By Jessica Ou Yang, RQA Group Principal Consultant
As one of the largest food manufacturers in the world, China has implemented various regulations and legislations to control the quality of food products. Existing measures primarily target biological contamination caused by microorganisms (such as bacteria, viruses, and fungi) or chemical contamination resulting from food adulteration or the misuse of harmful chemicals. However, it has been found that allergen control remains a neglected area, where current regulations and oversight are insufficient to effectively manage the associated risks.
This oversight may result in prepackaged food products containing undeclared allergens, which could lead to allergic reactions in consumers who are unaware of the hidden risks. These reactions can cause mild symptoms such as eczema, nausea and diarrhoea, but may even lead to life-threatening conditions like difficulty in breathing and anaphylaxis, which can ultimately result in death. Thus, allergen control becomes a significant challenge to food manufacturers in China.
Regulatory changes in allergen labelling
Allergen labelling is not a mandatory requirement in China currently. According to the currently in-use standard (GB 7718-2011 Standard for Labelling of Prepackaged Food (食品安全国家标准预包装食品标签通则[1]), food manufacturers are encouraged to provide voluntary allergen declaration for presence of allergens as ingredients, or allergens present due to cross-contamination. In other words, there is no strict requirement for food manufacturers to provide any allergen information on the consumer facing, labelling of pre-packed food.
Recently however, the standard mentioned above has been revised (2025). The updated GB 7718-2025 is expected to be enforceable and take effect from 16 March 2027. Under this new version of the standard, manufacturers are required to provide mandatory declaration of eight specific allergens: peanuts, eggs, milk, soybeans, wheat, fish, crustaceans and tree nuts. The allergens have to be indicated by bolding and underlining in the ingredient list, or by providing a ‘clear statement’.
To comply with such enforcement of labelling regulations, different challenges are presented on manufacturers, especially small and medium-sized enterprises. These include, but are not limited to, ensuring accurate traceability of allergenic ingredients throughout the supply chain and coordinating with suppliers to prevent cross-contamination. Packaging also needs to be redesigned to meet new labelling standards.
As the implementation date of GB7718-2025 is approaching, manufacturers must begin adapting their operations and processes/packaging to meet the new requirements. They must ensure that allergen information is clearly and consistently communicated to consumers.
Challenges in precautionary labelling
While China has made efforts to improve allergen labelling regulations, inconsistencies in the standards can lead to confusion in how allergens are declared. Under GB 7718-2025, food manufacturers are encouraged (but not required) to voluntarily provide information about allergens that may be unintentionally present in food (often due to cross-contamination during production or through the raw material supply chain). This lack of mandatory precautionary labelling poses challenges for manufacturers.
Excessive and/or insufficient use of precautionary allergen labelling both pose significant challenges. Overuse of precautionary allergen can unnecessarily restrict consumer choices, leading to confusion and reduced trust in labelling. Underuse of precautionary labelling may expose individuals with food allergies to serious health risks due to presence of unrecognized allergen risks.
To address this, manufacturers are advised to conduct risk assessments before deciding whether to include precautionary labelling and to determine the most appropriate phrasing. Additionally, they can minimize cross-contamination risks through measures such as regular deep cleaning of food contact surfaces, and segregation of ingredient storage and food preparation areas.
Low awareness in the general public about food allergy
The public awareness of food allergies in China remains low, which contributes to the challenges in allergen control for food manufacturers. It is believed by the general public in China that food allergies are uncommon. This, in turn, leads to underestimation of the risks. In addition, the access to facilities for food allergy, testing such as standardised food challenges, is limited. This results in both underdiagnosis and overdiagnosis for food allergies in the general public. Furthermore, the complexity of Chinese cuisine commonly includes numerous ingredients and sauces which makes it difficult to identify specific allergens. This further complicates public understanding and adds to the confusion on the subject.
Without adequate education and awareness, consumers may not even know they have an allergic reaction to a particular food. This means many people will unknowingly consume allergen-containing products, increasing the risk of adverse reactions. Many consumers may also overlook the importance of reading food labels to check for allergen information. Enhancing public knowledge is essential to support effective allergen management and improve food safety standards. It is essential not only for consumer safety but also to support the effectiveness of new labelling regulations and responsible food manufacturing practices.
In summary, although allergen labelling in China is currently voluntary, mandatory labelling is imminent. With the upcoming enforcement of GB 7718-2025, manufacturers must proactively get prepared by improving traceability, refining labelling practices and educating consumers. Strengthening both regulatory compliance and public understanding will be key to advancing food safety and protecting allergy-sensitive individuals in China. RQA Group are able to offer support, training and consultancy services on this topic and many others upon request.
[1] GB 7718-2011 English Version, GB 7718-2011 National Food Safety Standard –Standard for nutrition labelling of prepackaged foods (English Version) – Code of China