New Labeling Requirements of Solid Beverages will Come into Force on June 1, 2022

On January 7, 2022, State Administration for Market Regulation (SAMR) issued the Notice on Strengthening the Quality and Safety Supervision of Solid Beverages (Notice of No.46, 2021), which put forward many new requirements for the labels of solid beverages. The Notice will be implemented from June 1, 2022. Related enterprises are recommended to make preparations for label rectification in advance.

The key points in the Notice are as follows:

1. The name of solid beverage shall be different with the name of approved special food in China.

CIRS Comments: Special foods that have been approved can be retrieved on the Special Food Information Query Platform.

2. The words of "固體飲料" (solid beverage) shall be prominently marked on the label, and the font size shall not be less than other words on the same display page (including words contained in trademarks, patterns, etc.)

3. The minimum sales unit of protein solid beverages, plant solid beverages, special-purpose solid beverages, flavored solid beverages, and solid beverages with edible bacteria that are directly provided to consumers should be marked with "This product cannot be used as a substitute for food for special medical purposes, infant formula food, health food and other special foods” as a warning message on the same display page. The occupied area should not be less than 20% of the surface on which it is located. The warning message text shall be printed in the SimHei font and have a clear color difference with the background of the warning message area.

4. It is not allowed to use words or pictures to express, imply or emphasize that the products are suitable for specific groups such as minors, the elderly, pregnant women, patients, people with nutritional risk or malnutrition on the labels, instructions and promotional materials of solid beverages. Besides, production process, raw material name, etc. shall not be used to express or imply the disease prevention and treatment function, health care function, function of meeting the special needs of specific disease groups, etc.

CIRS Comments: In addition to labels, this provision also applies to instructions and promotional materials. Enterprises need to pay more attention when advertising on manuals, brochures, and even web pages.

5. The Notice will be implemented from June 1, 2022. Products previously produced can continue to be sold during the shelf life.

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SAMR Notice on Strengthening the Quality and Safety Supervision of Solid Beverages