5. Claim Requirements

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General Foods
China

This section provides information on the definition of different types of claims and any restrictions or allowance of claims as well as claim registration processes.

5.1 Overview of Claims

According to “Food Safety Law of the People’s Republic of China” [1], general food labels/instructions shall not contain false content and shall not mention or imply that the product has an effect on disease prevention and treatment.

According to GB 7718-2011 National Food Safety Standard - Labeling of Prepackaged Foods [2], general food should not be marked or imply that it has the effect of preventing or treating diseases, and non-health food should not express or imply that it affects health.

According to GB 28050 -2011 National Food Safety Standard - Standard for Nutrition Labeling of Prepackaged Foods [3], general food can only make nutrition claim, nutrition content claim, nutrition comparative claim, and nutrition function claim if they meet the specific conditions laid down in GB 28050 -2011 National food safety standard - Standard for Nutrition Labeling of Prepackaged Foods [3].

5.1.1 Types & Definitions

According to GB 28050 -2011 National Food Safety Standard - Standard for Nutrition Labeling of Prepackaged Foods [3], the definitions of nutrition claim, nutrition content claim, nutrition comparative claim, and nutrition function claim are:

Nutrition claim

Nutrition claim refers to a description and declaration of the nutritional properties of a food, such as the declaration of energy value and content claim of protein. Nutrition claim includes content claim and comparative claims.

Nutrition Content claim

Content claim means a claim that describes the energy or the nutrient content level in a food. The wording for nutrient content claim includes "contains", "high", "low" or "no", etc.

Nutrition Comparative claim

Comparative claim means a claim that compares the energy value or the content level of a nutrient in a food with other foods of the same type known by consumers. The wording includes "add", "reduce", etc.

Nutrient function claim

A claim that describes the role of a nutrient component in normal growth, development, and normal physiological function of the body.

5.1.2 List of Prohibited Claims

The functional claims authorized for health foods are prohibited for use for general food.

Below are the 24 functional claims of health food according to the “List of Allowable Health Food Claims for Health Functions Non-Nutrient Supplements (2023 edition)” (please refer to Attachment 12 - List of Allowable Health Food Claims for Health Functions [4]):

List of Allowable Health Food Claims for Health Functions Non-Nutrient Supplements
Help enhance the immune system	Alleviating physical fatigue	Help improve chloasma	Help maintain a healthy level of blood lipids (cholesterol/ triglycerides) level
Contribute to antioxidant	Anti-hypoxia	Help improve skin moisture condition	Help maintain healthy blood sugar level
Help improve memory	Help regulate body fat	Help regulate gastrointestinal flora	Help maintain a healthy level of blood pressure
Alleviating visual fatigue	Help increase bone density	Help Digestion	Auxiliary protection function against chemical liver injury
Clearing and nourishing throat	Improve nutritional anemia	Help defecation	Auxiliary protection function against ionizing radiation hazards
Help improve sleep	Help improve acne	Help protect gastric mucosa	Contribute to lead discharge

5.2 Nutritional Claims

According to GB 28050 -2011 National Food Safety Standard - Standard for Nutrition Labelling of Prepackaged Foods [3], nutritional claims include nutrition claims, nutrition content claims, and nutrition comparative claims.

5.2.1 Permitted Claims

According to GB 28050 - 2011 National Food Safety Standard - Standard for Nutrition Labeling of Prepackaged Foods [3], the regulatory requirements on nutrition claims, nutrition content claims, and nutrition comparative claims are listed in the following tables:

