeled in the following situations: first, for the product that is produced by branch or production base of a group company and labeled with only the name and address of the group company who assumes the legal liability, the labeling of it should include the “specification” to indicate the area of the branch or production base as well; second, for the product that is entrusted to other enterprises and only labeled the name and address of consignable company, the labeling of it should include the “specification” to indicate the area of the entrusted enterprises as well.

LI. How to label the names and places of producer and marketer when the subsidiary corporation signed the delegation to process the product but not for sale?
Label them according to the processing way entrusted by enterprise on foods production and marketing.

LII. On the prefecture-level city in the Standard

According to the administrative division, the place of origin can be labeled as sub-provincial city or prefecture-level city, like direct-controlled municipality, municipality with independent planning status, and others. The definition of prefecture-level city is under the relevant stipulations of the State. 

LIII. On the labeling of contact information
The contact information of producer and marketer who assume the legal liability in force should be labeled as the contact information. And the contact information should include more than one of the followings: the network contacts, like telephone number (number of hotline, customer service, or sales, etc.), fax number, e-mail address, and the postal address labeled with the location (Zip code or Box No.). 

LIV. On the labeling of quality level 
If there are explicit quality levels stipulated in national and industrial standards, the quality levels should be labeled as the Standard requires. While, quality levels don’t include the classifications and categories of products.

LV. On the situations exempted from labeling 
Situations exempted from labeling in this Standard are two: first, the Standard stipulates the types of foods that exempt from the guaranteed period; second, the Standard stipulates the exempt labeling content for foods whose surface is smaller than 10cm2. These two situations consider the native features and the difficulty of labeling vast content in small space. As exempting from labeling means not in compulsive requirements, whether to label is decided by enterprises.
The exemption clauses of this Standard stipulate the “solid sugar” as white granulated sugar, soft white sugar, brown sugar and rock sugar, but not sweets. 

LVI. How to label the imported prepackaged foods
The food labeling for imported prepackaged food may include contents in both Chinese and foreign languages, and the traditional Chinese can be used as well. The contents that are compulsively required in “General Rules for Labeling of Prepackaged Food” (GB7718-2011) should be labeled totally, and the recommended content can be labeled selectively. When Chinese and foreign language are both used in the labeling of prepackaged foods, the foreign language should be corresponding to the Chinese words both for compulsive content and selective content. It means that the foreign language should fit the meaning of Chinese words, and they can not be larger than the Chinese characters. As for the imported prepackaged foods with special shapes, the Chinese characters should not be lower than the foreign letters when they are displayed at the same side.
As for the situation that adds a Chinese labeling on the packaging of imported prepackaged foods, the added Chinese labeling should be labeled as “General Rules for Labeling of Prepackaged Food” (GB7718-2011) requires; the images and symbols of original labeling should include no contents that go against the stipulations of “General Rules for Labeling of Prepackaged Food” (GB7718-2011) and Relevant Laws and Regulations. 
The Chinese ingredients list should indicate all content in the foreign ingredients list of imported prepackaged foods; in addition, it should add the relevant contents required by laws, regulations and standards in China but not in the foreign ingredients list, including the water and single ingredient used in the process of foods production.
The labeling of imported prepackaged foods should include the place of original country or area, as well as the name, address and contact information of the agent, importer or marketer registered in China; the name, but the address and contact information of producer may be not labeled. The original name and address of producer need not to be translated.
The original nation and area of imported prepackaged food refers to the county or area where the final products are produced, including country or area for packaging (filling). The Chinese labeling of imported prepackaged foods should indicate the original country or area accurately.
Relevant standard codes and quality levels can be exempted to label for imported prepackaged foods. If the standard codes and quality levels are included, the authenticity and accuracy should be ensured.

LVII. How to label the production date when the imported food is only labeled with guaranteed period and ‘best before’ date?
Based on the guaranteed period and ‘best before’ date, add the production date actually in the forms of relabeling, reprinting or others.
LVIII. On the labeling of dates without additional relabeling, reprinting or tampering
In the clause 4.1.7.1 of this Standard, “labeling of dates without additional relabeling, reprinting or tampering” refers to the behavior that just tampers the dates by relabeling and reprinting. If the entire food labeling is produced into sticker, which includes the dates like “production date” or “guaranteed period”, it meets the stipulation in this Standard to relabel the entire sticker on the packaging. 

