Compliance Guidance on the New Prepackaged Food Labeling Rules: Digital Labels

Foodmate News: The National Food Safety Standard — General Rules for the Labeling of Prepackaged Foods (GB 7718-2025) incorporates digital labels into the national food safety standard for the first time, clarifying the legal status of digital labels. Subsequently, the National Health Commission and the State Administration for Market Regulation published the Announcement on Matters Concerning the Implementation of Digital Labels for Prepackaged Food, further detailing the application requirements for digital labels. The Measures for the Supervision and Administration of Food Labeling also stipulate that where QR codes and other information-based means are used on food packaging to display food label content, the content shall comply with the requirements of the Measures. To help food production and operation enterprises better understand and implement the new rules, Foodmate has sorted out the requirements for the use of digital labels for prepackaged food for industry reference.

01

What Is a Digital Label

GB 7718-2025 defines a "digital label" as "a food label displayed on food packaging by information-based means such as QR codes".

Digital labels break through the "physical" boundary of food labels. In addition to displaying food information more clearly through the zoom function of the digital label page, the audio and video functions provided by digital labels greatly enrich the forms in which food label information is presented and effectively solve the problem that food labels are difficult to read.

Reminder: The content displayed on a digital label shall comply with Article 67 of the Food Safety Law of the People's Republic of China and the provisions on mandatory labeling items for prepackaged food in the national food safety standards. Other information such as advertising and marketing does not belong to digital labels, and such information shall comply with the provisions of relevant laws and regulations.

02

Requirements for the Use of Digital Labels

2.1 Displayed Content and Requirements

(1) Consistency with mandatory labeling content: The mandatory information displayed on a digital label shall be consistent with the food label information displayed at the same time on the food packaging.

(2) Truthfulness and accuracy of other content: Information that may be indicated on the label of prepackaged food — such as ingredient sources, production processes, place of origin, methods of consumption, product traceability, food safety and nutrition — may be displayed via digital labels due to the space limitations of physical labels. Food producers and operators shall be responsible for the truthfulness and accuracy of the displayed content, ensure that the relevant information is objective and scientific, and not mislead consumers. In addition, food producers may provide digital labels according to the needs of specific consumer groups, for example, providing food information by means of video and voice reading in addition to textual labeling (GB 7718-2025 9.5).

(3) Special foods must be consistent with registration and filing: When product information of health foods, foods for special medical purposes and infant formula foods is displayed via digital labels, it shall be consistent with the content of their registration or filing.

(4) No tampering; modifications must be traceable: The content indicated on a digital label shall not be tampered with; when the content of a digital label is modified or updated, the modified content, time of modification, information on the person making the modification and other elements shall be recorded to ensure that the modification process is traceable.

Reminder: Digital labels fall within the scope of food labels. Digital labels are not required to indicate all mandatory label information, but the information displayed on both the digital label and the physical label shall be consistent in content.

2.2 Form Requirements for Digital Labels

(1) Clear identification: When using a digital label, digital means conforming to national standard provisions shall be used to provide the digital label, and its identity shall be clearly indicated in the vicinity of the digital label by the words "Digital Label" or similar wording.

(2) Display on the first-level page: Digital labels shall be provided in a form that is easy to obtain, and compatibility with multiple recognition means is encouraged; the indicated content shall be displayed directly on the first-level page after reading, and shall be clear, conspicuous and easy to read, avoiding overlap and piling up, and there shall be no pop-ups, floating windows or other interfering elements that affect normal reading.

Reminder: Food production enterprises may display digital label information through self-built platforms or third-party platforms. The QR code of a digital label may be integrated with other QR codes on the packaging to achieve multiple codes in one.

03

Simplified Labeling on Physical Labels

3.1 Producer's Address

Where a food producer displays the producer's detailed address via a digital label, the production address may be simplified on the prepackaged food label to the name of the county-level administrative region and indicated after the producer's name. For example, if the production address displayed on the digital label of a prepackaged food is "No. XX, XX Avenue, XX Town, XX County, XX City, XX Province", the food label may indicate "Producer XXX (XX County)".

Where multiple production addresses are stated on one food production license (i.e., one license with multiple addresses), they may be labeled by combining physical labels and digital labels: for example, one address stated on the license that is convenient for consumers to contact may be labeled on the physical label, while other addresses stated on the license are labeled by means of a digital label, with letters or numbers on the packaging used as codes to indicate the actual production address.

3.2 Information on Wholly Owned Subsidiaries of a Group

For food jointly produced by a group and its wholly owned subsidiaries, each undertaking part of the processes, where the group company bears full responsibility for its quality and safety, the group company may be labeled on the label as the producer, while information on the subsidiaries undertaking part of the production processes may be labeled as co-producers by means of a digital label.

3.3 Other Labeling Items for Small-Package Prepackaged Food

Where the maximum surface area of the packaging or packaging container of prepackaged food is not greater than 20cm², only the food name, net content, shelf life expiry date, shelf life, storage conditions, the name and contact information of the producer and/or operator, the food production license number, and the product standard code and serial number may be indicated, while other labeling items shall be indicated on the sales container or provided in the form of an accompanying instruction manual, digital label, etc.

3.4 Other Labeling Items for Prepackaged Food Not Directly Provided to Consumers

The label of prepackaged food not directly provided to consumers shall indicate the food name, net content and specifications (except for those sold by measurement), production date, shelf life expiry date and storage conditions; other content, if not marked on the label, may be indicated via a digital label.

Reminder: Apart from the circumstances where simplification is explicitly permitted as described above, the mandatory labeling items of prepackaged food labels shall still be fully marked on the outer packaging of the smallest sales unit as required.

04

Conclusion

Digital labels provide a new carrier for presenting food label information and also leave room for enterprises to save label printing costs and improve management efficiency. Foodmate reminds food production and operation enterprises that digital labels are not a mandatory requirement, but if an enterprise chooses to use them, it must strictly comply with the relevant standards and regulatory requirements to ensure that the digital label information is lawful and compliant.

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