Six Mandatory Food Packaging Labels: Ingredients List / Allergens / Shelf Life / Nutrition Facts / Net Content / Place of Origin — The 3 Most Common Pitfalls for Printing Plants

In June 2025, a printing factory in Guangdong that produces nut packaging was fined 38,000 yuan by the market supervision administration. The reason was that the “allergen information” on the packaging for a certain batch of products was printed after the barcode, with a character height of 1.5mm, failing to meet the national standard requirement of ≥1.8mm. The market supervision administration, under Article 125 of the Food Safety Law, determined that the label did not comply with GB 7718 and imposed a fine of 38,000 yuan.

The printing plant owner came to me and said: "The type size requirement for allergen information is stipulated in the national standard, and that's exactly how it is printed in the client's file. I printed it according to the file; why should I be fined?"

I said: "The documents provided by the client are incorrect, and you have not fulfilled your pre-press review obligations. Prepackaged food labels are a compliance checklist, and the printing plant is the second checkpoint in the compliance chain (the first is the brand owner). The fact that the client gave you incorrect information does not absolve you of responsibility."

Mandatory food labeling falls into 6 categories, each with specific national standard requirements. Rather than blindly printing according to the customer’s files, the printing plant should keep a copy of GB 7718 General Standard for the Labelling of Prepackaged Foods on the prepress proof-reading desk.

1. Six categories of mandatory food packaging labels—printing any one incorrectly may result in a fine of RMB 10,000-50,000

GB 7718-2011 "National Food Safety Standard, General Standard for the Labelling of Prepackaged Foods" is the "parent standard" for prepackaged food labels. The compliance requirements for all 6 types of mandatory markings derive from this standard and its supporting regulations.

Category 1: List of Ingredients. Ingredients are listed in descending order of quantity added, with three labeling methods: “specific name,” “category name,” and “compound ingredients.” Detailed rules apply according to the type of food. The ingredient list is one of the labels most frequently consulted by consumers and is also a key focus of market supervision authorities during spot checks.

Category 2: Allergen information. Products containing any of the 8 common allergens (cereals containing gluten, crustaceans, fish, eggs, peanuts, soybeans, milk, and tree nuts) or their derivatives must be clearly labeled after or adjacent to the ingredient list. Printing errors, omissions, or type that fails to meet the required height will result in penalties.

Category 3: Shelf Life / Production Date / Storage Conditions. These 3 labels are often marked together, but each has a national-standard format: a shelf life of either "6 months" or "180 days" is acceptable, but it must correspond to the production date; storage conditions such as "room temperature," "refrigerated," or "protect from light" must also be clearly stated.

Category 4: Nutrition Facts. 4 mandatory items (energy, protein, fat, and carbohydrates) + 1 item, "sodium" (mandatory after 2013). The values per 100g / 100ml or per serving must be clearly stated, with specific rules governing the labeling method.

Category 5: Net content. It shall be marked in “grams (g)”, “milliliters (mL)”, “kilograms (kg)”, or “liters (L)”. The minimum font size for the numerical value is determined according to the total surface area of the package (see GB 7718-2011, Clause 3.7).

Category 6: Place of Origin / Production Enterprise Information. “Place of origin” generally refers to the actual place where the food is produced or processed; the name, address, and contact information of the “production enterprise” must be authentic and verifiable. These 2 items are also frequently inspected by the market supervision administration.

2. The 3 Most Common Pitfalls Printers Fall Into—Letter Height / Font / Order

Among the 6 mandatory markings, the most common pitfalls for printing plants are character height, font, and order.

Pitfall 1: Text height below the required standard. GB 7718-2011, Clause 3.9, stipulates that when the maximum surface area of a prepackaged food package or container exceeds 35cm², the height of mandatory information—including text, symbols, and numbers—must not be less than 1.8mm. When the maximum surface area is less than 10cm², only the product name, production date, and shelf life may be marked, while other information may be exempted. However, the maximum surface area of most food packages exceeds 35cm², making 1.8mm the minimum requirement.

A common pitfall in printing plants is that the type height in the design file is 1.8mm, but after font substitution or font-size scaling during printing, it becomes 1.5mm. Another situation is when the font itself has an “x-height” (the height of the lowercase letter x) of only 1.2mm, while the “type height” includes ascenders/descenders, making it appear to be 1.8mm even though the lowercase portion is only 1.2mm—these details must be checked using font software before printing, rather than assessed by eye.

