Changes of Health Food Labels with Warning Statements in China

On 20 August 2019, the State Administration for Market Regulation (SAMR) issued “ Guideline on Warning Statements for Health Food Labeling” (hereinafter referred to as “Guideline”), which will come into force on 1st January 2020. According to the Guideline, warning statements and complaint hotline etc. information shall be marked on the Chinese labels of health foods. By implementing the Guideline, the SAMR hopes to make consumers more easily to distinguish health foods from normal foods and drugs.

Changes of mandatory information of health food labeling before and after the implementation of the Guideline

Before the implementation of the Guideline

After the implementation of the Guideline

Key points of the changes

Items	Key points of the changes (after the implementation of the Guideline)
Warning area and warning statements	Location: shall be located on the principle panel of the smallest sales package (or container); Size of warning area: shall be ≥20% of the surface area of the principle panel; Warning statements shall be labelled: Health foods are not drugs, cannot replace drugs to treat diseases; The font of warning statements shall be bold type.
Production date and shelf life	Shall be marked in the order of year, month, and day; The shelf life shall be labelled as “expiry on XXXX (year) XX (month) XX (day)”.
Complaint hotline	Complaint hotline and hotline service time shall be marked; The font of complaint hotline shall be consistent with the font of health function.

CIRS Comments

Health food label is not only an important part of product publicity but the focus of market supervision. SAMR will guide the market supervision department in all the provinces and cities to learn the Guideline. And the market supervision department will guide health food enterprises to adjust product labels, strengthen the supervision of health food, and strictly crack down on false propaganda.

In addition, SAMR confirmed that the Guideline will be implemented from 1st January 2020, and without mentioning of transitional period. How should companies deal with labels of products being sold? According to CIRS’s experience, the products produced before 1st January 2020 would be allowed to be sold until the expiration of their shelf life. However, the products produced after 1st January 2020 shall comply with the Guideline. Let’s hope that the SAMR will make a further interpretation of the implementation, and CIRS will continue to pay attention to it. For products being planned to be produced, it is suggested that enterprises should adjust labels in accordance with the requirements of the Guideline in advance.

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