Table 5-1: Nutrition Content Claim

Item	Claim	Conditions of use
Energy	No, Zero, Free, Without, etc., Or any other word or words of similar meaning or symbol denoting a similar meaning	≤17 kJ/100g solid ≤17 kJ/100ml liquid Restriction: Energy from fat ≤50% of total energy
	Low, Little, Low source, Contain a small amount, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤170 kJ/100g solid ≤80 kJ/100ml liquid Restriction: Energy from fat ≤50% of total energy
	Energy Reduced	Compared with the reference food, energy value is reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Protein	Low, Little, Low source, Contain a small amount, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	Energy from protein ≤ 5% of total energy Restriction: Total energy refers to per 100g/ml or per serving
	Origin, Source, Include, Contain, Provide, Has, etc., or any other word or words of similar meaning or symbol denoting a similar meaning	Content /100 g≥10% NRV Content /100 ml ≥5% NRV Content /420 kJ ≥5% NRV
	High, Rich, Good Source, etc., or any other word or words of similar meaning or symbol denoting a similar meaning	Content /100 g≥20% NRV Content /100 ml ≥10% NRV Content /420 kJ ≥10% NRV
	Protein-enhanced or reduced	Compared with the reference food, protein content is enhanced or reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Fat	No, Not Including, Not, Zero, Free, Without, etc., Or any other word or words of similar meaning or symbol denoting a similar meaning	≤0.5 g/100g (solid) or 100ml (liquid)
	Low, Little, Low source, Contain a small amount, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤3 g/100g solid ≤1.5 g/100ml liquid
	Fat reduced	Compared with the reference food, fat content is reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Saturated fat/Saturated fatty acids	No, Not Including, Not, Zero, Free, Without, etc., Or any other word or words of similar meaning or symbol denoting a similar meaning	≤0.1 g/ 100g(solid) or 100ml (liquid) Restriction: Refer to the sum of saturated fat and trans fat
	Low, Little, Low source, Contain a small amount, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤1.5 g/100g solid ≤0.75 g /100mL liquid Restriction: 1. Refer to the sum of saturated fat and trans fat 2. energy from saturated fat no more than 10% of total
	Saturated Fat reduced	N/A
Trans fatty acids	No, Not Including, Not, Zero, Free, Without, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤0.3 g/100g (solid) or 100ml (liquid)
Trans fatty acids	Trans fatty acids reduced	N/A
Cholesterol	No, Not Including, Not, Zero, Free, Without, etc., Or any other word or words of similar meaning or symbol denoting a similar meaning	≤5 mg/100g (solid) or 100ml (liquid). Restriction: Should comply with both demand and restriction for low saturated fat claim
	Low, Little, Low source, Contain a small amount, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤20m g /100g solid; ≤10m g /100ml liquid. Restriction: Should comply with both demand and restriction for low saturated fat claim
	Cholesterol reduced	Compared with the reference food, cholesterol content is reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to understand.
Sugar (Carbohydrate)	No, Not Including, Not, Excluded, Zero, Free, Without, etc., Or any other word or words of similar meaning or symbol denoting a similar meaning	≤ 0.5 g /100g (solid) or 100ml (liquid)
	Low, Little, Low source, Contain a small amount, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤ 5 g /100g (solid) or 100ml (liquid)
	Carbohydrate enhanced or reduced	Compared with the reference food, carbohydrate content is enhanced or reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
	Sugar reduced	Compared with the reference food, sugar content is reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Dietary Fiber	Origin, Source, Include, Contain, Provide, Has, etc. or any other word or words of similar meaning or symbol denoting a similar meaning	≥3 g/ 100g (solid) ≥1.5 g/ 100ml (liquid) or ≥1.5 g/ 420 kJ Restriction: Total content of dietary fiber should comply with the demand; or at least one of soluble dietary fiber, insoluble dietary fiber and monomer comply with the demand
	High, Rich, Good Source, etc. or any other word or words of similar meaning or symbol denoting a similar meaning	≥6 g/ 100g (solid) ≥3 g/ 100ml (liquid) or ≥3 g/ 420 kJ Restriction: Total content of dietary fiber should comply with the demand; or at least one of soluble dietary fiber, insoluble dietary fiber and monomer comply with the demand
	Dietary fiber enhanced or reduced	Compared with the reference food, dietary fiber content is enhanced or reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Sodium/Salt	No, Not Including, Not, Excluded, Zero, Free, Without, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤5 mg /100g or 100ml Restriction: The “sodium” can be replaced by “salt”, such as “low salt”, “salt reduced”, etc.
	Very Low, Extremely Low, Super Low, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤40 mg /100g or 100ml Restriction: The “sodium” can be replaced by “salt”, such as “low salt”, “salt reduced”, etc.
	Low, Little, Low source, Contain a small amount, etc. Or any other word or words of similar meaning or symbol denoting a similar meaning	≤120 mg /100g or 100ml Restriction: The “sodium” can be replaced by “salt”, such as “low salt”, “salt reduced”, etc.
	Sodium reduced	Compared with the reference food, sodium content is reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Vitamin	Origin, Source, Include, Contain, Provide, Has, etc. or any other word or words of similar meaning or symbol denoting a similar meaning	/100 g ≥15% NRV /100 ml≥7.5% NRV /420 kJ ≥5% NRV Restriction: Including “multivitamins” refer to 3 or more vitamins, complying with the “including” demand
	High, Rich, Good Source, etc. or any other word or words of similar meaning or symbol denoting a similar meaning	/100 g ≥ 30% NRV /100 ml≥15% NRV /420 kJ ≥ 10% NRV Restriction: Rich in “multivitamins” refer to 3 or more vitamins, complying with the “rich in” demand
	Vitamin enhanced or reduced	Compared with the reference food, vitamin content is enhanced or reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Mineral (Except Sodium)	Origin, Source, Include, Contain, Provide, Has, etc. or any other word or words of similar meaning or symbol denoting a similar meaning	/100 g ≥15% NRV /100 ml≥7.5% NRV /420 kJ ≥5% NRV Restriction: Including “multi-minerals” refer to 3 or more minerals, complying with the “including” demand
	High, Rich, Good Source, etc. or any other word or words of similar meaning or symbol denoting a similar meaning	/100 g ≥ 30% NRV /100 ml≥15% NRV /420 kJ ≥ 10% NRV Restriction: Rich in “multi-minerals” refer to 3 or more minerals, complying with the “rich in” demand
	Mineral (exclude sodium) enhanced or reduced	Compared with the reference food, mineral content is enhanced or reduced by 25% or more. Condition: The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.

