More realistic packaging standards for special dietary foods


Based on the national standards released in 2021, the set ratios for empty space within food packaging were unrealistically small for special dietary foods, which include infant formula and foods for special medical purposes (FSMP). If impacted manufacturers had been compelled to follow these standards, they would have faced severe compliance costs, as well as difficulties selling their products in online and offline markets. Consumers who rely on certain products would likely have lost access to them.

The European Chamber was engaged with the relevant authorities for a long time to highlight the risks and potential negative impacts of these requirements. On 29th March, the State Administration of Market Regulation (SAMR) issued an amendment to the relevant document, which, following the Chamber’s recommendations, optimised the requirements for five special dietary food categories.


To accelerate green and low-carbon development in the food and cosmetics industries, the SAMR released the Requirements of Restricting Excessive Package—Foods and Cosmetics (GB 23350) in 2021, which came into effect on 1st September 2023. These standards specify the allowed ratios for empty space within the packaging of all food and cosmetics commodity categories.

The set ratios were unrealistically small for the special dietary foods category, which includes infant formula, FSMP, milk powder, modified milk powder, complementary foods for infants and young children and complementary food nutritional supplements. While the technical requirements for the production and packaging of these products are the same as those for ‘ordinary’ food products, they were given stricter parameters. For instance, the ratio for ordinary cookies was set almost seven times higher than for cookies for infants and young children.

If manufacturers of special dietary foods had been compelled to follow these standards, they would have faced significant compliance costs, as well as difficulties being able to sell in online and offline markets. Even if the ratio was increased by 50 per cent, the estimated cost of rectification for a single product for the whole sector, taking rice powder for infants and young children as an example, would be around Chinese yuan (CNY) 0.8 billion.

Furthermore, consumers who rely on certain products, including due to medical conditions, would likely have lost access to them.

Advocacy Efforts

From June to December 2023, the Chamber sent two advocacy letters to the SAMR and four advocacy letters to the Ministry of Industry and Information Technology (MIIT) on behalf of the Agriculture, Food and Beverage Working Group, the Paediatric Nutrition Desk, the FSMP Desk and the Dairy Industry Desk, detailing the compliance risks of relevant products on the market and the potential impact on industry and consumers.

These advocacy efforts successfully encouraged three rounds of public consultation on the No.2 Amendment to GB 23350. After the Chamber submitted comments in September 2023, the second draft adopted the Chamber’s suggested ratios for empty space for four special dietary food categories. The Chamber again provided comments during the second round of public consultation.

In January 2024, the Department of Consumption of the MIIT informed the Chamber about the upcoming third round of public consultation. The Chamber then submitted comments providing reports on the potential impact on special dietary food products, as standards for this category had not been amended in the draft version.


On 29th March 2024, the SAMR issued No.2 Amendment to GB 23350 (Amendment), optimising the requirements for five special dietary food categories in line with the Chamber’s recommendations.

With the release of this Amendment, relevant products from our members can continue to be sold online and offline without the need to make any changes.