GB 7718 Revised: New Allergen Declaration Rules for Imported Food | 2027 Deadline

China‘s food labeling regulatory landscape has undergone its most significant transformation in over a decade. The revised GB 7718-2025 “National Food Safety Standard – General Standard for the Labeling of Prepackaged Foods”, along with GB 28050-2025 for nutrition labeling and the Food Labeling Supervision and Administration Measures, were released in March 2025 and will take full effect on March 16, 2027. For importers of food products, the most consequential change is the introduction of a dedicated chapter for imported prepackaged foods and the elevation of allergen labeling from a voluntary recommendation to a mandatory requirement. This guide provides a comprehensive breakdown of the new allergen declaration rules, the specific obligations for importers, and a practical roadmap for achieving compliance before the 2027 deadline.

1. Implementation Timeline and Transition Period

GB 7718-2025, titled “General Standard for the Labeling of Prepackaged Foods,” was officially released on March 16, 2025, by the National Health Commission and the State Administration for Market Regulation. The standard has a two-year transition period and will become mandatory on March 16, 2027. During the transition period (2025-2027), food producers may voluntarily comply with the new standard or continue using the 2011 version. However, products manufactured after March 16, 2027, must fully comply with GB 7718-2025, while products manufactured before that date using the old standard may be sold through their shelf life.

2. Eight Major Allergens: From Recommended to Mandatory

The most significant change in GB 7718-2025 is the elevation of allergen labeling from a voluntary recommendation (under the 2011 edition) to a mandatory requirement. For the first time, food producers must explicitly declare the presence of any of the following eight major allergens when they are used as ingredients. This change aligns China‘s allergen labeling framework with international standards established by the Codex Alimentarius Commission and brings it into closer alignment with EU and US regulations.

Under GB 7718-2025, the following eight categories of allergenic substances must be labeled when used as ingredients:

• Cereals containing gluten and their products – wheat, rye, barley, oats, spelt, or their hybrid strains, as well as products derived from them (bread, beer, wheat flour, etc.)
• Crustaceans and their products – shrimp, lobster, crab, crayfish, and products containing them (shrimp paste, crab flavoring, etc.)
• Fish and their products – all fish species and products containing fish (fish sauce, fish meal, surimi, etc.)
• Eggs and egg products – whole eggs, egg whites, egg yolks, and derived products (mayonnaise, egg powder, etc.)
• Peanuts and peanut products – peanut oil, peanut butter, peanut flour, and any ingredient derived from peanuts
• Soybeans and soybean products – soybean oil, tofu, soy protein, soy lecithin, and other soybean-derived ingredients
• Milk and dairy products (including lactose) – milk, cream, butter, cheese, yogurt, whey, lactose, and all milk-derived ingredients
• Tree nuts and nut products – almonds, walnuts, cashews, hazelnuts, pecans, Brazil nuts, pistachios, macadamia nuts, and their derived products

A critical nuance: the term “nuts” in Chinese mandatory labeling refers strictly to tree nuts (almonds, walnuts, cashews, etc.) and does not include seeds such as sesame, sunflower seeds, pumpkin seeds, or rapeseed. Seed-based products are not subject to mandatory declaration.

3. Permitted Labeling Formats for Allergen Declaration

GB 7718-2025 provides flexibility in how allergens are declared on the label, but the declaration must be unmistakable and easy for consumers to notice. The standard specifies two primary labeling methods, as detailed in Appendix D of GB 7718-2025:

• Method 1 – In-ingredient declaration with emphasis: Allergens may be indicated directly within the ingredient list using distinctive formatting. Permitted emphasis methods include bolding the allergenic ingredient name, underlining it, or using a font color that contrasts with the surrounding text. For example, “Ingredients: Water, Whole Milk Powder, Sugar, Milk, Wheat Flour” where the allergenic components are visually emphasized.
• Method 2 – Separate allergen information panel: Allergens may be declared in a dedicated section adjacent to the ingredient list. This panel can be headed with guiding phrases such as “Allergen Information,” “Allergen Declaration,” or “Contains.” No guiding word is strictly required if the intent is clear from the layout. For example, “Contains: Eggs, Milk, Peanuts, Soybeans” placed immediately below or beside the ingredient list is fully compliant.

Importers should note that if either labeling method is used, the allergen declaration must accurately reflect all allergenic ingredients present in the product. Partial declarations (e.g., declaring only some but not all allergenic components) constitute a violation and will result in rejection.

