Page 64 - FoodFocusThailand No.247 November_December 2026

STRENGTHEN THE PACKAGING

Allergens Must Be Checked Against Actual processes, consumption instructions, product origin, and
Formulations traceability details, where required by law.
According to GB 7718-2025, the eight main allergen categories
are gluten-containing cereals, crustaceans, fish, eggs, Food Producer Registration with GACC
peanuts, soybeans, milk and dairy products, and tree nuts. GACC Decree 280 took effect on June 1, 2026, requiring
These allergens must be clearly declared on food labels, with the overseas food manufacturers exporting their products
relevant information emphasized using bold or underlined text. to China to register with GACC. Exporters should verify
Although sesame and coconut are not included in the the categories under which their products fall, identify the
eight-category list, food businesses may choose to provide applicable registration channels, and ensure that information
additional information about other allergens where appropriate. in the GACC system is consistent with factory records and
This can help consumers make informed purchasing decisions export documentation.
and support food safety. Exporters managing multiple SKUs or factories should
The label preparation process should begin with the verify product names, product types, HS codes, and
verification of manufacturing formulations, raw materials, product categories to ensure consistency across all relevant
and the components of all raw materials. In addition, the risk records. The registration status of each factory and warehouse
of cross-contamination on production lines should be assessed, should be monitored regularly, particularly when changes
particularly when equipment and production lines are shared occur in manufacturing facilities, formulations, ingredients,
among products containing different allergens. or packaging. Before shipping products, exporters should
Allergen verification should extend beyond label preparation confirm the applicable information requirements with Chinese
to include manufacturing formulations, raw material certificates, importers or customs brokers to minimize potential import
supplier documentation, and production processes. Cross- issues.
checking these sources helps ensure the accuracy of Chinese
label information and supports effective traceability. How Should Thai Exporters Adapt?
Thai exporters should establish a China compliance file for
Caution on Marketing Claims each factory and product, focusing on the following four key
Exporters should also review and revise marketing claims, areas:
particularly those involving “No Added Sugar,” “No Added,” 1. GACC registration and factory status: Verify the
“Zero,” and “Does Not Use.” Claims regarding formulations, accuracy of GACC/CIFER registration numbers, product types
ingredients, and the quantities of relevant compounds must also (HS codes and product categories), and factory or warehouse
comply with the new Chinese regulations. registration status.
Furthermore, SAMR Order No. 100 addresses false, 2. Formulation and ingredient information: Review
misleading, or exaggerated label claims, including claims that product formulations and ingredients, assess risks associated
overstate a product’s medicinal or preventive properties or with the eight main allergen categories, and evaluate the
misrepresent its purpose or intended use without a legal basis. potential for cross-contamination on production lines.
3. Artwork and nutritional label design: Verify saturated
Changes in Nutrition Labeling in 2027 fat and sugar data and incorporate the required nutritional
Effective March 16, 2027, GB 28050-2025 will replace information, including %NRV calculations, into the revised
GB 28050-2011, introducing new nutrition labeling requirements. nutritional tables. Ensure that all relevant dates, including
Key changes include the addition of saturated fat and sugars expiry dates, follow the required year-month-day format.
to the required nutritional declarations, along with the calculation Marketing claims should also be reviewed, and Chinese labels
and declaration of %NRV (percentage of nutrient reference redesigned as necessary.
value). The new measures will also introduce warnings about 4. Data reconciliation and system-wide alignment:
excessive consumption of salt, oil, and sugar among children Before export, verify and harmonize key data across all
and adolescents. relevant formats and platforms, including Chinese labels,
These changes will affect not only the format of nutrition product formulations, export documentation, and Chinese
information tables but also product formulations, nutritional customs systems.
information, and packaging space. Exporters should begin The regulatory changes in 2026–2027 encompass the
compiling and verifying data on saturated fat and sugars registration of overseas food manufacturers and food
to ensure that nutritional information can be updated and labeling requirements. Under GACC Decree 280, the new
packaging redesigned promptly. registration requirements took effect on June 1, 2026, making
it essential for exporters to verify their registration status
Digital Labels: QR Codes Are Allowed, and ensure data consistency across all relevant platforms,
but They Are Not a Shortcut including export documentation. On March 16, 2027,
GB 7718-2025 permits the use of digital labels, such as QR GB 7718-2025, GB 28050-2025, and the relevant SAMR
codes, to facilitate access to food information. However, digital regulations are scheduled to take effect, introducing changes
labels should not be considered a complete replacement for to food labeling, nutritional information, allergen declarations,
physical packaging labels, which remain a fundamental legal date display, font size, and marketing claims. Therefore,
requirement. Essential information must still appear on physical food businesses should prepare for China compliance to
labels and be consistent with the information provided through minimize the risk of subsequent label or documentation
digital labels. revisions.
Digital labels serve as a supplementary tool for enhancing
transparency, allowing manufacturers to provide additional
food information, such as raw material origins, manufacturing
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