1. Separate publication from commencement
On 7 May 2026, the Beijing Municipal Administration for Market Regulation explained that GB 7718-2025 had been published and would take effect on 16 March 2027. SAMR Order No. 100, the Food Labelling Supervision Measures, carries the same commencement date.
‘A new standard has been issued’ is therefore a trigger to prepare, not proof that every existing artwork became invalid immediately or that every production date must use the future layout without considering the applicable transition rules.
2. An import label is more than a Chinese sticker
The National Health Commission’s GB 7718-2025 Q&A says all content displayed on imported prepackaged-food labels is in scope: foreign languages, traditional Chinese characters, printed or overlaid Chinese labels, and other explanatory material.
Review must cover the whole pack—not only translate the product name while overlooking claims, imagery, ingredients, storage instructions, dates or text on the outer carton.
3. What to bring into artwork review
Beijing’s market regulator highlights preparation topics including a distinct and legible area for production and expiry dates, strong visual contrast, treatment of ‘no added’ claims, and allergen emphasis within the standard’s defined scope.
Those points frame review questions. A product decision still requires the full standard, the actual formula and the confirmed food category—especially where a durian snack may contain milk, nuts, flour or other ingredients.
4. China Label Transition Evidence File: seven layers
This is an editorial evidence-management framework, not a Chinese standard, label approval or Siam Diamond certification.
- Rule Snapshot — document, authority, publication date, effective date, version and primary link
- Product Classification — food name, format, sales channel and accountable classification rationale
- Formula & Claim Map — recipe, ingredients, allergens, claims and substantiation for each statement
- Bilingual Artwork Proof — Chinese and foreign-language master, type size, position, dates, version and reviewer
- Importer & Market Review — importer, destination/channel requirements, questions and recorded revisions
- SKU–Lot Cutover — SKU, production date, lot, film/carton inventory, label version and old/new quarantine rule
- Release & Change Control — approver, evidence, printed sample, Hold/Release status and retrigger conditions
5. No filing does not mean no accountability
GACC Announcement No. 70 of 2019 removed first-import filing for prepackaged-food labels, while placing responsibility on importers to review Chinese labels against Chinese laws, administrative rules and standards.
The control point shifts from waiting for a filing record to keeping a traceable review. If nobody can show who reviewed which authority, artwork and lot, ‘the label passed’ remains an unsupported statement.
6. A practical release gate
Before a volume print run, lock the formula and SKU, review the Chinese and foreign-language master against requirements applicable on the target date, obtain importer confirmation, inspect a physical print proof, and define a cutover linking each film roll or carton version to production lots.
If the effective date, classification, translation, allergens, claims or treatment of remaining stock is unresolved, place the work on Hold and obtain specialist review. Do not invent the answer or treat this article as legal clearance.
