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    3. Compositional Aspects
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    3. Compositional Aspects

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    Beers, RTDs, Whisky
    China


    This section provides the compositional requirements for the food category and/or food products in scope and information on permitted nutrients, ingredients, and additives.

    3.1 Composition Requirements

    General Foods

    According to the “Food Safety Law of P.R.C” [1], the following substances are prohibited to be used in food:

    1. Non-food raw materials or added chemicals other than food additives and other substances that may harm human health.
    2.  Pathogenic microorganisms, pesticide residues, veterinary drug residues, biological toxins, heavy metals and other polluting substances, and other substances harmful to human health exceed the food safety standard limits of substances.
    3. Substances that are past their expiration date.
    4. Excessive use of food additives.
    5. Substances with spoilage, fat rancidity, mildew and worms, filth and impurity, mixed with foreign bodies, adulteration, or abnormal sensory properties.
    6. Meat and products of poultry, livestock, wild animals, and aquatic animals that have died of disease, poisoning, or unknown causes.
    7. Substances contaminated by packaging materials, containers, means of transport, etc.
    8. Other substances that do not comply with laws, regulations, or food safety standards.

    Therefore, the permitted food ingredients in General Foods are:

    1. General food raw material.
    2. Food additives in GB 2760, food fortifiers in GB 14880.
    3. Novel food raw materials specifically permitted to be used in General Food (published by official announcements).
    4. New food additives permitted to be used in General Food (published by official announcements).
    5. The catalog of substances that are traditionally both food and traditional Chinese medicinal materials.
    6. Substances traditionally eaten or with a history of consumption as General Food.
    7. Substances with a history of consumption in China. 
    8. Raw material described in product standards for specific food.
    9. Chinese Food Composition Table

    Category

    Alcoholic drinks

    Raw material requirements for alcoholic drinks shall comply with the corresponding standards and relevant regulations.

    Product

    Beer

    According to GB/T 4927-2008 Beer [2] and GB/T 17204-2021 Terminology and classification of beverages and alcoholic beverages [3], the general composition of beer is Malt, water, hops (including hop products), yeast, carbon dioxide, fruit, and vegetable juice, and any necessary food raw material, processing aids, etc. which the food safety standards prohibit and permit to use as described for "General Foods" above.

    • Raw materials shall comply with corresponding regulations and standards: please refer to Section 3.2 below.
    • Food nutrition fortifiers limit: refer to Section 3.4 below.
    • Food additives limit: refer to Section 3.5 below.
    • Flavor restrictions: refer to Section 3.6 below.
    • Food processing aids usage condition: refer to Section 3.7.
    • Food Enzyme Preparations usage condition: refer to Section 3.8.
    • The Brewing malt shall comply with the Quality requirements of brewing material— Part 2: Brewing malt (Draft for Approval) [8] (Please note that only the final officially released version shall be considered for implementation)
    • Alcohol content:

    Parameters

    Limit

    Alcohol content/(%vol)         ≥

    ≥ 14.1 °P

    5.2 %vol

    12.1 °P~14.0 °P

    4.5 %vol

    11.1 °P~12.0 °P

    4.1 %vol

    10.1 °P~11.0 °P

    3.7 %vol

    8.1 °P~10.0 °P

    3.3 %vol

    ≤ 8.0 °P

    2.5 %vol

    Remark: Low-alcohol beer (alcohol content: 0.5~2.5 %vol) and no-alcohol beer (alcohol content: ≤0.5 %vol) are not included.

    • Tolerance limit for alcohol content: N/A
    • Order of specific gravity (where applicable): N/A
    • Methanol ≤ 2.0 mg/L
    • Original wort concentration: X °P ("X" is the original wort concentration marked on the label. When X°P >10.0°P, the allowable negative deviation is "-0.3". When X°P <10.0°P, a negative deviation of “-0.2” is allowed.)
    • Dietary fiber content: N/A 
    • Carbon dioxide /%(mass fraction): 0.35~0.65%. Barrel (fresh, raw, cooked) beer shall not have less than 0.25% carbon dioxide (mass fraction).

    Ready-to-drink beverages (such as Chuhai)

    The composition requirement will be described for Chuhai products as an example.

    Chuhai is not legally defined in Chinese legislation. In light of the general definition in GB/T 17204-2021 Terminology and classification of beverages and alcoholic beverages [3] and in GB 2757-2012 National Standard for Food Safety Distilled liquor and its integrated liquor [5], the general composition of Chuhai would be: Shochu (Liquor), water, general food raw material, food additives, and any necessary food raw material, processing aids, etc. which the food safety standards prohibit and permit to use as described in the "General Foods" section above. 