4. Exemptions from Allergen Labeling

GB 7718-2025 recognizes that certain highly refined ingredients no longer contain allergenic proteins and thus may be exempt from allergen labeling. The standard explicitly lists specific ingredients that are exempt based on scientific evidence confirming the removal of allergenic proteins through deep processing or hydrolysis. Exemptions include:

• Soybean and peanut products – refined soybean oil, refined peanut oil, soybean-derived peptides, phospholipids, vitamin E, phytosterols and their esters, xanthan gum
• Cereal products – starch, dextrin, glucose syrup, grain-derived refined vegetable oils
• Seafood products – chitin, chitosan, fish gelatin, refined fish oil, DHA from fish oil
• Dairy products – lactitol

Important note: These exemptions apply only when the exemption criteria are strictly met. If cross‑contamination is possible or if the exemption conditions are not satisfied, allergen labeling remains mandatory. Importers should verify with their ingredient suppliers whether specific batches meet the exemption criteria.

5. Cross‑Contact and Voluntary Labeling Recommendations

Beyond mandatory declaration of intentionally added allergens, GB 7718-2025 encourages food producers to declare allergens that may be present due to cross‑contact during production. This applies when a product is manufactured on shared equipment or in a facility that also processes allergenic ingredients, even if those allergens are not intentionally added to the recipe. Recommended phrasing includes:

• “This product may contain traces of …”
• “May contain …”
• “May contain trace amounts of …”
• “This production equipment also processes food containing …”
• “This production line also processes food containing …”

While such cross‑contact declarations remain voluntary, the standard strongly encourages them as a measure of social responsibility and consumer protection. For importers, offering clear cross‑contact information can reduce liability risk and build consumer trust, particularly in the Chinese market where food allergy awareness is rapidly increasing.

6. Dedicated Chapter for Imported Foods – A Major Shift for Importers

For the first time, GB 7718-2025 sets out an independent chapter (Chapter 8) specifically governing imported prepackaged food labels. This chapter standardizes the basic labeling requirements for imported foods, the “correspondence relationship” between Chinese and foreign languages, and other label content rules. It also strengthens cross-reference consistency between the Chinese label and the original foreign packaging, ensuring that imported products are held to the same standards as domestic products.

Key requirements for importers include:

• Mandatory Chinese label: Imported prepackaged foods must bear a printed or affixed Chinese label. All visible labeling content (including foreign or traditional Chinese characters, Chinese label content, and explanatory materials) must comply with Chinese laws, regulations, and food safety standards.
• One‑to‑one correspondence of mandatory content: For mandatory labeling content (e.g., ingredient list, net content, nutritional information), the Chinese language version must have a one‑to‑one correspondence with the foreign language content. This means that every ingredient, additive, or claim that appears on the original packaging must be accurately translated into Chinese.
• Allergen declaration in Chinese: Allergen information that appears on the original label must be fully translated and prominently displayed on the Chinese label. If the original label does not include allergen information but the product contains allergenic ingredients, the allergen information must be added to the Chinese label.
• Non‑mandatory foreign content treatment: For non‑mandatory foreign content that cannot be fully translated, importers may use a white label to cover it or provide a concise Chinese summary description (e.g., “This product‘s foreign label includes brand information and trademark‑related content”).
• Expanded mandatory labeling content: Compared to the previous version, new mandatory items have been added: 1) production date and shelf‑life expiry date (“dual date” system), 2) allergen information, and 3) the overseas producer’s registration number in China or the registration number approved by the competent authority of the country (region) of origin.

7. Other Key Revisions in GB 7718-2025 Affecting Importers

Beyond allergen labeling and the dedicated chapter for imported foods, GB 7718-2025 introduces several other revisions that importers must address:

• “Dual date” system: Food labels must now display both the production date and the shelf‑life expiry date (in YYYY-MM-DD format). The previous practice of listing only “shelf life: X months” is no longer sufficient. This change helps consumers directly see when a product expires without manual calculation.
• Inclusion of “sold by weight” products: The definition of prepackaged food now includes foods pre‑packaged and sold by weight (e.g., bulk snacks sold by the kilogram). These foods must also comply with the labeling requirements of GB 7718-2025.
• Digital labels (optional): QR codes may be used to provide supplementary information, but the core mandatory content (allergens, dates, ingredients) must remain on the physical label.
• Ban on “zero added” claims: Misleading claims such as “zero added,” “no added,” or “no artificial flavors” are now prohibited. Importers should remove such claims from labels immediately.

