Food Labeling Contrast between China and EU Regulations (Part II)

In case you have not spotted the first part, here you can find the link. This is an invaluable comparison between the Chinese food labeling standards and the Regulation (EU) No 1169/2011. The part II is more focused on nutrition labeling requirements.

Nutrition declaration (Nutrition labeling)

1,Mandatory information

Reg. (EU) No 1169/2011 GB7718-2011


  Reference intake 1+4


Energy value 8400 kJ/2000 kcal Energy value 8400 kJ/2000 kcal
Fat (Total fat)70 g Protein 60 g
Saturates 20 g Fat 60g
Carbohydrate 260 g Carbohydrate 300 g
Sugars 90 g Sodium 2000 mg
Protein 50 g Note: In (EU) No 1169/2011, salt =sodium×2.5
Salt 6 g

If any nutrition claim or functional claim is made about nutrition component besides energy and the core nutrients, the content of such nutrition component and its corresponding NRV% should be indicated on the nutrition labeling.


If any nutritional fortification substances are used in pre-packed food, the content of the fortified nutrition component and its corresponding NRV% should be indicated on the nutrition labeling.


The content of trans fatty acid should be indicated if any hydrogenated oil and fat or partially hydrogenated oil and fat is used as an ingredient or in the manufacturing process.

Not mandatory NRV%

Note: In GB7718-2011, NRV% ×100%

In the formula, x stands for the content of one nutrient.


2, Supplements

Reg. (EU) No 1169/2011 GB 28050-2011
Fat Reference intake Fat NRV
Mono-unsaturates (Total fat)70 g Saturates(acid) ≦20g
Polyunsaturates Trans fats(acid)  
Cholesterol ≦300 mg
Carbohydrate   Carbohydrate  
Polyols (Carbohydrate)260g Sugar(lactose)  
Fibre Dietary fibre (monomer component, soluble or insoluble dietary fibre) 25g



Reg. (EU) No 1169/2011 GB7718-2011
Where the labeling of beverages containing more than 1.2% by volume of alcohol provides a nutrition declaration, the content of the declaration may be limited to the energy value only. For beverages containing more than 0.5% by volume of ethanol, a nutrition labeling is not required.
Where food are offered for sale to the final consumer or to mass caterers without prepackaging, or where foods are packed on the sales premises at the consumer’s request or prepacked for direct sale, the content of the nutrition declaration may be limited to:

(a)    the energy value; or

(b)    the energy value together with the amounts of fat, saturates, sugars, and salt.

  For fresh produce such as meat, fish, vegetables and fruits, eggs etc, a nutrition labeling is not required.
Food in packaging or containers the largest surface of which has an area of less than 25 cm².

For foods which have a total surface area less than 100 cm²or a maximum surface area less than 20 cm², a nutrition labeling is not required.

Food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer.

For site-selling foods, a nutrition labeling is not required.

Waters intended for human consumption, including those where the only added ingredients are carbon dioxide and/or flavorings.

For packed water, a nutrition labeling is not required.
  For prepacked foods of which daily consumption are less than 10 g or 10 ml, a nutrition labeling is not required.

Other foods stipulated in ANNEX V



4, Vitamins and minerals

Reg. (EU) No 1169/2011 GB 28050-2011
Vitamin A 800μg Vitamin A 800μgRE
Vitamin D 5μg Vitamin D 5μg
Vitamin E 12mg Vitamin E 14mgα-TE
Vitamin K 75μg Vitamin K 80μg
Thiamin 1,1mg Thiamin 1.4mg
Riboflavin 1,4mg Riboflavin 1.4mg
Vitamin B6 1,4mg Vitamin B6 1.4mg
Vitamin B12 2,5μg Vitamin B12 2.4μg
Vitamin C 80mg Vitamin C 100mg
Niacin 16mg Niacin 14mg
Folic acid 200μg Folic acid 400μg DFE
Pantothenic acid 6mg Pantothenic acid 5mg
Biotin 50μg Biotin 30μg
None Choline 450mg
Phosphorus 700mg Phosphorus 700mg
Potassium 2 000mg Potassium 2000mg
Chloride 800mg None
Magnesium 375mg Magnesium 300mg
Calcium 800mg Calcium 800mg
Iron 14mg Iron 15mg
Zinc 10mg Zinc 15mg
Iodine 150μg Iodine 150μg
Selenium 55μg Selenium 50μg
Chromium 40μg None
Molybdenum 50μg None
Copper 1mg Copper 1.5mg
Fluoride 3,5mg Fluoride 1mg
Manganese 2mg Manganese 3mg


5, Expression of the content of nutrients

Reg. (EU) No 1169/2011 GB7718-2011
Per 100g or per 100ml Per 100g or per 100ml
Per portion or per consumption unit Per portion


A much more detailed Questions and Answers of GB 28050-2011 (Revised Version) has been provided by National Health and Family Planning Commission of the People’s Republic of China and acts as an inseparable supplement to GB 28050-2011. It gives the basic introduction of GB 28050-2011 and clarifies relevant definitions, while elaborating on the most important parts and elements in making a nutrition labeling. It’s more intricate than GB 28050-2011 and requires more patience if one wants to master the Chinese regulations in food nutrition labeling.

