Some statements on a wine label
may keep it from being sold legally in China

The standard was published in March 2025 and takes effect on 16 March 2027. Its clause 8.1 provides that everything visible on the label of an imported prepackaged food, including foreign-language text, the Chinese label and any other accompanying material, must comply with Chinese laws, regulations and food safety standards.

The current GB 7718-2011 mainly requires foreign-language text to correspond to the Chinese. The new standard extends the requirement to everything visible on the label and sets out specific rules for imported prepackaged foods. On that basis, we take the view that English, French, Italian or other foreign-language text on the original front label, back label and neck label must also comply with Chinese rules.

“No added” claims

Clause 4.4.2.2 of the new standard prohibits the use of “not added” (不添加), “not used” (不使用) and their synonyms.

No added sulphites, Sans sulfites ajoutés and Senza solfiti aggiunti all mean “no sulphites added”. The standard does not list foreign-language wording one by one, but as we understand it, such statements may also be treated as “no added” claims. Simply putting them in a foreign language will not necessarily get around the requirement.

“Free from” and “contains no” claims

Clause 4.4.2.1 provides that no claim may be made about a food additive using words such as “free from” (无) or “contains no” (不含).

In China, sulphur dioxide is regulated as a food additive. Statements such as Sulphite-free or No sulphites therefore may not appear even if test results show zero. The same applies to Preservative-free.

For components other than food additives, a “contains no” claim may be used only when the content is zero. Dry wines usually still contain some residual sugar, and a product whose residual sugar is not zero should not be labelled Zero sugar.

Health and functional claims

Clause 3.5 provides that a label must not state or imply, through words, images, symbols or other means, that a food prevents or treats disease, and that a food which is not a registered health food must not state or imply any health function. Back-label copy about resveratrol, antioxidants or being “good for the heart” should therefore be handled with care.

In recent years some brands have used phrases such as “no headache after drinking” or “no hangover”. Statements of this kind may be found to lack a scientific basis or to be exaggerated.

Which products the new rules apply to

Whether the old or the new rules apply depends on the production date, not the import date. The official Q&A on implementing the Measures for the Supervision and Administration of Food Labelling makes clear that the production date is the date on which the packaging process is completed. For wine, that is normally the bottling date.

Wine bottled on or after 16 March 2027 must therefore meet the new requirements. For products bottled before that date, if the label contains prohibited content, the product may not continue to be sold once the rules take effect; the example the Chinese authorities give is “zero added”. If the label contains no prohibited content, the product may be sold until the end of its shelf life.

Because the new standard still exempts wine from stating a shelf life, such products in practice have no fixed sell-by deadline.

However, both “no added” claims and “free from / contains no” claims fall within the prohibitions. As we understand it, wine whose original label carries wording such as No added sulphites, left uncovered, risks being unsaleable in China from 16 March 2027, whenever it was bottled.

What wineries and importers can do

The official Q&A on the standard also makes clear that foreign-language text covered by an affixed label or by similar means does not need to be translated. Importers can cover the wording above with the Chinese label.

If the wording sits in a corner of the back label, covering it is straightforward. If it is printed prominently on the front label, covering it will spoil the look of the label as a whole. Wineries that want to keep such statements can therefore place them, at the design stage, where they are easy to cover.

For products made specifically for the Chinese market, we recommend that wineries remove these statements when the labels are printed at origin. Where it is hard to tell whether a statement complies, it is best to have the importer or customs clearance provider confirm it before the labels are printed, rather than dealing with it after the goods have arrived in China.

The author works at W&S Logistics Center Co., Ltd in Shanghai, which handles import customs clearance and Chinese labelling for wine and sake.