8. Interaction with GB 28050-2025: Nutrition Labeling Upgrades

Importers should be aware that GB 7718-2025 works in tandem with GB 28050-2025 “General Standard for Nutrition Labeling of Prepackaged Foods,” which also becomes mandatory on March 16, 2027. The nutrition labeling standard has been upgraded from “1+4” (energy, protein, fat, carbohydrates, sodium) to “1+6” (adding saturated fat and sugars). Additionally, a mandatory child health prompt statement (“Children and adolescents should avoid excessive intake of salt, oil, and sugar”) must now appear below the nutrition facts panel. For many imported products, this requires new laboratory testing for saturated fat and sugar content, as well as updated nutrition label artwork.

9. Practical Compliance Roadmap for Food Importers

To successfully navigate the new allergen declaration rules and other labeling requirements before the March 16, 2027 deadline, follow this six‑step roadmap:

1. Conduct a comprehensive label audit (Immediate): Review your existing imported product labels against GB 7718-2025 requirements. Identify which products contain any of the eight major allergens. Note any missing “dual date” information (production date + expiry date). Confirm that overseas manufacturer registration numbers are present and correct.
2. Verify one‑to‑one correspondence between foreign and Chinese ingredient lists (Months 1-2): Cross‑reference the original foreign ingredient list with the Chinese translation. Ensure every allergenic ingredient is properly declared using one of the permitted labeling formats (bold, underline, or separate panel). Any ingredient or additive present on the foreign label must be accurately translated and included on the Chinese label.
3. Test for nutritional content (saturated fat and sugar) – Months 2-3: If your product requires a Chinese nutrition label, engage a CNAS‑accredited laboratory to test for saturated fat and sugar content. These two parameters are now mandatory under GB 28050-2025 and must be included on the nutrition facts panel. Update the child health prompt statement accordingly.
4. Design and approve new label artwork (Months 3-4): Work with a professional translator to create compliant Chinese labels. Ensure allergen declarations are correctly formatted. Use “dual date” format (production date and expiry date). Include the child health prompt statement. Remove any “zero added” or similar claims.
5. Coordinate with overseas suppliers (Months 4-5): Communicate the new labeling requirements to your product suppliers. Ensure they understand the need for one‑to‑one correspondence between ingredient lists and the mandatory inclusion of Chinese translations. Request updated allergen declarations and nutritional data if needed.
6. Plan inventory transition (Ongoing): Manage your packaging material inventory to ensure that all products manufactured after March 16, 2027 bear compliant labels. Products manufactured before that date with old labels may be sold through their shelf life, but new production must fully comply.

10. Pre‑Import Label Compliance Checklist for GB 7718-2025

Before submitting any imported food shipment after the effective date, verify compliance with this checklist:

• [ ] Chinese label affixed (printed or permanent sticker).
• [ ] Allergen declaration present for any of the eight major allergens (in bold, underline, or separate panel).
• [ ] Production date and expiry date in YYYY-MM-DD format (“dual date”).
• [ ] One‑to‑one correspondence between foreign and Chinese ingredient lists – no missing ingredients.
• [ ] Overseas manufacturer registration number (GAC registration) correctly displayed.
• [ ] Importer or China agent name, address, and contact information included.
• [ ] Nutrition label updated to “1+6” format (energy, protein, fat, saturated fat, carbohydrates, sugars, sodium).
• [ ] Child health prompt statement present below nutrition facts panel.
• [ ] No “zero added,” “no added,” or similar misleading claims.
• [ ] For cross‑contact risk, voluntary warning present (recommended).
• [ ] For products sold by weight, labeling includes all mandatory content.

Summary: GB 7718-2025 introduces the most significant reform of China‘s food labeling system in over a decade, with the elevation of allergen labeling from a voluntary recommendation to a mandatory requirement as the centerpiece of the revision. The eight major allergens – cereals containing gluten, crustaceans, fish, eggs, peanuts, soybeans, milk, and tree nuts – must now be declared in bold, underlined, or in a separate panel adjacent to the ingredient list. For importers, the new dedicated chapter for imported foods imposes stricter one‑to‑one correspondence rules between foreign and Chinese ingredient lists and adds new mandatory content: production date and expiry date (dual‑date system), allergen information, and the overseas manufacturer‘s registration number. With GB 7718-2025 and GB 28050-2025 both taking full effect on March 16, 2027, importers have a limited transition period to conduct label audits, reformat allergen declarations, update nutrition labels with saturated fat and sugar data, and coordinate with overseas suppliers. Early action is essential to avoid customs holds, shipment delays, and market access disruptions. By following the compliance roadmap and checklist, importers can ensure their products remain compliant in China’s evolving food labeling landscape.