In early August 2024, the National Health Commission’s Standardization Working Group on Food Nutrition and Health Management released the Guideline for Graphical Representation of Nutritional Information on Pre-packaged Food (Draft for Public Comment) (hereinafter referred to as the “Draft for Public Comment”). The deadline for submitting comments is October 4, 2024. The draft outlines in detail the relevant terms and definitions, basic principles to be followed, specific classifications, and corresponding requirements for front-of-pack nutrition labelling (hereinafter referred to as “FOPNL”) on pre-packaged food. Below is an analysis and interpretation of the key content of the draft.
1. Relevant Terms and Definitions
The draft primarily defines the terms related to the front-of-pack, front-of-pack nutrition labelling, and graphical representation:
1) Front-of-Pack (FOP): Refers to the area on the label of pre-packaged food that simultaneously displays the product name and net content.2) Front-of-Pack Nutrition Labelling (FOPNL): A supplementary form of nutritional information that simplifies the nutritional content on the front of pre-packaged food packaging. It may include symbols/graphics, text, or a combination of both, providing information about the overall nutritional value and/or specific nutrients of interest.3) Graphic Symbol of FOPNL: The form in which FOPNL is presented, consisting of symbols/graphics, text, or a combination thereof, used on pre-packaged food to facilitate consumer recognition and understanding.
2. Basic Principles for Using FOPNL
As a draft guideline for GB/Z (guiding national standards), the standard specifies four forms of FOPNL (warning labels, rating labels, endorsement labels, and informational labels). Additionally, the standard outlines the following points that should be observed when using FOPNL:
1) In principle, only one form of label should be used on a single food label.2) Warning labels are applicable to foods intended for children aged 36 months and above but under 15 years old.3) FOPNL should be displayed on the front of the smallest sales unit’s packaging.4) Each form of FOPNL has specific font size requirements, and the font size or color contrast should not be used to mislead consumers.5) Pre-packaged foods exempted from nutrition labelling under GB 28050 must display a nutrition label if they use FOPNL.2. Four Forms of FOPNL and Their Usage Requirements
1) Warning Labels: Warning Labels are applicable to labels claiming to be for “babies,” “children,” or “students” aged 36 months and above but under 15 years old, or pre-packaged foods reflecting these groups in marketing, excluding cheese and processed cheese.
For solid and liquid foods, warning thresholds for fat, sugar, and sodium content are set. When the content of any of these exceeds its warning threshold, the corresponding warning label (black hexagon) should be used. If two or more of these contents exceed the warning threshold, they should all be labelled. Additionally, the label icon should not be smaller than 50% of the font size used for the product name on the front of the packaging. Foods bearing this label should not be marketed to children.
2) Rating Labels: Rating labels are applicable to pre-packaged foods intended for direct consumption, excluding cheese and processed cheese.
Solid and liquid foods are categorized into four levels—A, B, C, D—based on their fat, sugar, and sodium content, with A being the highest (lowest content) and D the lowest (highest content). The level of the food is determined by the lowest grade among the three nutrients. Pasteurized milk, high-temperature sterilized milk, and ultra-high-temperature sterilized milk are rated as A. The font size of the prominent letter in the label icon should not exceed the font size of the product name on the front of the packaging. If a company uses this type of label, all products within the same series must use it uniformly.
3) Endorsement Labels: Endorsement labels are applicable to 10 categories of pre-packaged foods, including grain products, legume products, dairy products, nuts and seeds, meat products, aquatic products, egg products, fruit and vegetable products, beverages, and other foods, covering 27 sub-categories.
For pre-packaged foods using rating labels with an A or B rating, the “Smart Choice” icon can also be displayed. The icon should not be larger than the font size of the product name on the front of the packaging.
4) Informational Labels: Informational labels are applicable to pre-packaged foods intended for direct consumption.
When labelling by portion, the weight or volume of each portion must be indicated. The icon color should be black text on a white background, with red highlighting used for fat, sugar, and sodium content that meets or exceeds the threshold. When “portion” is used as a food measurement unit, it should be converted for assessment. The font size of the text within the label icon should not exceed the font size of the product name on the front of the packaging.
Comment
The release of the Guideline for Graphical Representation of Nutritional Information on Pre-packaged Food (Draft for Public Comment) marks a significant step forward in the standardization and meticulous management of food safety in China. By clearly defining the terms, definitions, and principles for front-of-pack nutrition labelling, the draft not only aims to help consumers better understand the nutritional content of food but also imposes stricter labelling requirements on food manufacturers. The official implementation of this standard will effectively enhance public health awareness and promote greater transparency and healthfulness in the food industry. In the future, as feedback from the public is incorporated and the standard is further refined, FOPNL will become a crucial tool for consumers when selecting food, contributing to the achievement of national health goals.
