Food safety standards and food labeling and testing regulations are core parts of China’s food law and regulation. A lookback at drafts in 2020 illustrates that many important rules and standards on labeling, packaging, and testing are under revision, and while timelines are difficult to predict, there could be notable changes to such regulations and standards in 2021. Below is a collection of key draft food-related regulations and standards in China and the latest status for readers who are looking to monitor for change in this area over the next year.

Draft Regulation Date Issued Comment Period

Administrative Measures on Food Safety Standards (Draft for Comment)

《食品安全标准管理办法》(征求意见稿)

Sept. 16, 2020 Sept. 16 – Oct. 15, 2020

National Food Safety Standard GB 28050 General Rules for Nutrition Labeling of Prepackaged Foods (Draft for Comment)

《食品安全国家标准 GB 28050 预包装食品营养标签通则》(征求意见稿)

Aug. 31, 2020 Aug. 31 – Oct. 20, 2020

Measures for the Supervision and Administration of the Quality and Safety of Food-Related Products (Draft for Comment) [Includes packaging and food contact substances.]

《食品相关产品质量安全监督管理办法》(征求意见稿)

July 30, 2020 July 30 – Aug. 31, 2020

Measures for the Supervision and Administration of Food Labeling (Draft for Comment)

《食品标识监督管理办法》(征求意见稿)

July 27, 2020 July 27 – Aug. 26, 2020

Measures for the Administration of Import and Export Food Safety (Draft for Comment)

《进出口食品安全管理办法》(征求意见稿)

June 12, 2020 June 12 – July 11, 2020

National Food Safety Standard GB 7718 General Rules for the Labeling of Prepackaged Foods (Draft for Comment)

《食品安全国家标准 GB 7718 预包装食品标签通则》(征求意见稿)

Jan. 3, 2020 Jan. 3 – Feb. 28, 2020

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Contributors for the China & APAC Food, Drug, Device, and Cosmetics blog:

John Balzano, Julia Post, Muyun Hu, Annie Wang, and Kaixin Fan

Photo of John Balzano John Balzano

John Balzano represents companies and business associations on U.S. and China regulatory and policy matters related to food, drugs, medical devices, cosmetics, and other regulated products.

John has over a decade of experience with legal and regulatory issues related to China, particularly with…

John Balzano represents companies and business associations on U.S. and China regulatory and policy matters related to food, drugs, medical devices, cosmetics, and other regulated products.

John has over a decade of experience with legal and regulatory issues related to China, particularly with regard to products regulated by the State Administration for Market Regulation, the National Medical Products Administration (NMPA), and other agriculture, animal and healthcare (including digital health) products and services. He assists clients with developing strategies to obtain pre-market approvals for these products in China, including clinical development, understanding relevant pricing and reimbursement policies, and reviewing distribution and promotional plans.

He also advises on regulatory compliance, due diligence, and enforcement matters for China operations, including drafting and revising and integrating China and global standard operating procedures, assessing the functions of regulatory departments in China, responding to inspection results and enforcement inquiries, and implementing product recalls. John also has significant experience designing strategies to handle professional consumer litigation for food and cosmetic companies operating in China and working with local counsel.

He advises companies and industry associations on their advocacy strategies, including the notice and comment process before NMPA and other regulatory agencies.

John has particular experience in the U.S. advising on the requirements for the acquisition and transfer of biospecimens for research purposes.

Photo of Julia Post Julia Post

Julia Post advises companies and trade associations on a broad range of regulatory and policy matters related to drugs, biologics, and other regulated products in both the U.S. and China. Julia has significant experience in advising clients on clinical trial and product development…

Julia Post advises companies and trade associations on a broad range of regulatory and policy matters related to drugs, biologics, and other regulated products in both the U.S. and China. Julia has significant experience in advising clients on clinical trial and product development matters, including informed consent requirements, biospecimen procurement and research use, and other good clinical practice. She advises clients regularly on product life-cycle management issues, including patent linkage frameworks and marketing exclusivity in the U.S. and China.

Julia works with pharmaceutical, medical device, food, and cosmetics clients on complex regulatory compliance matters and helps them develop their advocacy strategies before U.S. and China regulators, at both national and local levels. She regularly assists companies and trade associations on policy issues, including the development and submission of comments on legislative and regulatory proposals. Julia works closely with local counsel throughout the Asia-Pacific region to assist clients with their marketing approval and compliance strategies.

Prior to joining the Food, Drug, and Device practice group, Julia was a member of the Litigation practice group where she focused on representing clients in Hatch-Waxman patent litigation.

Julia has an active pro bono practice at Covington, with a particular focus on reproductive justice matters and representation of third-party caregivers and children in custody cases.