Chinese back labels on imported food and wine (中文标签)
Imported pre-packaged food and wine may not enter China without a Chinese label naming the country of origin and the business in China that answers for it. It can be a sticker over the original. From 16 March 2027 a new standard also requires the overseas plant’s China registration number and the eight major allergens.
Your Chinese importer has asked for the artwork for the “Chinese back label”, and the first shipment is booked. If the label is wrong, the goods can be held at the port until it is fixed, or sent back. Once they are on a shelf, a shopper can claim ten times the price.1 The rules also change on 16 March 2027, so a label designed this year may not serve next year’s shipments.2,3
Two details are easy to miss. From that date the label must carry the China registration number of the plant that made the food. And a bottle of wine with a lot number on it needs no date at all.2,4
What must the Chinese label on imported food show?
Everything a Chinese-made food’s label shows, less two items that only apply to domestic producers, plus three that only apply to imports. The base list comes from the Food Safety Law, and GB 7718, the national labelling standard (预包装食品标签通则), sets out how each item is shown. The table follows the 2025 edition, which applies from 16 March 2027.
| Item | What the label shows |
|---|---|
| Name食品名称 | A name that states what the food is. A brand or transliterated name may sit beside it, not replace it |
| Ingredients配料表 | Every ingredient on the foreign list, in Chinese, plus anything Chinese rules require that the foreign list leaves out |
| Allergens致敏物质 | Cereals containing gluten, crustaceans, fish, egg, peanut, soy, milk and tree nuts, where used as ingredients. Voluntary under the 2011 edition, mandatory from 2027 |
| Net content净含量 | On the same panel as the name |
| Importer or agent进口商 / 代理商 | Name, address and contact details of whichever bears food-safety responsibility in China, introduced by that word |
| Registration number在华注册编号 | The overseas plant’s China registration number, or the number its own authority approved. It identifies the plant, not the importer, which the label names by name, address and contact details |
| Country of origin原产国 | Where the last substantial transformation happened. If it was bottled or repacked elsewhere, that country too |
| Dates日期标示 | Production date and expiry date. With a shelf life of 6 months or more, the shelf life and expiry date are enough |
| Storage贮存条件 | How to store it |
| Not needed on imports | The Chinese production licence number and the product standard code |
The producer’s own name and address, a foreign distributor’s name and address, the trademark and the website may stay in the original language only.4
Can the Chinese label be a sticker over the original?
Yes, for most food: the standard accepts a Chinese label that is printed or affixed. Like any label, a sticker must be durable and must not come away from the package.2 Foreign text the sticker covers does not need translating. Foreign text left visible must comply with Chinese rules too, and every mandatory item in it needs a Chinese counterpart.4
Two limits apply. Health food (保健食品) and food for special dietary uses must have their Chinese label printed on the smallest sales package, with no sticker.5 And a wine that relies on its lot number in place of dates may not have that number stickered over, overprinted or altered, as the next section explains.4
Because the mandatory items must match one to one, the translation is part of the label’s compliance. The translation of the original label that customs asks for at inspection need not be certified.6 Having it done as a certified Chinese translation is a practical choice, not a legal requirement.
Does a Chinese back label on wine need anything different?
Wine follows the general standard, with three additions and one exemption. The wine standard, GB 2758-2012, which is still current, adds the alcohol content in %vol and the warning “过量饮酒有害健康” (excessive drinking harms health).3,7 A wine made with sulphur dioxide as an additive must list it as 二氧化硫 (sulphur dioxide), or as 微量二氧化硫 (trace sulphur dioxide) with the amount. The guidance sets no level below which it may be left off.4
The exemption is the dates. With a lot number on the bottle, wine of any strength, and other alcoholic drinks of 10% vol or more, need no production date, shelf life or expiry date.2 The catch is that the lot number then may not be stickered, overprinted or altered.4 It has to be on the bottle as it leaves the winery.
Take a 750 ml New Zealand Sauvignon Blanc at 13% vol, shipped to an importer in Shanghai in May 2027. The original label stays on, and a Chinese sticker on the back carries:
- the name 葡萄酒 (wine) with the style, and the ingredients, including 二氧化硫 (sulphur dioxide);
- 750 ml and 13%vol;
- the importer’s name, address and phone number, under 进口商 (importer);
- the winery’s China registration number, and 原产国 新西兰 (country of origin, New Zealand);
- storage conditions and the health warning.
The lot number printed on the glass at bottling does the work of the dates.
The registration number is the one the winery obtains under Decree 280 of the General Administration of Customs (GACC). How a drinks producer gets it, and why customs will not accept the declaration without it, is in GACC registration under Decree 280.
Who checks the label, and when?
The Chinese importer reviews it, and customs checks it at the border. China stopped pre-approving import labels on 1 October 2019. Since then the label has been one item in the food’s inspection, and the importer is the party responsible for checking that it complies.6
If the shipment is picked for inspection, the importer hands customs the original label, its translation and a sample of the Chinese label.6 A label that fails on a point that is not about safety can be corrected, and the goods are released once they pass. If they cannot be fixed in time, the importer is ordered to destroy them or ship them back.5
This is one reason the importer’s identity matters before you design anything: its name goes on the label, and it carries the responsibility. Whether that partner buys the goods or sells them for you changes more than the label. The differences are in selling through a Chinese distributor or agent. Goods sold to consumers through cross-border e-commerce follow separate rules.6
How much can a wrong label cost once the food is on sale?
