China CFDA Drafts Guidelines for the Labeling of Infant Formula Milk Powder Formula Registration

On 26 January 2017, CFDA released two supplementary documents for infant formula milk powder formula registration relating to labeling and stability research for public comments. Opinions and advises shall be given before 20 February 2017. Here CIRS will focus on the labeling guideline, to help you better understand the relevant important labeling requirements.

1. Highlights on the product name

The product name consists of trade name and common name. Comparing with the Formula Registration Measure and the Dossier Requirement Regulations, the drafted 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

The forbidden words for the trade name are more specific in the Guideline. If it comes into force, a lot of current product shall modify their names.

S.N.

Forbidden Chinese words

Examples

1

Words that are false, exaggerated, violating the principles of science or absolute

金装”(gold), “超级”(super), “升级”(upgrade), “博士”(doctor), “冠军”(champion), “天才”(genius), etc.

2

Words that involving health function , disease prevention or treatment;

宝康”(baby health), “贝健”(baby health), “优护”(good care), etc.

3

Express and imply the function of improving intelligence, strengthening resistance or immunity, protecting intestine, etc.

益智”(intelligence benefit), “聪明”(clever), “贝聪”(baby clever), “益生菌”(probiotic), etc.

4

Vulgar or words with feudal superstition

金字塔”(pyramid), “金皇后”(golden queen), “名门贵族”(famous aristocracy), etc.

5

Words involving human tissues and organs

心护”(heart protection), etc.

6

Names with similar words to mislead consumers

体智佳”(wisdom and good), “亲体”(close to body), “母爱(love of mother)”, etc.

1.2 Format of product name 

I. 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. 

II. The common name shall be marked prominently on the top 1/2 of the main layout. 

III. It is forbidden to highlight the trade name through colour and size. The font size of trade name shall be no more than 1/2 of the common name.

IV. Colour of the product name shall be obvious on the label. 

2. Other Labeling requirements 

Items

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.

Foreign language except English on the label

I. The Foreign product name shall be translated into English.

II. The notarized translation and undertaking shall be provided when applying for registration.

Registered trade mark except trade name

I. The font size shall be not more than 1/4 of the common name, and shall be small 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.

CIRS comments

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.

If you have any needs or questions, please contact us at service@cirs-reach.com.


Reference: http://www.sfda.gov.cn/WS01/CL0782/169260.html