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Member News: Requirements of Restricting Excessive Packaging-Food & Cosmetics

China continues its fight to combat excessive packaging in the food and cosmetics industry. On September 1st 2023, the ‘National Food Safety Standard Restricting Excessive Packaging for Foods and Cosmetics (GB 23350-2021) was updated. We asked Sparks Partners for their interpretation and what New Zealand companies need to consider for their product packaging in China. Read through it below:


Q: What is the National Standard of the People's Republic of China?

A: The National Standard of the People's Republic of China, commonly referred to as the national standard or GB (GuoBiao), is a set of mandatory technical specifications, guidelines, and requirements established by the Chinese government. These standards are developed by specialized committees and cover various industries and sectors to ensure product safety, quality, and compatibility across the country.

Q: What constraints does the National Standard impose on the food industry?

A:

  • Food Safety

  • Labeling and Packaging

  • Quality Control

  • Production Standards

  • Compliance and Inspections

Q: What aspects does China's national standard "GB 23350-2021" mainly stipulate?

A: This standard, which was implemented on September 1, 2023, provides clear requirements of restricting excessive package of foods and cosmetics. The No.1 Amendment attached at the end of this national standard has been implemented on August 15, 2022, which includes a specific provision regarding the mooncakes and zongzi (sticky rice dumplings).

Q: Does the new national standard only apply to domestically produced and sold food/cosmetics?

A: No, the new national standard applies to all sales packaging of food (including bulk food) and cosmetics produced, sold, and imported within China. It does not differentiate between domestically produced and imported products. Therefore, both domestically produced and imported food and cosmetics must comply with the packaging requirements outlined in the standard.

Q: What are considered excessive packaging practices according to the new national standard?

A: According to the new national standard, excessive packaging practices include:

  • having too many layers of package

  • large empty spaces in the package, and

  • packaging that incurs high costs.

Q: According to the new national standard, what actions do we need to take?

  • The number of packaging layers for food should be limited, with grains and processed products not exceeding three layers and other food and cosmetics not exceeding four layers.

  • The cost of all packaging, excluding the packaging in direct contact with the contents, shall not exceed 20% of the product's selling price.

Q: Can you briefly summarize the special provisions of the No. 1 Amendment on mooncakes and zongzi?

A:

  • It states that mooncakes should not be mixed with other products (wine, tea, cutlery, etc.), except for food deoxidizers and ice packs used to protect the mooncakes.

  • It states that zongzi should not be mixed with products that exceed its price.

  • For both products with a selling price of over 100 yuan, the packaging cost should not exceed 15% of the selling price. The standard also prohibits the use of expensive materials such as precious metals and rosewood in packaging materials.

Q: Is there a national database/resource companies can go to for specific packaging requirements?

A: National GB standard database: 国家标准全文公开系统


About Sparks Partners


Sparks Partners is a partnership law firm founded by Rocky Meng in Shanghai. We take pride in offering a wide range of comprehensive and high-quality legal services. Our team consists of dedicated and experienced legal professionals who specialize in areas including intellectual property, foreign direct investment, international trade, legal compliance and litigation.


Founder Rocky Meng insists on dedicating the firm's resources in serving Kiwi clients. Sparks Partners’ NZ clients include companies in the Food&Beverage industries, primary produce, manufacturing, education, tech and software providers. Sparks Partners is also on NZTE's list of legal advisors.

At Sparks Partners, your satisfaction is our utmost priority. We strive to build long-lasting relationships based on trust and exceptional services. To find out more, please visit our website www.sparkslaw.cn


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