    • Raw materials shall comply with corresponding regulations and standards: please refer to Section 3.2 below.
    • Food nutrition fortifiers limit: refer to Section 3.4 below.
    • Food additives limit: refer to Section 3.5 below.
    • Flavor restrictions: refer to Section 3.6 below.
    • Food processing aids usage condition: refer to Section 3.7.
    • Food Enzyme Preparations usage condition: refer to Section 3.8.
    • Alcohol content: ≥0.5% vol
    • Tolerance limit for alcohol content: N/A
    • Order of specific gravity (where applicable): N/A
    • Methanol ≤ 0.6 g/L (Convert to 100% alcohol)
    • Cyanide (in HCN) ≤ 8.0 mg/L (Convert to 100% alcohol)

    Whisky

    According to GB 2757-2012 National Standard for Food Safety Distilled liquor and its integrated liquor [4] and GB/T 11857-2008 Whisky (partially valid) [5], the composition is Malt, various grains (e.g., rye, wheat, corn, green, oats), and any necessary food raw material, processing aids, etc. which the food safety standards prohibit and permit to use as described in the "General Foods" section above.  

    • Raw materials shall comply with corresponding regulations and standards: please refer to Section 3.2 below.
    • Food nutrition fortifiers limit: refer to Section 3.4 below.
    • Food additives limit: refer to Section 3.5 below.
    • Flavor restrictions: refer to Section 3.6 below.
    • Food processing aids usage condition: refer to Section 3.7.
    • Food Enzyme Preparations usage condition: refer to Section 3.8.
    • Alcohol content: ≥ 40% vol
    • Tolerance limit for alcohol content: the allowable difference between the measured alcohol value and the label value is 1.0% vol
    • Order of specific gravity (where applicable): N/A
    • Methanol ≤ 0.6 g/L (Convert to 100% alcohol)
    • Cyanide (in HCN) ≤ 8.0 mg/L (Convert to 100% alcohol)
    • According to the Quality requirements for spirits - Part 1: Whisky (draft for approval) [9] (please note that only the final officially released version shall be considered for implementation):
      1. Raw materials such as grains and water should comply with corresponding standards and requirements.
      2. The maximum alcohol content of new whisky should be less than 95% vol.
      3. Single malt whisky should not use exogenous enzymes during production 
      4. The volume of the wooden barrels used for aging whisky should not exceed 700 L.
      5. Edible alcohol, coloring substances (except caramel color), and flavoring substances (except for flavored whisky) should not be used in the production of whisky.

    3.2 Raw Material Requirements

    General Foods

    According to the relevant standards, the raw material requirements of General Foods shall comply with the corresponding standards and relevant regulations. The raw material reference product standards depend on the product formulation. 

    Category

    Alcoholic drinks

    Same as "General Foods".

    Product

    Beer

    The raw material requirements for beer shall comply with the corresponding standards and relevant regulations. The raw material reference product standards depend on which food raw materials are used in the product formulation. Below is a non-exhaustive list of the main commonly used raw material reference product standards:

    The PDFs of the standards are attached at the end of this document below.

    Ready-to-drink beverages (such as Chuhai)

    The raw material requirements for alcoholic drinks comply with the corresponding standards and relevant regulations. The raw material reference product standards depend on which food raw materials are used in the product formulation. Below is a non-exhaustive list of the main commonly used raw material reference product standards:

    The PDFs of the standards are attached at the end of this document below. 

    Whisky

    The raw material requirements for whisky shall comply with the corresponding standards and relevant regulations. The raw material reference product standards depend on which food raw materials are used in the product formulation. Below is a non-exhaustive list of the main commonly used raw material reference product standards:

    The PDFs of the standards are attached at the end of Section 3 below.

    3.3 Fortification

    General Food

    The nutrition fortification used in General Foods shall comply with GB 14880-2012 National Food Safety Standard - Standard for the use of nutritional fortification substances in foods [8]. Furthermore, the nutritional fortification substances shall comply with the relevant raw material standards or technical requirements specific to corresponding product standards or food raw materials (published by official announcements).

    Category

    Alcoholic drinks

    According to GB 14880-2012 National Food Safety Standard - Standard for the use of nutritional fortification substances in foods [6], it is not permitted to use nutritional fortification substances in the alcoholic drinks category. 