Two things: a fine from the market regulator, and claims from shoppers. A business selling food whose label breaks the rules can be fined RMB 5,000 to 50,000 where the goods are worth under RMB 10,000, and 5 to 10 times their value above that.1 A shopper can claim ten times the price paid, or three times the loss, and at least RMB 1,000.1
The Supreme People’s Court has drawn the line between what costs ten times the price and what does not.8 Leaving out an item the standard requires is not a minor flaw, and the seller cannot defend itself on that ground. A clumsy translation, or foreign text printed larger than the Chinese, does not support a tenfold claim, as long as it does not mislead anyone about safety.
Say a Belgian biscuit made with wheat, butter and egg goes on sale in Hangzhou after 16 March 2027 with no allergen statement on its Chinese label. A shopper who paid RMB 1,200 for a case can claim RMB 12,000, ten times the price. The same biscuit with “butter” rendered awkwardly in Chinese gives the shopper no tenfold claim.
Which rules change on 16 March 2027?
GB 7718-2025 was issued on 16 March 2025 and takes effect on 16 March 2027, when it replaces the 2011 edition. The Food Labelling Supervision Measures of the State Administration for Market Regulation (SAMR) take effect the same day.2,9 For an imported product the changes that move the artwork are these:
- The overseas plant’s China registration number goes on the label.
- The eight allergen groups listed in the table above become mandatory.
- “No added” claims are banned, including 不添加, 零添加 and their synonyms, unless another standard provides for them.2
- Mandatory text must be at least 1.8 mm tall and the dates at least 3.0 mm, and no foreign text may be taller than the Chinese beside it.9
- A QR-code digital label becomes an option, but what it shows must match the pack.2
Food produced before 16 March 2027 may stay on sale until its shelf life ends, unless its label breaks one of the new prohibitions. That is how a city regulator summarised SAMR’s implementation guidance in September 2026.10
What is not yet settled for imported labels?
As of 5 October 2026, three points have no published answer. Neither the standard nor the official Q&A says which label a product made before 16 March 2027 but imported after it needs. The standard says every visible word on an import must comply, foreign text included, and it bans “no added” claims.2 No guidance says how customs reads an English “no added sugar” left visible beside a Chinese sticker. And GACC has issued no notice on inspecting labels under the new edition.
Market Entry and Structure Advisory sets out what a product needs before its first shipment, from the plant registration to who stands on the label as importer.
Want this done rather than explained? Market Entry & Structure Advisory From US$900, 2–3 weeks. See the service Sources
- Food Safety Law of the PRC (中华人民共和国食品安全法), as amended 12 September 2025: Article 97, Chinese labels on imported pre-packaged food and no import without one; Article 125, fines for food with non-compliant labels; Article 148, ten times the price or three times the loss, at least RMB 1,000 (MOFCOM law database, policy.mofcom.gov.cn, retrieved 5 October 2026)
- National Food Safety Standard: General Standard for the Labelling of Prepackaged Foods (食品安全国家标准 预包装食品标签通则), GB 7718-2025, issued 16 March 2025, in force 16 March 2027: clauses 3.2, 3.6, 4.4.2.2, 4.12, 8.1 to 8.7, 9 and 10.1 to 10.2 (full Chinese text, USDA Foreign Agricultural Service copy, gain.fas.usda.gov, retrieved 5 October 2026)
- National Health Commission, Catalogue of National Food Safety Standards (食品安全国家标准目录), to September 2025: GB 7718-2011 replaced on 16 March 2027; GB 2758-2012 current (nhc.gov.cn, retrieved 5 October 2026)
- National Health Commission and SAMR, explanatory material and Q&A on GB 7718-2025 (解读材料 and 问答): items 42 (sulphur dioxide in wine), 43 and 45 (stickers and foreign text), 48 (working out a production date), 49 (importer or agent, registration number) and 50 (wine exemptions), as printed from the NHC standards platform (Quanzhou Administration for Market Regulation, scjgj.quanzhou.gov.cn, retrieved 5 October 2026)
- Administrative Measures on the Safety of Imported and Exported Food (中华人民共和国进出口食品安全管理办法), GACC Order No. 249, in force 1 January 2022: Article 28(5), customs inspection covers labels; Article 30, health food and special dietary food labels printed on the smallest sales package, not stickered; Article 33, technical treatment, destruction or return (State Council Gazette 2021 No. 18, gov.cn, retrieved 5 October 2026)
- GACC Announcement No. 70 of 2019 on the inspection and supervision of labels on imported and exported pre-packaged food (海关总署公告2019年第70号), in force 1 October 2019: items 1, 2, 3 and 5 (gov.cn, retrieved 5 October 2026)
- National Food Safety Standard: Fermented Alcoholic Beverages and Their Integrated Alcoholic Beverages (发酵酒及其配制酒), GB 2758-2012, in force 1 February 2013: clause 4, alcohol in %vol and the warning “过量饮酒有害健康” (Guangdong Medical Products Administration copy, anan.gov.cn, retrieved 5 October 2026)
- Supreme People’s Court, Interpretation on Punitive Damages in Food and Drug Disputes (关于审理食品药品惩罚性赔偿纠纷案件适用法律若干问题的解释), 法释〔2024〕9号, in force 22 August 2024: Articles 6 and 8 (court.gov.cn, retrieved 5 October 2026)
- Food Labelling Supervision Measures (食品标识监督管理办法), SAMR Order No. 100, published 14 March 2025, in force 16 March 2027: Article 11, foreign text no taller than the Chinese; Article 13, minimum character heights (gov.cn, retrieved 5 October 2026)
- Wuhu Administration for Market Regulation, notice on “zero added” labels, 8 September 2026, citing SAMR’s implementation Q&A on the Food Labelling Supervision Measures, question 35 (amr.wuhu.gov.cn, retrieved 5 October 2026)
All sources checked 5 October 2026. This page is general information, not legal, tax or customs advice. Requirements vary by product, market and circumstance. Confirm your own position before acting.
