July 01, 2011

National Food Safety Standards for Pathogen Limits and Nutritional Labeling

National Food Safety Standards for Pathogen Limits for Food (Draft for Comment)
Issuing Body: Ministry of Health
Issuing Date: December 2010

National Food Safety Standards for Nutrition Labeling of Prepackaged Foods (Draft for Comment)
Issuing Body: Ministry of Health
Issuing Date: April 7, 2010

With food safety a growing concern in China—and around the world—China's Ministry of Health issued a draft National Food Safety Standards for Pathogen Limits for Food ("Pathogen Limits Standards") in December 2010, pursuant to its authority to formulate such standards provided by China's Food Safety Law, which was enacted by the National People's Congress in February 2009, and the Food Safety Law Implementing Regulations, which were promulgated by the State Council in July 2009. The Ministry of Health also issued a draft National Food Safety Standards for Nutrition Labeling of Prepackaged Foods ("Nutrition Label Standards") on April 7, 2010.

Pathogen Limits

The Food Safety Law lists a number of areas on which food safety standards will focus, including pathogenic microorganisms in food and food-related products, varieties, food additives, and nutrition labels.

The draft Pathogen Limits Standards cover 17 categories of food produced, served in, imported to, or exported from China: meat and meat products; aquatic products; egg products; cereal products; soybean products; baked and fried food; candy, chocolates, and cocoa products; honey and honey products; processed fruits; algae products; beverages; frozen beverages; alcoholic drinks; condiments; fats and oils; fruit jelly; and instant foods.

While the Pathogen Limits Standards are primarily based on China's existing food safety standards, the Ministry of Health also referred to international and foreign national standards enacted by the United States, the International Commission on Microbiological Specifications of Food, the European Union, Australia, and Canada, as well as other countries. The ministry's stated goal was to align China's new standards with global practices while remaining workable in China.

The Pathogen Limits Standards specifically list the most common kinds of pathological bacteria found in food, such as salmonella, Staphylococcus aureus, and Shigella. Currently, for most food, the existing food safety standards allow for no detectable presence of salmonella, Staphylococcus aureus, and Shigella when inspections are made. Rather than simply demand a complete absence of pathogens, however, the Pathogen Limits Standards adopt new risk-based criteria of limits, wherein the maximum permissible amount of particular pathogens within each category of food is determined on the basis of an analysis of potential risk resulting from the presence of the pathogen.

With technical improvements in food production and the rapid development of China's tourism industry, canned food has become increasingly common, and people have become increasingly aware of related safety questions. The Pathogen Limits Standards provide that food produced by canning technology with ultra-high temperatures and short-term sterilization must meet requirements of commercial sterilization, which have previously been published.

Nutrition Labeling

The Nutrition Label Standards establish requirements for providing consumers with certain basic information about the nutritional content of packaged foods.

The requirements apply to "prepackaged foods," which are defined as food products that are directly edible by consumers. Prepackaged food processing raw materials are excluded from the requirements.

The Nutrition Label Standards make it mandatory to list "energy and four core nutrients (protein, fat, carbohydrates and sodium)" along with their content and nutrient reference values on labels. In addition, under each nutrient component, certain sub-components must be listed. Under fat, for example, there will be subcategories for saturated fat, unsaturated fat, and transfat, and if any of these is contained in the prepackaged food, it must be indicated accordingly on the label.

The Nutrition Label Standards also provide that nutrition information must be presented in a tabular format. The Ministry of Health attached six types of recommended formats in an exhibit, varying from very concise to detailed, from only Chinese to bilingual (for the benefit of foreigners).

Finally, the Nutrition Label Standards exempt certain prepackaged food from the new labeling rules. Among those foods that would be exempt are fresh foods such as raw meat, fish, and vegetables, bottled water, foods sold on-site, health food, infant formula, and formulas for medical purposes.


Under China's two-year-old Food Safety Law, a significant number of food safety standards are to be compiled, updated, or drafted anew in order to keep pace with trends and international practices. As a result, food producers and distributors need to keep a close eye on developments with these standards to ensure compliance.

Although the Pathogen Limits Standards and Nutrition Label Standards are still at the draft stage, both are expected to be finalized and officially issued in the near future.

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