    Product

    Beer

    Same as "Category" above.

    Ready-to-drink beverages (such as Chuhai)

    Same as "Category" above.

    Whisky

    Same as "Category" above. 

    3.4 Other Permitted Ingredients

    General Food

    N/A.

    Category

    Alcoholic drinks

    N/A.

    Product

    Beer

    N/A.

    Ready-to-drink beverages (such as Chuhai)

    N/A.

    Whisky

    N/A.

    3.5 Permitted Additives

    General Foods

    Food additive usage must comply with GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7]. 

    Category

    Alcoholic drinks

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted additives used under alcoholic drinks are outlined in Attachment 1 - Food Additives - Alcoholic beverages.

    Product

    Beer

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted additives used under alcoholic drinks are outlined in Attachment 4 - Food Additive - Beer and malt beverage. 

    Ready-to-drink beverages (such as Chuhai)

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted additives used under alcoholic drinks are outlined in Attachment 2 - Other fermented alcoholic beverage (carbonated) and Attachment 3 - Food Additives - Distilled spirit.

    Whisky

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted additives used under alcoholic drinks are outlined in Attachment 5 - Food Additives - Whisky.

    3.6 Permitted Flavors and Colors 

    General Foods

    The permitted flavors and colors shall comply with GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7].

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the basic principle of flavor usage is:

    1. The purpose of using food flavors and flavorings in food is to produce, alter, or enhance the flavor of food. Food flavors are generally formulated into food flavorings for use in flavoring food, although some can also be used directly for this purpose. Food flavors and flavorings do not include substances that only produce sweetness, sourness, or saltiness, nor do they include flavor enhancers.
    2. Food flavors and flavorings should be used in various types of food in appropriate amounts as needed for production. Foods that can be flavored should comply with the relevant food product standards.
    3. The types of food flavors used to formulate food flavorings should comply with the provisions of this standard. Natural flavor complexes with aromatic characteristics obtained from food (which may be unprocessed or processed through traditional food preparation processes suitable for human consumption) using physical methods, enzymatic methods, or microbial methods (the enzymes used should comply with the relevant provisions of this standard) may be used to formulate food flavorings. (Note: Natural flavor complexes are preparations containing edible aromatic substances.)
    4. Food flavors that have functions of other food additives or other food uses should be formulated into food flavorings for flavoring food. When they perform functions of other food additives in food, they should comply with the relevant provisions of this standard. When they are used for other purposes, they should comply with the provisions of the corresponding standards. For example: benzoic acid, cinnamaldehyde, guarana extract, sodium diacetate (also known as sodium acetate), sodium succinate, tricalcium phosphate, amino acids, etc.
    5. Food flavorings may contain food flavoring auxiliaries (including food additives and food) that are necessary for their production, storage, and application. Food flavoring auxiliaries should meet the following requirements:
      1. The auxiliaries allowed in food flavorings should comply with the provisions of the "National Food Safety Standard for Food Flavorings" (GB30616). The types of auxiliaries used should be minimized as far as possible while achieving the intended purpose.
      2. Food additives added as auxiliaries to food flavorings should not function in the final food. Their use in food should be minimized as far as possible while achieving the intended purpose.
    6. The labeling of food flavors and food flavorings should comply with the provisions of the "National Food Safety Standard for General Rules on Labeling of Food Additives" (GB29924).
    7. Prepackaged foods to which food flavors or flavorings have been added should be labeled in accordance with the "National Food Safety Standard for General Rules on Labeling of Prepackaged Foods" (GB7718).
    8. The quality specifications of food flavors should comply with the provisions of the "National Food Safety Standard for General Rules on Food Flavors" (GB29938) and the relevant flavor product standards.

    Category

    Alcoholic drinks

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted flavors used under alcoholic drinks can be found in Attachment 6 - Permitted Food Natural Flavors and Attachment 7- Permitted Food Synthetic Flavors.

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted colors used under alcoholic drinks can be found in Attachment 1 - Food Additives - Alcoholic beverages.

    Product

    Beer

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted flavors used under alcoholic drinks are listed under Attachment 6 - Permitted Food Natural Flavors and Attachment 7- Permitted Food Synthetic Flavors.

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted colors used under beer are listed in Attachment 4 - Food Additive - Other fermented liquor.

