Allergen Labeling in China: GB 7718-2024 from March 2027

Introduction

China is undergoing a significant overhaul of its food labeling framework. The new national standard GB 7718-2024 was published in 2024 and takes effect on March 27, 2027 — with one change of particular importance for businesses operating internationally: for the first time, binding allergen declaration requirements are being introduced for pre-packaged food at this comprehensive level.

For European food manufacturers exporting to China, this is a clear regulatory obligation with a fixed deadline. For international restaurant chains managing operations across markets, for Chinese food businesses operating in Europe, and for any operator receiving growing numbers of Chinese guests, a working understanding of GB 7718-2024 is increasingly relevant. Acting early means avoiding supply chain disruptions, labeling non-compliance, and customs rejections — all of which become harder to manage as the March 2027 deadline approaches.

GB 7718-2024: What Is the New Standard?

GB 7718 is China’s national standard for the labeling of pre-packaged food (预包装食品标签通则, Yù bāozhuāng shípǐn biāoqiān tōngzé). The current version in force is GB 7718-2011, which has governed food labeling in China since 2011. The new GB 7718-2024 replaces it entirely.

The standard is issued by SAMR (State Administration for Market Regulation, 国家市场监督管理总局) — China’s central authority for market oversight, food safety, and standardization. GB 7718 is not a voluntary industry guideline; it is a mandatory national standard (强制性国家标准, qiángzhìxìng guójiā biāozhǔn). Every pre-packaged food product sold in China — whether domestically produced or imported — must comply with it.

The most significant substantive change in GB 7718-2024, based on current information, concerns allergen labeling. Under the 2011 standard, allergen declarations were recommended but not legally mandated. The new standard introduces binding requirements for allergen declaration, bringing China into alignment with the approach already established in the EU under the FIC Regulation and in the US under FALCPA and the FASTER Act.

Effective Date March 27, 2027 — Transition Period

GB 7718-2024 was published in 2024 and takes full effect on March 27, 2027. The approximately three-year transition period is intended to give manufacturers, importers, and exporters time to review formulations, redesign labels, update packaging lines, and align internal compliance processes.

Under the transitional provisions, products that were lawfully manufactured and labeled before the March 27, 2027 deadline may continue to be sold — even if they do not yet fully comply with the new standard. From the deadline onwards, however, all newly produced food sold in China must meet GB 7718-2024 requirements without exception.

For exporters, this distinction matters operationally: production dates and import clearance dates often differ by weeks or months. A product manufactured in late 2027 under old labeling cannot be retroactively brought into compliance at the point of import. The practical recommendation is to set an internal compliance deadline well before March 2027 — ideally by mid-2026 at the latest — to leave adequate time for label design, regulatory review, and production changeover.

China’s Allergen List vs. EU-14 and US Top 9

Based on current information, China’s allergen list under GB 7718-2024 covers the globally recognized major food allergens, with notable differences from both the EU and US frameworks:

Key differences from the EU:

First, China — like the US — does not use the EU’s overarching category of „cereals containing gluten.“ Instead, it refers to specific grain types. This means rye, barley, and oats may not automatically fall under the same declaration requirement as wheat, which has direct implications for products containing barley malt, rye flour, or oat-derived ingredients.

Second, the five EU-specific allergens — celery, mustard, lupin, molluscs, and sulphur dioxide/sulphites — are not, based on current information, included in China’s mandatory allergen list. A product fully compliant under EU labeling rules is not automatically compliant for the Chinese market, and vice versa.

Third, precautionary allergen labeling („may contain traces of…“) has historically been voluntary in China. Whether GB 7718-2024 introduces any changes to this remains, based on current information, to be clarified in implementing guidance. Exporters should verify this with a China-specialized food law advisor before finalizing label copy.

SAMR Regulation and Enforcement

SAMR (国家市场监督管理总局) is the apex authority for food labeling standards in China. It issues national standards, coordinates regulatory oversight, and can initiate enforcement action against non-compliant products and businesses. In practice, day-to-day enforcement is carried out at the provincial and municipal level by local market supervision bureaus — which can result in variation in enforcement intensity and response times across different regions of China.

The legal basis for penalties is China’s Food Safety Law (食品安全法, Shípǐn ānquán fǎ), most recently amended in 2021. Labeling violations can attract administrative fines, suspension of business licenses, product recalls, and, in serious cases, criminal prosecution. The scale of penalties is substantial: for significant violations, fines can reach five times the value of the illegal proceeds, with additional consequences for responsible individuals within the company.

Compared to the EU’s enforcement framework, China’s system is less harmonized across its territory — local authorities exercise significant discretion. However, the direction of travel is clearly toward stricter enforcement, particularly for imported products subject to customs inspection. Non-compliant labeling on imported goods can result in the rejection of entire shipment batches at the border, which represents a significant financial and logistical risk for exporters.