Table 5-2: Synonymous Name of Nutrition Content Claim

Standard Words	Synonymous
Not including, or no	Zero (0), without, 100 % not including, no, 0 %
Very low	very few
Low	less, less oil (refers to low fat claim only)
Including, origin of	Provide, include, have
Rich in, high	Good origin, with rich XX, rich in xx, provide high xx (content)

Table 5-3: Nutrition Comparative Claim

Comparative Claim Form	Requirements	Conditions
Energy reduced	Compared with the reference food, energy value is reduced by 25% or more	The reference food should be of the same type or genus which is well known by the consumers and easy to be understood.
Protein-enhanced or reduced	Compared with the reference food, protein content is enhanced or reduced by 25% or more
Fat reduced	Compared with the reference food, fat content is reduced by 25% or more
Cholesterol reduced	Compared with the reference food, cholesterol content is reduced by 25% or more
Carbohydrate-enhanced or reduced	Compared with the reference food, carbohydrate content is enhanced or reduced by 25% or more
Sugar reduced	Compared with the reference food, sugar content is reduced by 25% or more
Dietary fiber enhanced or reduced	Compared with the reference food, dietary fiber content is enhanced or reduced by 25% or more
Sodium reduced	Compared with the reference food, sodium content is reduced by 25% or more
Mineral (exclude sodium) enhanced or reduced	Compared with the reference food, mineral content is enhanced or reduced by 25% or more
Vitamin-enhanced or reduced	Compared with the reference food, vitamin content is enhanced or reduced by 25% or more

Table 5-4: Synonymous of Nutrition Comparison Claim

Standard Words	Synonymous
Enhanced	Enhanced by X %（X times）
	Enhanced, enhanced by X %（X times）
	Raised, raised by X % (X times)
	Heightened, X % (X times) higher
	Increased by X % (X times), etc.
	X% more, X times increased
Reduced	Reduced by X %（X times）
	Reduced, reduced by X% (X times)
	Subtracted, subtracted by X %（X times）
	Lowered, X % (X times) lower
	Decreased by X % (X times), etc.
	X% less, X times decreased

According to GB 28050 -2011 National Food Safety Standard - Standard for Nutrition Labeling of Prepackaged Foods [3], the regulatory requirements on nutrition function claims are listed in the following table:

