On March 9, 2022, the State Administration for Market Regulation (SAMR) issued no. 1 amendment for GB 23350-2021 The Requirements of Restricting Excessive Package-Foods and Cosmetic (hereinafter referred to as “the Requirements”) and calls for public comments before April 6, 2022.

The Requirements is a national mandatory standard that aims at controlling excessive packaging. The goal is to protect consumer rights and reduce environmental pollution caused by unnecessary packings.

Key contents of the no. 1 amendment outline further restrictions on the excessive packing of mooncakes and zongzi (a unique traditional Chinese food eaten during the Dragon Boat Festival that consists of a pyramid-shaped dumpling made of glutinous rice wrapped in bamboo or reed leaves). The amendment specifies that:

·   The packing of mooncakes and zongzi should not exceed three layers, and the packing of other grain-based foods should not exceed four.

·   All packing costs, unless in direct contact with the product, should not exceed 20% of the selling price.

·   Materials, such as precious metals and red sandalwood, are not allowed to be applied to mooncake and zongzi packaging.

·   Mooncakes are not allowed to be sold in mixed packing with any other goods

·   Goods with higher value than zongzi are not permitted to be sold in mixed packing with it.  

·   The parameters of mooncakes and zongzi are added into the chart of necessary spatial coefficient of commodity

Further proof of the no.1 amendment aiming at stricter control of excessive packing for mooncakes and zongzi is through suggestion that its revised contents become effective on August 1, 2022. This would begin ahead of the effective date for the GB 23350-2021 (which will come into force on September 1, 2023). It requires packing designers and manufacturers of such products to follow the new regulations, with all inventories of these two foods being sold or used before August 1, 2022.

Based on the mentioned facts, relevant foreign stakeholders, especially manufacturers of such products, must closely follow the next steps from the no.1 amendment (such as the official implementation announcement). Once the amendment is effective, such manufacturers will have a very small window to make adjustments or modifications if their products are not compliant.

Other relevant foreign food manufacturers and MNCs are suggested to check the revised chart of necessary spatial coefficient of commodity mentioned in the amendment. Such new changes will directly impact both packing and product design.

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