Pitfall 2: Font color / insufficient contrast. Clause 3.10 of GB 7718-2011 stipulates that mandatory information shall be clear, prominent, and durable, enabling consumers to easily recognize and read it when making a purchase. Specifically, although the national standard does not provide a quantified value for color contrast, the market supervision authority’s inspection standard requires “contrast between text and background ≥ 4.5:1” (equivalent to the WCAG AA standard).

A common pitfall for printing plants is that brands use light gray text on a light-colored background in pursuit of a “designer look,” resulting in an actual contrast ratio of only 3:1. Upon identifying this issue in a design file, printing plants should proactively remind the client to revise it, rather than simply printing whatever the client provides.

Trap 3: Incorrect ordering of the ingredient list. GB 7718-2011, Clause 4.1.3.1 states: Ingredients shall be listed one by one in descending order of the amount added during the manufacture or processing of the food; ingredients added in an amount not exceeding 2% may be listed without descending order. This means that when the printer prints the ingredient list, the order cannot be arranged arbitrarily according to the brand owner’s “design draft”; it must follow the actual food formula, from the highest amount to the lowest.

A common mistake printers make is that the sequence of the ingredient list in the design draft provided by the brand owner is incorrect (possibly because the brand owner’s marketing and R&D departments are not aligned). The printer prints it as given, and the market supervision authority later finds that the formula does not match the label, potentially resulting in penalties for both the brand owner and the printer.

3. Three checkpoints for pre-press file review—three key matters the printing plant should monitor

To avoid regulatory compliance risks related to labeling, the printing plant should focus not on "printing exactly as the customer's files specify," but on establishing three checkpoints for pre-print file review.

First step: Mandatory label completeness check. After receiving the customer’s files, first verify that all 6 categories of mandatory labels are complete. If any item is missing, immediately request that the customer supplement it. This is the most basic compliance threshold, yet many printing plants skip this step and proceed directly to printing.

Stage 2: Type Size / Font / Contrast Technical Check. Use a PDF reader or Illustrator’s “Font Info” function to verify that all mandatory markings have a type size of ≥1.8mm, that the font is not “Light / Extra Light / Decorative,” and that the color contrast, measured with an eyedropper, is ≥4.5:1. The print shop must perform these 3 technical checks itself because customers’ designers are often unfamiliar with national standards.

Stage 3: Verification of the Ingredient List, Allergens, and Nutritional Values. At this stage, the customer must provide the food formulation and nutritional analysis report, and the printer must verify whether the ingredient list is in the same order as the formulation, whether any allergens have been omitted, and whether the nutritional values match the analysis report. This stage involves the most technical work and requires customer cooperation, but if these checks are not performed, the likelihood of problems is the highest.

Practical recommendation: During the printer’s prepress file review stage, establish a “Label Compliance Checklist” covering the core provisions of GB 7718-2011. Before each order enters production, a designated reviewer should verify the checklist and sign off before printing may begin. This step has minimal cost (adding 30 minutes of review time per order) and can prevent more than 80% of label compliance risks.

4. Is the printing plant exempt from liability when the customer supplies an erroneous draft?

This is a major concern for many printing factory owners: if the customer's design file itself has compliance issues and the printing factory produces the packaging according to the file, will the market supervision authority impose a penalty on the brand owner or the printing factory?

The answer is: in most cases, both parties will be fined.

The legal basis is Article 125 of the Food Safety Law: where the labels or instructions for food or food additives produced or operated by an entity have defects that do not affect food safety and will not mislead consumers, the food safety supervision and administration department of the people's government at or above the county level shall order rectification; if the entity refuses to rectify, a fine of not less than five thousand yuan and not more than fifty thousand yuan shall be imposed. In serious circumstances, production and operations shall be ordered to cease, and the license may be revoked.

As the “producer of the labels” (even though the content is provided by the brand owner), the printing company assumes “producer responsibility”—if it prints non-compliant labels, it must bear the corresponding legal liability. Unless the printing company can prove that it has fulfilled its pre-printing review obligations by proactively identifying the issues and requesting in writing that the customer make corrections (in any verifiable form, such as an email, WeChat screenshot, or signed paper document), it may only be possible to mitigate or exempt its liability.

Real case: In 2024, a printing plant in Zhejiang discovered before printing that a customer's ingredient list was in the wrong order. It submitted a written request for correction, with email records retained. The customer replied, "Print according to the original file; I will bear the compliance responsibility." After retaining the records, the printing plant proceeded as requested. A subsequent market supervision inspection found that only the brand owner was penalized, while the printing plant was not, because it had complete records showing "proactive notification + customer insistence."