1. Relevant Terms and Definitions
The draft primarily defines the terms related to the front-of-pack, front-of-pack nutrition labelling, and graphical representation:
1) Front-of-Pack (FOP): Refers to the area on the label of pre-packaged food that simultaneously displays the product name and net content.2) Front-of-Pack Nutrition Labelling (FOPNL): A supplementary form of nutritional information that simplifies the nutritional content on the front of pre-packaged food packaging. It may include symbols/graphics, text, or a combination of both, providing information about the overall nutritional value and/or specific nutrients of interest.3) Graphic Symbol of FOPNL: The form in which FOPNL is presented, consisting of symbols/graphics, text, or a combination thereof, used on pre-packaged food to facilitate consumer recognition and understanding.
2. Basic Principles for Using FOPNL
As a draft guideline for GB/Z (guiding national standards), the standard specifies four forms of FOPNL (warning labels, rating labels, endorsement labels, and informational labels). Additionally, the standard outlines the following points that should be observed when using FOPNL:
1) In principle, only one form of label should be used on a single food label.2) Warning labels are applicable to foods intended for children aged 36 months and above but under 15 years old.3) FOPNL should be displayed on the front of the smallest sales unit’s packaging.4) Each form of FOPNL has specific font size requirements, and the font size or color contrast should not be used to mislead consumers.5) Pre-packaged foods exempted from nutrition labelling under GB 28050 must display a nutrition label if they use FOPNL.2. Four Forms of FOPNL and Their Usage Requirements
1) Warning Labels: Warning Labels are applicable to labels claiming to be for “babies,” “children,” or “students” aged 36 months and above but under 15 years old, or pre-packaged foods reflecting these groups in marketing, excluding cheese and processed cheese.
For solid and liquid foods, warning thresholds for fat, sugar, and sodium content are set. When the content of any of these exceeds its warning threshold, the corresponding warning label (black hexagon) should be used. If two or more of these contents exceed the warning threshold, they should all be labelled. Additionally, the label icon should not be smaller than 50% of the font size used for the product name on the front of the packaging. Foods bearing this label should not be marketed to children.
2) Rating Labels: Rating labels are applicable to pre-packaged foods intended for direct consumption, excluding cheese and processed cheese.
Solid and liquid foods are categorized into four levels—A, B, C, D—based on their fat, sugar, and sodium content, with A being the highest (lowest content) and D the lowest (highest content). The level of the food is determined by the lowest grade among the three nutrients. Pasteurized milk, high-temperature sterilized milk, and ultra-high-temperature sterilized milk are rated as A. The font size of the prominent letter in the label icon should not exceed the font size of the product name on the front of the packaging. If a company uses this type of label, all products within the same series must use it uniformly.
3) Endorsement Labels: Endorsement labels are applicable to 10 categories of pre-packaged foods, including grain products, legume products, dairy products, nuts and seeds, meat products, aquatic products, egg products, fruit and vegetable products, beverages, and other foods, covering 27 sub-categories.
For pre-packaged foods using rating labels with an A or B rating, the “Smart Choice” icon can also be displayed. The icon should not be larger than the font size of the product name on the front of the packaging.
4) Informational Labels: Informational labels are applicable to pre-packaged foods intended for direct consumption.
When labelling by portion, the weight or volume of each portion must be indicated. The icon color should be black text on a white background, with red highlighting used for fat, sugar, and sodium content that meets or exceeds the threshold. When “portion” is used as a food measurement unit, it should be converted for assessment. The font size of the text within the label icon should not exceed the font size of the product name on the front of the packaging.
Comment
The release of the Guideline for Graphical Representation of Nutritional Information on Pre-packaged Food (Draft for Public Comment) marks a significant step forward in the standardization and meticulous management of food safety in China. By clearly defining the terms, definitions, and principles for front-of-pack nutrition labelling, the draft not only aims to help consumers better understand the nutritional content of food but also imposes stricter labelling requirements on food manufacturers. The official implementation of this standard will effectively enhance public health awareness and promote greater transparency and healthfulness in the food industry. In the future, as feedback from the public is incorporated and the standard is further refined, FOPNL will become a crucial tool for consumers when selecting food, contributing to the achievement of national health goals.