China Solicits Public Opinion on First Amendment to Restriction on Excessive Packaging Requirements

On 18 April 2022 China’s Ministry of Industry and Information Technology issued a notice to seek public opinion on GB 23350-2021 (Restriction of Excessive Packaging Requirements for Food and Cosmetics) 1st Amendment. The amendment is open for public comments for the second time and aims to further restrict excessive packaging used with moon cakes and zongzi. Comments are due by 24 April 2022.

3E Review

The national standard GB 23350-2021 (Restriction of Excessive Packaging Requirements for Food and Cosmetics) was published on 10 August 2021 and will enter into force on 1 September 2023. GB 23350-2021 was proposed to place stricter restrictions on the packaging of moon cakes and zongzi.

The proposed 1st amendment aims to revise the following requirements on the packaging of moon cakes and zongzi.

Revised Section 4.2: Packaging Layers

The packaging of grain and its processed products, moon cakes and zongzi, should not exceed three layers of packaging. Other products should not exceed four.

Revised Section 4.3 Packaging Costs

Manufacturers should take measures to ensure the total packaging cost of a product does not exceed 20% of the product’s sale price, except for packaging in direct contact with the product.

For moon cakes and zongzi with a sale price higher than RMB 100, the packing cost should not exceed 15% of the sale price. The packaging of moon cakes and zongzi should not use expensive materials, such as precious metal and precious wood.

Section 4.4 Requirements of Mixed Packaging

The proposed amendment would add Section 4.4 Requirements for Mixed Packaging, which stipulates that moon cakes should not be boxed with other products and zongzi should not be boxed with other products whose value exceeds the zongzi.

The proposed amendment also would revise Table A.1 Product Necessary Space Coefficient for Food.

3E Analysis 

Companies that manufacture and package food products in China, especially moon cakes and zongzi, should note that China proposes to revise GB 23350-2021 to pose stricter restrictions on the packaging of moon cakes and zongzi. Companies are advised to review the proposal and submit their comments to China's Ministry of Industry and Information Technology to KJBZ@miit.gov.cn before 24 April 2022.

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