After Food Packaging QS Mark Transition: 3 Real Oversights — 3 Hidden Risks When Printers Still Run Legacy QS on New Food Packaging Orders in 2026

In August 2026, a pastry packaging printer in Wuxi took on an order from a long-established local pastry shop — 5,000 kraft paper gift boxes. The design file the customer sent featured the "QS + 12 digits" mark. The printer's salesperson thought, "It's a regular customer, just print it," and went into production without a second thought.

When the goods were delivered to the customer's storefront, the market regulation authority spotted the QS mark during a spot inspection — QS had exited in October 2018, replaced by SC. New production packaging printed with QS was directly deemed "non-compliant packaging." The market regulation authority not only punished the pastry shop but also summoned the printer, requiring it to recall the batch and submit a corrective report.

The printer owner felt wronged — "The QS mark was in the customer's artwork; we didn't add it ourselves." But the market regulation authority's response was: the printing enterprise bears a "primary review obligation" for packaging compliance. If the customer-supplied artwork is clearly non-compliant and the printer did not provide written notice and refused to print, the printer bears joint liability.

This is not an isolated case. During spot inspections by market regulation authorities in Wuxi, Suzhou, and Changzhou from 2024 to 2025, a total of 11 cases were found where food packaging was printed with the abolished QS mark; 7 of those also led to penalties against the printing enterprises.

It has been 8 years since the QS mark transition. Why does it still appear in 2026? Because many established brands' packaging design files have been carried over from 2017 or even earlier, and their design departments did not keep up with policy changes, continuing to place QS in their files. The printer, acting as the "professional printing party," becomes the "fallback responsible party" for the customer design department's policy lapse.

Oversight #1: Customer artwork still contains "QS + 12 digits" — the printer did not catch it

The "correct format" of the QS mark is "QS + 12 Arabic digits," representing the 12-digit enterprise license number. However, since October 2018, newly established food enterprises no longer receive QS certification; instead, they use "SC + 14 digits."

When preparing plates, press operators typically look only at color, dimensions, and fonts — they rarely check whether "QS has been abolished." As a result, if customer artwork still contains QS, the printer simply prints it as-is.

Real case: A pastry brand's gift box design file had been carried over since 2016, and the QS mark in the file had never been updated. The printer produced 50,000 units per year for 7 years, until a spot inspection by the market regulation authority in 2024 finally detected it — over the 7 years, 350,000 non-compliant packages had been printed. Ultimately, recall costs were split 50/50 between the printer and the brand owner.

The printer's response path: add a "compliance check" step at the plate-making stage — after receiving the customer's artwork, the printer's design/plate-making staff spend 30 seconds scanning against the "Food Packaging Compliance Checklist": QS mark? SC digit count? Allergen labeling? Minimum character height for net content? Any non-compliance is sent straight back to the customer.

Oversight #2: The customer's SC number has the wrong digit count — the printer printed 13-digit SC per the artwork

The correct format for the SC mark is "SC + 14 digits." However, in 2026, among new food orders received by printers, about 5% of customer artwork contains SC numbers with 13 or 15 digits — either the customer's design department mistyped the 14 digits, or an old version had not been updated.

Press operators at the plate-making stage see the SC marking and assume "the customer is compliant," without counting the digits. Once printed, the market regulation authority checks and finds the SC number is wrong, and again the printer is held responsible.

Real case: In 2025, a Suzhou printer took on a packaging order for a nut brand; the SC number in the file had 13 digits. The printer printed 8,000 units per the artwork. A spot inspection by the market regulation authority uncovered the SC digit error, and the printer was summoned and fined RMB 15,000.

The printer's response path: add an "SC digit-count self-check" at plate-making — when a printer's plate-making staff receives food packaging artwork, they directly circle the SC number on the file and count the digits. If it isn't 14, send it back to the customer.

Oversight #3: Legacy stock packaging mixed into new orders — the printer did not distinguish "stock" from "newly printed"

In 2026, many food brands still have packaging produced between 2020 and 2023 in their warehouses, and these packages feature the QS mark (pre-October 2018 packaging is still usable). If customers commingle legacy stock with new orders and send them to the printer for supplementary printing, the printer can easily make mistakes if it does not distinguish them.

Real case: In 2025, a Changzhou printer received a "supplementary order" from a snack brand — the customer said, "we still have 2,000 from the previous run; print another 3,000 this time." The printer printed 3,000 units per the customer artwork, but the "production date format" corresponding to the SC number in the file was inconsistent with the stock QS packaging. When the market regulation authority inspected, they found mixed batches and deemed it "混乱的包装日期标识" (confused packaging date marking), penalizing the printer RMB 20,000.

The printer's response path: before printing each batch of food packaging, the printer's sales/planning department asks the customer, "Is this a new order or a supplementary order? Is any stock being mixed in?" and writes the answer on the production order. When shipping from the warehouse, separately mark "stock packaging" and "newly printed packaging" so the two don't get mixed into the same customer order.

Printer "Food Packaging Compliance Self-Check Checklist" (ready to copy)

After receiving a food packaging design file, the printer's sales/plate-making staff scan these 5 items within 30 seconds:

1. QS mark: Does the file still contain "QS + 12 digits"? If yes, send back to the customer to change to SC.
2. SC digit count: Are there 14 digits after "SC" in the file? If not 14 digits, send back to the customer.
3. Allergen labeling: Does the file include allergen information (e.g., "contains gluten")? If not, send back to the customer to add it.
4. Net content character height: Is the net content numerical font ≥ 1.8mm? If not, send back to the customer.
5. Production date / shelf-life format: Has a production date inkjet location been reserved in the file? If not, remind the customer to add it.

If any one of these 5 items is non-compliant, the printer must notify the customer in writing and retain evidence (WeChat screenshot / email), rather than silently making corrections and continuing to print.

How the printer should respond after being summoned

If the printer has already been summoned by the market regulation authority (similar to the pastry shop case), the printer needs to do 3 things:

Item 1: Immediately recall the shipped packaging, and negotiate the recall cost with the customer (non-compliant customer artwork = customer primarily responsible)

Item 2: Submit a corrective report, including "compliance self-checklist has been established + compliance review has been performed on all customer artwork"

Item 3: Send a "Compliance Notification Letter" to the customer, requiring the customer to confirm subsequent design files are compliant; retain proof

If the printer handles these 3 items, it can generally avoid penalties over RMB 50,000.

The real state of affairs 8 years after the QS mark transition

When QS exited in October 2018, the industry estimated that "old stock would be worked off in 1–2 years." The actual situation in 2026 is — legacy brands have not updated their design files and QS marks are still being carried over; new brands' SC number formats are inconsistent, with occasional digit-count errors; regulatory inspections are getting stricter, and starting in 2025, "joint printer liability" was written into the spot-inspection workflow.

Printer owners must realize: food packaging compliance is no longer "the customer's business" — it is "the printer's and customer's shared business." A 30-second self-check at the plate-making stage can help printers avoid the vast majority of risks.

Further reading

• Food Packaging 6 Mandatory Labeling Categories: Ingredient List / Allergens / Shelf Life / Nutrition Facts / Net Content / Origin
• Food Packaging GB 4806.10 Coatings: 3 Real Compliance Cases
• Food Contact Packaging GB 4806 Testing Items in Practice