I.Domestic Label Compliance: New Regulations Approaching – Health Food Labels Become a Key Focus   

1.Core Regulations and Key Milestones   

National Level: The “Food Labeling Supervision and Management Measures” (Order No.100 of the State Administration of Market Regulation, 2025; effective March 16,2027); GB 7718-2011 “General Rules for Prepackaged Food Labels” and GB 28050-2011 “General Rules for Nutrition Labels” serve as the foundational standards.

Exclusive for Health Foods: The “Guidelines for Warning Statements on Health Food Labels” stipulate that the warning section must occupy at least 20% of the main display area, with the statement “Health foods are not medicines and cannot replace medical treatment for diseases” clearly printed in bold font. The Blue Hat logo along with the registration number/filing number (e.g., “National Food Health Registration G2025XXXX”) must be prominently displayed, with a font height of ≥6 mm (for large packaging).

2.Required Standard Items and Common Pitfalls

Product name, ingredient list (listed in descending order of quantity), net content, producer/distributor information, production date + shelf life, storage conditions, production license number, and applicable standard code.

Additional requirements for health foods: The health food logo, registration number/filing number, warning statement section, and nutrient supplements must be labeled with “Nutrient Supplement”.

minefield reminder: Avoid using medicalized terms such as “special supply,”  “zero additives,”  “therapeutic,” or “curative”; label content must strictly match the registered/filing information and shall not be altered without authorization.

Small packaging exemption: For minimum sales units with a surface area <35 cm², the product name, Blue Hat certification, production license number, production date, shelf life, and warning statements must still be indicated.

II.EU Label Compliance: Centered on Regulation (EU) No 1169/2011, Digital Labeling Emerges as a New Trend   

1. The core regulation, Regulation (EU) No 1169/2011, applies to all prepackaged foods and requires information to be accurate, clear, and non-misleading.

2. Core Requirements and Mandatory Information under the 2026 New Policy: Product name, ingredient list (including additives), allergens (must be prominently labeled), net content, country of origin/place of origin (for certain categories), operator name and address, storage conditions, usage instructions, alcohol content (>1.2%), and nutritional claims.

Mandatory allergen listing: Ingredients containing gluten, crustaceans, eggs, fish, peanuts, soybeans, dairy products, nuts, and sesame (in certain countries) must be prominently indicated alongside the ingredient list.

2026 New Regulation: -Wine Regulations (EU 2026/471): QR codes may be used to display nutritional information such as energy values; the scan links shall solely contain technical information and must not include marketing content.

New food labeling: For foods containing novel ingredients (e.g., 3-fucosyl lactose), the name and usage conditions must be clearly specified.

Special requirements: The packaging area shall be <10 cm², and must display the product name, allergens, net content, and shelf life; text should preferably be in the local language, with English text permitted as an attachment.

III.U.S. Label Compliance: The FDA’s updated compliance framework introduces new regulations on allergens and pigments.

1. Core Regulations: The FDA’s “Nutrition Facts Label” remains the primary standard, with the 2016 revision still in effect; multiple detailed rules will be implemented between 2025 and 2026.

2. Core Requirements and the 2026 New Nutrition Labeling Policy: Mandatory labeling of calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrates, dietary fiber, sugar, added sugar, protein, vitamin D, calcium, iron, and potassium; “Added sugar” is a mandatory item.

New allergen regulations: The FASTER Act designates sesame as the ninth major allergen, requiring mandatory labeling starting in 2025.

2026 Pigment Regulations: The use of petroleum-based artificial pigments is prohibited; labels may indicate “No artificial pigments” (containing only natural pigments); the FDA has approved natural pigment alternatives such as beet red.

Format requirements: The ingredient list font size shall be ≥1/16 inch (equivalent to the height of the lowercase letter “o”), and it must be laid out on the same page as the manufacturer information; the main display section must clearly display the product name, net content, and operator information.

IV.Key Practical Points for Label Compliance in Cross-Border Contract Manufacturing Enterprises

1. Synchronous Compliance Across Multiple Markets: Customize label templates for different markets to avoid using a single global label; prioritize verification of four core information items: allergens, warning statements, nutritional data, and certification marks.

2. Overlapping platform rules: Platforms such as Amazon and AliExpress impose stricter labeling requirements than regulatory standards, mandating clear, complete, and qualification-aligned labels; heat-sensitive labels (prone to damage) are prohibited.

3. Rapid iteration mechanism: Establish a label compliance review process, align with regulatory updates (e.g., the 2027 domestic regulations, EU wine QR code standards), and complete label registration and printing adjustments in advance.

4. Third-party Verification: Entrust a third-party institution to conduct label compliance evaluations to mitigate the risk of mislabeling; retain label review records for regulatory inspections and platform audits.

V. Summary: Compliance is the prerequisite for cross-border growth. By 2026, compliance requirements for product labeling will become stricter both domestically and internationally. Contract manufacturers with low compliance costs, rapid response capabilities, and high labeling accuracy will gain a competitive edge in the cross-border market. Companies should seize the opportunity presented by the countdown to new domestic regulations to concurrently align with labeling updates in markets such as the EU and the US, establish a comprehensive compliance framework for labeling, and avoid missing market opportunities or incurring financial losses due to labeling non-compliance.