Table 5-5: Nutrition Function Claim

Item	Claim	Conditions of use
Energy	The human body needs energy to maintain life activities. The body growth and all activities need energy. Appropriate energy could maintain good health. Excessive intake of energy and insufficient exercise are related to overweight and obesity.	As for the prepackaged foods for special dietary supplies meeting content claim requirements, the function claim of energy and (or) nutritional ingredients may be conducted. The wording of the function claim shall be the standard wording for the function claim specified in GB 28050.
Protein	Protein is the major component of the human body and provides various kinds of amino acids. Protein is essential to human activities and contributes to tissue formation and growth. Protein is conducive to the formation and formation or repairing of human tissue. Protein contributes to tissue formation and growth. Protein is a major nutrient for tissue formation and growth.
Fat	Fat could provide high energy. Energy from fat of daily diet should not exceed 30% of total energy. Fat is an important component of the human body. Fat helps the absorption of fat-soluble vitamins. Fat provides the amino acids that the human body needs.
Saturated fat	Saturated fat could promote the absorption of cholesterol in foods. Excessive intake of saturated fat is harmful to health. Excessive intake of saturated fat will increase cholesterol; therefore, intake of saturated fat should be less than 10% of total daily energy.
Trans fatty acid	Daily intake of trans fatty acid should not exceed 2.2g; excessive intake of trans fatty acid is harmful to health. Intake of trans fatty acid should be less than 1% of total daily energy; excessive intake of trans fatty acid is harmful to health. Excessive intake of trans fatty acids will increase cholesterol in the blood and increase the risk of cardiovascular disease.
Cholesterol	For adults, daily intake of cholesterol should not exceed 300mg.
Carbohydrate	Carbohydrate is the basic substance for human life and the major source of energy. Carbohydrate is the major source of energy for humans. Carbohydrate is the major source of blood sugar formation. Carbohydrates should take about 60% of the total energy in diet.
Dietary fiber	Dietary fiber helps maintain the normal function of the intestines. Dietary fiber is a low-energy substance.
Sodium	Sodium adjusts the water balance of the body, hence the acid-base balance. Daily intake of salt should not exceed 6g for adults. Excessive intake of sodium is harmful to health.
Vitamins	Vitamin A helps maintain the scotopic (dark visual acuity). Vitamin A helps maintain the health of skin and mucosa.
	Vitamin D facilitates the absorption of calcium. Vitamin D is good for bone and tooth health. Vitamin D helps the formation of bones.
	Vitamin E features an anti-oxidation function.
	Vitamin B1 is an indispensable component of energy metabolism. Vitamin B1 helps maintain the normal physiological function of the neural system.
	Vitamin B2 helps maintain the health of skin and mucosa. Vitamin B2 is an indispensable component for energy metabolism.
	Vitamin B6 helps metabolism and the use of protein.
	Vitamin B12 helps the formation of RBC.
	Vitamin C helps maintain the health of skin and mucosa. Vitamin C helps maintain the health of bones and gum. Vitamin C facilitates the absorption of iron. Vitamin C has anti-oxidation efficacy.
	Nicotinic acid helps maintain the health of skin and mucosa. Nicotinic acid is an indispensable component for energy metabolism. Nicotinic acid helps maintain the health of the neural system.
	Folic acid helps the development of the brain and neural system for embryo. Folic acid helps the formation of RBC. Folic acid helps the development of embryo.
	Pantothenic acid is essential for energy metabolism and tissue formation.
Minerals (Except Sodium)	Calcium is the major component of human bone and tooth; many physiological functions require the participation of calcium. Calcium is the major component of bone and tooth, and it maintains bone density. Calcium helps the development of bones and teeth. Calcium makes the bone and tooth firmer.
	Magnesium is an essential component for energy metabolism, tissue formation, and bone growth.
	Iron is an important component for RBC formation. Iron is an essential element for RBC formation. Iron is essential for the production of hemoglobin.
	Zinc is an essential element for children's growth. Zinc helps improve appetite. Zinc helps maintain skin health.
	Iodine is essential for the normal function of the thyroid.

5.2.2 Nutritional Claim Registration

For nutritional claims that are already permitted for use: N/A

For nutritional claims that are not currently permitted for use: New nutritional claims only could be added through the standard revision in the national standard revision plan.