LIX. Whether to point out the specific position of dates when the words--“see the packaging” are used to label the dates?
It should be considered in the following two situations: first, as for the larger packaging, the specific position of dates should be pointed out; second, as for the smaller packaging, “see the production date on packaging”, “see the production date on spray code” or others can be chosen. The requirements mentioned above are to help customers finding the information of dates.

LX. On the labeling of standard codes of products
The standard code and sequence number should be labeled for the product, but the year number may be not labeled. Production standards may be national food safety standards, local food safety standards, food safety standards on enterprises, or other national, industrial and local food safety standards, and food safety standards on enterprises.
The titles can be labeled in these forms: product standard No., product standard code, product standard number, product standard executive number, and so on. But other forms are not limited as well.

LXI. On the signs of green food in labeling
As “General Rules for Labeling of Prepackaged Food” (GB7718-2011) 4.1.10 stipulates, the product standard code in execution should be labeled for prepackaged food (imported prepackaged foods are exclusive). The standard code means the execution standards of prepackaged foods that refer to quality and specification of product. The standards may be national food safety standards, local food safety standards, food safety standards on enterprises, or other national, industrial and local food safety standards. As the “Administrative Measures for Green Food Signs” (No.6 of the Ministry of Agriculture in 2012) stipulates, the signs of green food on packaging of company’s products means that the products are promised to have met the standards of green food. On the packaging of products, the execution standards of green food may be labeled, and other standards executed in the production may be labeled by the company.

LXII. On the labeling of allergen
Some ingredients or elements in foods may induce anaphylaxis on specific people after they are eaten. One of the effective methods to prevent that is to label the allergen contained or may be contained in the foods on the labeling so that customers who hold history of allergy can choose proper foods for themselves. Referring to international Codex Alimentarius, this Standard lists eight types of allergen to encourage companies volunteered to label allergens and remind customers so as to carry out their social responsibilities effectively. As for other allergens, the producers can label them selectively and the detailed labeling methods for selection are following: 
The allergen can be labeled in the ingredients list as legible name, like milk, egg power, soybean lecithin, and others; they may be reminded near the ingredients list, like “contains …”; when foods containing allergens are produced in the same workshop or production line, the allergens may get into other products whose ingredients don’t include allergens, then the other products can be labeled with “may contain …”, “may contain little of …”, “this production device also process foods containing …”, and “this production line also process foods containing …” to indicate the allergen information near the ingredients list.

LXIII. On the calculation on the largest surface area of packaging material or container
The Appendix A indicates the method to calculate the largest surface area packaging material or container. In it, A.1&A.2 stipulate the method of calculation for rectangular and cylindrical packaging separately, which are to calculate the regular shapes. A.3 stipulates the method to calculate irregular shapes (volume). To calculate the largest surface area of packaging material or container should follow the stipulations.

LXIV. On the calculation on the irregular surface area of packaging for prepackaged foods
As for the food whose packaging material or container is in irregular shape, its major side should be plane or nearly plane, and the surface area is the area of this side. If several sides are plane or nearly plane, the largest one among them should be the major side; if they are nearly same, the major side can be chosen independently. The total surface of packaging area can be calculated when it lies flat and without product in, while, the edge and spaces without printing words should be cut off.

LXV. On Appendix B in the Standard
When food producers label the food additives in the ingredients list, one of the labeling methods in Appendix B should be chosen. In Appendix B, the different methods to label food additives in ingredients list have been indicated with detailed specific examples, food producers can choose one of them to label based on the food’s features. But the separating method and punctuationmarks are not in specific requirement.

LXVI. On Appendix C in the Standard
The Appendix C integrates recommended examples for labeling method of some items. When labeling corresponding items, the producers should make the labeling in accordance with the basic meaning of recommended forms, but the expressions and punctuation marks are not limited.
The Appendix C applies lots of examples to indicate the labeling of net mass, specification, date, guaranteed period and storage condition. Choose one form of labeling, but it needn’t to be the same as recommended. Based on the features of food or prepackaging and the premise of not changing the basic meaning, some proper modifications may occur.

LXVII. On the implementation of the Standard
Before the date to implement this Standard, companies on food production and marketing are allowed and encouraged to carry out this Standard. To save resources, the food labeling required in previous “General Rules for Labeling of Prepackaged Food” (GB7718-2004) can be still used. After the date of implementing this Standard, companies on food production must carry out this Standard, but foods labeled as previous Standard can be sold as well during the guaranteed period.

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