What are the key points of the import prepackaged food label review?

Case replay

After verification by the Chongqing Municipal Food and Drug Administration (now the Market Supervision and Administration Bureau), a Chongqing trading company sold one box of "German Double Heart Deep Sea Fish Oil SoftGels" to three customers on May 14, September 26 and November 16, 2017, respectively, with a total of 262 yuan

Lawyer's opinion

The above cases belong to the situation that

Knowledge extension

On December 18, 2017, the Import and Export Food Safety Bureau of the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China issued a letter on the WTO TBT Notification on the Measures for the Supervision and Administration of The Labeling of Import and Export Prepackaged Foods (hereinafter referred to as the "Measures"), which is an adjustment to the content of the Provisions on the Supervision and Administration of the Labeling of Import and Export Prepackaged Foods promulgated in 2012 and has been implemented

Therefore, when reviewing the labels of imported prepackaged food, food enterprises must pay attention to the provisions of various laws and regulations, and generally need to grasp the following three aspects

1 Standards and regulations related to food labelling

Specifically, it is divided into four types: laws and regulations, departmental rules, normative documents, and standards

(1) Laws and regulations, such as the Food Safety Law, the Regulations for the Implementation of the Food Safety Law, the Product Quality Law, the Advertising Law, etc.

(2) In terms of departmental regulations, such as the Administrative Measures for the Inspection and Supervision of Import and Export Prepackaged Food Labels, the Regulations on the Administration of Food Labeling, the Administrative Measures for the Certification of Organic Products, and the Administrative Measures for Prohibiting Food Dosing, etc.

(3) Normative documents, such as the Notice of the Ministry of Health on Further Regulating the Management of Health Food Raw Materials, the Letter on Opinions on the Labeling of Imported Infant Formula Milk Powder, and the Letter on Whether Snow Chrysanthemum Can Be Used as An Ordinary Food Raw Material;

(4) Standards, such as "General Rules for Labeling Prepackaged Food", "General Rules for Nutrition Labeling of Prepackaged Foods", "General Rules for Food Additives", etc

2 Tag review content

(1) Whether the product meets the requirements of import and export laws and regulations;

(2) The review of the content of the label identification, the standardization of the text (whether the translation language is standardized, whether the content is true and complete, etc.

(3) Review of the consistency of Chinese and foreign content;

(4) Review of the use of food additives and nutritional enhancers;

(5) Review of labeling and pasting methods;

(6) Review of the content of the original packaging picture;

(7) Compliance audit

3 Label review steps

Step 1: Determine the food category;

Step 2: Determine the reference standard and basis;

Step 3: Audit according to the standard;

Step 4: Discover and correct problems with labels in

In the inspection of imported food labels, the non-conformity ratio with the standard is relatively high

However, the label inspection of imported prepackaged food is an indispensable content of imported food inspection, and the label inspection is unqualified, and the technical rectification treatment is required, and the whole batch of products may be returned or destroyed

Finally, in view of the current lack of professionals engaged in food labeling audits in the vast majority of food enterprises, it is recommended that imported food dealers can entrust third-party food labeling professional institutions to conduct compliance audits in advance, and then send the labels to third-party food labeling testing agencies to issue label qualified test reports after proofing, which can minimize the legal risks