Impact for International Businesses

European food manufacturers exporting to China face the most direct compliance obligation under GB 7718-2024. Labels must be updated, and the allergen declaration must meet the new mandatory requirements before products manufactured after March 27, 2027 enter the Chinese market. Given lead times for label redesign, regulatory consultation, and production changeover, beginning this process in 2025 is strongly advisable.

Chinese restaurant chains and food businesses operating in Europe that move products or semi-finished ingredients between the EU and China face a dual compliance challenge: EU labeling for the European market and Chinese labeling for the Chinese market. These are not interchangeable. Managing both requires a labeling infrastructure that can generate jurisdiction-specific outputs from a single source of truth on ingredient composition.

How to Prepare Now

For any business with a China connection, a structured three-step approach is recommended:

1. Know China’s allergen list: Audit your product formulations against the GB 7718-2024 allergen requirements. Identify where your ingredients differ from EU requirements and where additional declaration obligations may arise. Engage a food law specialist with China expertise to validate your assessment.

2. Review label compliance: Systematically compare your existing labels for the Chinese market against the new standard’s requirements. Factor in not just allergen content, but also formatting requirements, font sizes, and language specifications that may be mandated under the full GB 7718-2024 text.

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Frequently Asked Questions

What does the Chinese standard GB 7718-2024 regulate?

GB 7718-2024 is China’s national standard for the labeling of pre-packaged food (预包装食品标签通则), issued by SAMR (国家市场监督管理总局). It replaces the previous standard GB 7718-2011, which has governed food labeling in China since 2011. As a mandatory national standard — not a voluntary guideline — it applies to all pre-packaged food sold in China, including imported products regardless of their country of origin.

The most significant change concerns allergen labeling. Under the 2011 standard, allergen declarations were recommended practice but not legally mandated. GB 7718-2024, based on current information, introduces binding allergen declaration requirements for the first time at this comprehensive level, bringing China into alignment with the regulatory approach already established in the EU and the US. This represents a meaningful shift in China’s food safety framework and signals a direction of travel toward stricter consumer protection standards that is likely to continue beyond 2027.

When does the new allergen labeling take effect in China?

The new standard GB 7718-2024 takes full effect on March 27, 2027. Since its publication in 2024, companies have had a transition period of approximately three years to adapt their products, labels, and internal processes. Products manufactured and labeled lawfully before the March 27, 2027 deadline may continue to be sold in China even after that date — the deadline governs production, not point of sale.

For exporters to China, the practical implication is clear: do not wait until early 2027 to begin the transition. Label redesign, regulatory review, supplier documentation updates, and production changeovers all take time, and the consequences of missing the deadline — customs rejections, product recalls, regulatory fines — can be severe. Setting an internal compliance target of mid-2026 at the latest provides an adequate buffer for the typical complexity of label change processes in international food businesses.

Which allergens must be declared in China?

Based on current information, China’s allergen list under GB 7718-2024 includes the globally recognized major food allergens: cereals containing gluten, crustaceans, fish, eggs, peanuts, soybeans, milk, tree nuts, and — based on current information — sesame. This broadly parallels the US Top 9 list, though the classification details differ in important respects.

Compared to the EU’s 14 mandatory allergens, China’s list does not include celery, mustard, lupin, molluscs, or sulphur dioxide/sulphites. Additionally, China does not use the EU’s broad category of „cereals containing gluten“ to encompass all relevant grain types; rye, barley, and oats may therefore not fall under the same mandatory declaration requirement as wheat. This means a product fully compliant with EU allergen labeling is not automatically compliant for the Chinese market — and a separate, China-specific compliance review is essential for any exporter.

Does the Chinese allergen law affect restaurants in Europe?

Not directly. GB 7718-2024 applies to pre-packaged food sold in China; it does not extend to restaurant operations in Europe, where EU law — the FIC Regulation and national implementing measures — governs allergen labeling requirements. However, the indirect effects are real and should not be dismissed.

European food manufacturers exporting to China must comply with the new standard by March 2027. Chinese restaurant chains or food businesses in Europe that move products or ingredients between the EU and Chinese markets face dual compliance obligations. And as Chinese consumer expectations around allergen labeling evolve — driven by the normalization of mandatory labeling at home — Chinese tourists and expatriates in Europe increasingly expect clear, accessible allergen information when eating out. For European restaurants serving Chinese cuisine or operating in areas with significant Chinese visitor numbers, providing this information clearly — ideally in Chinese as well as the local language — is a meaningful expression of hospitality and a practical risk management measure.

Last updated: 2026 · ChinaYung — Allergen labeling for food service