On 25 May 2017, CFDA released the formal version of Guidelines for the Labeling of Infant Formula Milk Powder Formula Registration (Trial). Compared with the draft version, there is no big change in the formal version. Here we listed the key points in the guideline, to help you better understand the relevant important labeling requirements.
- Highlights on the product name
The product name is consisted of trade name and common name. Compared with the Formula Registration Measure and the Dossier Requirement Regulations, the Labeling Guideline puts up stricter requirements on the product name. Enterprises shall pay more attention to the name.
1.1 Forbidden words for trade name
|S.N.||Forbidden Chinese words|
|1||Words that are false, exaggerated, violating the principles of science or absolute|
|2||Words that involving health function, disease prevention or treatment;|
|3||Express and imply with the function of improving intelligence, strengthening resistance or immunity, protecting intestine, etc.|
|4||Vulgar or words with feudal superstition|
|5||Words involving human tissues and organs|
|6||Names with similar words to mislead consumers|
Previously in the drafted version, there are several specific examples for each forbidden items, such as “金装”(gold), “超级”(super), “升级”(upgrade), “宝康”(baby health), “贝健”(baby health), “优护”(good care), etc. However, all samples have been removed in the formal one. Even though, we still suggest enterprises to avoid using these words in the trade name, to avoid unnecessary troubles.
1.2 Common name
The common name is clearly stipulated. It shall be “婴儿配方乳（奶）粉（0—6月龄，1段）”, or “较大婴儿配方乳（奶）粉（6—12月龄，2段）”, or “幼儿配方乳（奶）粉（12—36月龄，3段）”, according to the suitable ages.
1.3 Format of product name
- The common name cannot be separated, and the font, size, colour shall stay consistent. e.g., for “婴儿配方乳（奶）粉（0-6月龄，1段）” (infant formula milk powder (0-6 months, 1 stage)), it is forbidden to indicate “婴儿配方乳（奶）粉” and “（0-6月龄，1段）” in two different places of the label.
- Calculated in single font area, the total font area of trade name shall be not more than 1/2 of the common name. And the font size of trade name shall be small than common name.
III. Colour of the product name shall be obvious on the label.
- Other Labeling requirements
|Place for Production license number (oversea manufacturer registration number for imported food), formula registration number, production date, agent information, etc.||The place for these contents shall be reserved on the sample manuscript of label and instruction with the format of “XXX”. Detail information shall be added when get them.|
|Registered trade mark except trade name||I. The font area shall be not more than 1/4 of the common name, and shall be smaller than trade name.
II. It is forbidden to use together with the product name.
III. When labeled on the main layout, it shall be indicated on the corner of the label.
|Optional contents on the label||I. For the allowed content claims and function claims in China, they shall be indicated as text in the non-main layout.
II. The certificated items can be marked by text or certification mark in the non-main layout, and the copy of the confirmation certificate shall be submitted.
III. Information for product traceability, reminders or alerts, and custom service can be indicated on the label as well.
Chinese government attaches great importance to infant formula milk powder. With the release of this new Guideline for Labeling, the designation of infant formula label will be more standardized. More current claims will be forbidden to use, and more formats on the label need to modify. Enterprises shall focus on the labeling requirements, and adjust the Chinese label design in time.