    Ready-to-drink beverages (such as Chuhai)

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted flavors used under alcoholic drinks are listed in Attachment 6 - Permitted Food Natural Flavors and Attachment 7- Permitted Food Synthetic Flavors.

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted colors used under ready-to-drink beverages (mainly Chuhai) are listed in Attachment 2- Other fermented alcoholic beverage (carbonated) and Attachment 3 - Food Additives-Distilled spirit.  

    Whisky

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted flavors used under alcoholic drinks are listed in Attachment 6 - Permitted Food Natural Flavors and Attachment 7- Permitted Food Synthetic Flavors.

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted flavors and colors used under whisky are listed in Attachment 5 - Food Additives - Whisky.  

    According to the Quality requirements for spirits - Part 1: Whisky (draft for approval) [9] (please note that only the final officially released version shall be considered for implementation), edible alcohol, coloring substances (except caramel color), and flavoring substances (except for flavored whisky) should not be used in the production of whisky.

    3.7 Permitted Processing Aids 

    General Foods

    The permitted processing aids shall comply with GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7].

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the basic principle of processing aids usage is:

    1. Processing aids should be used in the process of food manufacture and processing and should have technological necessity for being used, the quantity of the substance used should be limited to the lowest possible level necessary to accomplish its desired effect.
    2. Processing aids should be removed generally before final products are manufactured. Where they cannot be removed completely, residues of the substance remaining in food should be reduced as far as possible, should not pose any health hazards, and should not function in final foods.
    3. Processing aids should meet the relevant requirements for quality specification.

    Category

    Alcoholic drinks

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted processing aids used under alcoholic drinks are highlighted in Attachment 8 - Permitted Food Processing Aids.

    Product

    Beer

    Same as "Category" above.

    Ready-to-drink beverages (such as Chuhai)

    Same as "Category" above.

    Whisky

    Same as "Category" above.

    3.8 Additional Notes 

    General Foods

    The permitted food enzyme preparations shall comply with GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7].

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the basic principle of food enzyme preparations usage is the same as processing aids. Please refer to Section 3.7 above.

    Category

    Alcoholic drinks

    According to GB 2760-2024 National Food Safety Standard - Standard for uses of food additives [7], the permitted food enzyme preparations can be found in Attachment 9 - Permitted Food Enzyme Preparations.

    Product

    Beer

    Same as "Category" above. 

    Ready-to-drink beverages (such as Chuhai)

    Same as "Category" above.

    Whisky

    Same as "Category" above.

    3.9 References

    1. Food Safety Law of the People’s Republic of China

    https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2023/art_6bff4ef87291497fa72949e1fc88efb5.html

    2. GB/T 4927-2008 Beer

    https://openstd.samr.gov.cn/bzgk/gb/newGbInfo?hcno=DAF322E2D52C4F98F50E35B1283ED5C3&refer=outter

    PDF attached below

    3. GB/T 17204-2021 Terminology and classification of beverages and alcoholic beverages

    https://openstd.samr.gov.cn/bzgk/gb/newGbInfo?hcno=B8F9CD37320835EEF17458CBA5962881&refer=outter

    PDF attached below

    4. GB 2757-2012 National Standard for Food safety Distilled liquor and its integrated liquor

    https://sppt.cfsa.net.cn:8086/db?type=2&guid=2F5BA85F-715C-41D5-B095-C09F1695363F

    PDF attached below

    5. GB/T 11857-2008 Whisky (partially valid)

    https://openstd.samr.gov.cn/bzgk/gb/newGbInfo?hcno=F0E725C544A9684681C90CFD01CDE76F&refer=outter

    PDF attached below

    6. GB 14880-2012 National Food Safety Standard - Standard for the use of nutritional fortification substances in foods

    https://sppt.cfsa.net.cn:8086/db?type=2&guid=002D3B53-DE13-42C1-B099-C57EC501138A

    PDF attached below

    7. GB 2760-2024 National Food Safety Standard - Standard for uses of food additives

    https://sppt.cfsa.net.cn:8086/db?type=2&guid=6CA1489A-9570-4906-8CE8-CC86FBFB1941

    8. Quality requirements of brewing material— Part 2: Brewing malt (draft for approval) 

    https://www.sac.gov.cn/xw/zqyj/art/2024/art_635aba06f5764dd9b9c3bf095be251e8.html

    9. Quality requirements for spirits - Part 1: Whisky (draft for approval)

    https://www.sac.gov.cn/xw/zqyj/art/2024/art_0af16fbd48a342e980d419b1cb54788f.html


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