FDA ruling on Trans-Fats

FDA released its’ final determination that Partially Hydrogenated Oils (PHOs) are not Generally Recognized as Safe (GRAS). The determination is based on extensive research into the effects of PHOs, as well as input from stakeholders during the public comment period.

PHOs are the primary dietary source of artificial trans fat in processed foods. In FDA view, removing PHOs from processed foods could prevent thousands of heart attacks and deaths each year.


FDA has set a compliance period of three years. This will allow food companies to either reformulate products without PHOs and/or petition the FDA to permit specific uses of PHOs. Many companies have already been working to remove PHOs from processed foods and the FDA anticipates that many may eliminate them ahead of the three-year compliance date.

It’s important to note that trans fat will not be completely gone from foods because it occurs naturally in small amounts in meat and dairy products, and is present at very low levels in other edible oils.

The FDA encourages consumers seeking to reduce trans fat intake to check a food’s ingredient list to determine whether or not it contains partially hydrogenated oil.


In January 2006, FDA required the food industry to declare the amount of trans fat in food on the Nutrition Facts label. FDA data indicate that many processed foods have been reformulated to reduce the amount of trans fat since the requirement was instituted, but a substantial number of products still contain PHOs.

One of FDA’s core regulatory functions is ensuring that food, including all substances added to food, is safe. In November 2013, FDA made a preliminary determination that PHOs are not “generally recognized as safe” (GRAS) for use in food. FDA opened a 60-day public comment period on this measure to solicit data and information on a number of issues, including:

1. Whether FDA should finalize its tentative determination that PHOs are no longer GRAS;
2. How long it would take producers to reformulate food products to eliminate PHOs.

The comment period was then extended an additional 60 days and closed March 8, 2014.

The final determination was released June 16, 2015. This determination is based on extensive research into the effects of PHOs, as well as input from all stakeholders received during the public comment period (see Final Determination Regarding Partially Hydrogenated Oils, June 2015).

To learn more about trans fat, see also the FDA Trans Fat page.

EU Situation

In EU art. 30.7 of the FIC Regulation (“Food Information to Consumers” Reg. (EU) n. 1169/2011) says that “by 13 December 2014, the Commission, taking into account scientific evidence and experience acquired in Member States, shall submit a report on the presence of trans fats in foods and in the overall diet of the Union population. The aim of the report shall be to assess the impact of appropriate means that could enable consumers to make healthier food and overall dietary choices or that could promote the provision of healthier food options to consumers, including, among others, the provision of information on trans fats to consumers or restrictions on their use. The Commission shall accompany this report with a legislative proposal, if appropriate.”

Today the report has not been submitted yet and the Commission has been deeply criticized, especially from consumers associations for the unexpected delay. As a matter of fact in this situation is not even possible to declare voluntary the trans fat value in the EU format of the nutrition declaration (while in USA is mandatory from 2006).

Here below, you can find the definition of Trans fatty acids (TFA) and the advice given by EFSA in a 2010 Scientific Opinion:

“Trans fatty acids are not synthesised by the human body and are not required in the diet. Therefore, no Population Reference Intake, Average Requirement, or Adequate Intake is set. Consumption of diets containing trans-monounsaturated fatty acids, like diets containing mixtures of saturated fatty acids, increases blood total and LDL cholesterol concentrations in a dose-dependent manner, compared with consumption of diets containing cis-monounsaturated fatty acids or cispolyunsaturated fatty acids. Consumption of diets containing trans-monounsaturated fatty acids also results in reduced blood HDL cholesterol concentrations and increases the total cholesterol to HDL cholesterol ratio. The available evidence indicates that trans fatty acids from ruminant sources have adverse effects on blood lipids and lipoproteins similar to those from industrial sources when consumed in equal amounts. Prospective cohort studies show a consistent relationship between higher intakes of trans fatty acids and increased risk of coronary heart disease. The available evidence is insufficient to establish whether there is a difference between ruminant and industrial trans fatty acids consumed in equivalent amounts on the risk of coronary heart disease. Dietary trans fatty acids are provided by several fats and oils that are also important sources of essential fatty acids and other nutrients. Thus, there is a limit to which the intake of trans fatty acids can be lowered without compromising adequacy of intake of essential nutrients. Therefore, the Panel concludes that trans fatty acids intake should be as low as is possible within the context of a nutritionally adequate diet. Limiting the intake of trans fatty acids should be considered when establishing nutrient goals and recommendations.”