Practical recommendations: When a printing plant identifies noncompliance in a customer's file, it must take 3 steps: First, notify the customer in writing of the specific issues (email / WeChat); Second, if the customer replies "Do not modify; print according to the original file," retain the record for archiving; Third, note on the production order / process sheet that "The customer has confirmed printing according to the original file, and the customer assumes responsibility for compliance." By completing these 3 steps, the printing plant can generally be released from liability.

5. Differences in Labeling Requirements for Imported and Cross-Border E-commerce Foods

In addition to domestic food products, printing companies may also receive orders to print Chinese labels for imported food products. Such orders differ from those for domestic food products in 3 key compliance requirements.

Difference 1: Chinese labels are a “statutory marking”. Imported food entering the Chinese market for sale must have a Chinese label. Chinese-label compliance requirements are implemented according to GB 7718-2011, the same as for domestically produced food. However, Chinese labels for imported food are prepared by the “domestic importer / distributor.” The printing factory works with the importer, not the overseas brand owner.

Difference 2: “Country of origin” must be indicated. The Chinese label of imported foods must state the “Country of origin,” while this is not required for domestically produced foods. The labeling method for the country of origin follows the regulations of the General Administration of Customs, with common formats such as “Country of origin: Japan” and “Place of origin: Italy.”

Difference 3: Nutritional information exemptions. Nutritional information tables are mandatory for domestically produced foods, but certain imported foods (such as certain imported alcoholic beverages and condiments) may be exempted from nutritional information labeling under General Administration of Customs regulations. When a printing plant receives an order for imported food products, it must first confirm the General Administration of Customs' exemption list for nutritional information labeling for that food category, so that mandatory labeling does not result in the products being deemed “non-compliant.”

Practical recommendation: Upon receiving an imported food order, the printing plant should first ask the customer whether the food is included in the exemption list for nutrition facts labeling, whether the country of origin has been confirmed, and whether the importer/distributor qualifications are complete. If any of these 3 items is incomplete, the printing plant should not proceed with printing without due caution.

6. Three Standard Operating Procedures for Food Packaging Printing Plants

Finally, here are 3 practical actions that food packaging printing companies must take to avoid labeling compliance risks.

Action 1: Make GB 7718-2011 a prerequisite for prepress file review. The prepress file review desk at the printing plant must have a paper copy of GB 7718-2011 (or a full-text searchable PDF). Before each food packaging order goes to press, the reviewer shall check each item against the core provisions of GB 7718 (Clauses 3.1–3.10 and 4.1–4.5) and record the results on the “Labeling Compliance Checklist.”

Action 2: Proactively provide customers with a "Label Compliance Recommendations". A printing plant should not passively wait for the customer to supply documents; instead, it should proactively provide the customer with a "Food Packaging Label Compliance Recommendations" document, listing common error cases (insufficient character height / incorrect ingredient list order / omitted allergens / excessively fine fonts, etc.), so that customers can avoid these pitfalls before finalizing their designs. This action can reduce prepress rework by more than 50%.

Action 3: Establish a “Customer Compliance Undertaking” system. For each food packaging customer, sign a Customer Compliance Undertaking stating that “the customer guarantees that the food label design files it provides comply with applicable national laws and regulations, and that if the printing plant is penalized by a regulatory authority after printing according to the customer’s files solely because of compliance issues inherent in those files, the customer shall bear the compliance liability.” This undertaking does not exempt the printing plant from its pre-printing review obligations, but it can serve as evidence for the printing plant’s protection in the event of a dispute.

If your printing plant is evaluating a food packaging order, send us the product category (pastries / beverages / condiments / imported foods, etc.), packaging type (paper boxes / plastic / metal cans / glass bottles, etc.), sales region (domestic / export / cross-border e-commerce), and order quantity. We can help you determine the labeling compliance risk level and the additional prepress review actions required within 30 minutes.

Further Reading

A Clear Guide to GB 4806.1 Through 4806.11: How to Use the Five Core Standards for Food Contact Packaging

Practical Guide to GB 4806 Testing Items for Food Contact Packaging: 5 Commonly Challenging Test Items + 3 Remedial Approaches for Non-Conformance

Packaging for Export to the United States: 3 Key Requirements—FDA, Prop 65, and CPSIA. What Does Each Regulate, and How Can You Pass All Three?

3 mandatory requirements of the ISO 22000 food safety management system for packaging factories