[Q&A] Should the country of origin for imported products be indicated in Chinese?
2023. 7. 21
[Q&A] Should the country of origin for imported products be indicated in Chinese?
As a corporate law firm, we are used to answering many questions from our clients about their business in China. In this series of Q&A articles, we will discuss some of the topics that our clients have shown interest in.
Question: Should the country of origin for imported products be indicated in Chinese?
Answer: The requirements for country-of-origin labeling vary depending on the nature of the product (such as food, cosmetics, or other daily consumables). For example, for packaged imported food products, the Chinese label indicating the country of origin must be included according to Article 97 of the Food Safety Law. For imported cosmetics, the relevant regulations apply, such as the Measures for the Inspection, Quarantine, Supervision and Administration of Import and Export Cosmetics (Revised in November 2018), the Measures for the Administration of Cosmetic Labels, and GB 5296.3-2008 Instruction for use of Consumer Products - General Labelling for Cosmetics, stating the country or region of origin (including Hong Kong, Macau, and Taiwan) for imported cosmetics.
However, unlike food and cosmetics, there is no mandatory requirement in Chinese law for other general daily consumable products to indicate their country of origin in Chinese (note that there are specific industry regulations for products in specialized industries, such as pharmaceuticals and medical devices, where labeling requirements may differ and have specific provisions).
It should be noted that, as a general rule, the country of origin of a product should be consistent with the Chinese label. If the country of origin indicated on the original package differs from the label in Chinese, it may be considered as a violation of provisions, such as the Product Quality Law, the Regulations on Place of Origin of Imports and Exports, and the Advertising Law, which could lead to administrative penalties.
Furthermore, Article 27 of the Product Quality Law states that labels on products or their packages must be truthful, and the product name, manufacturing facility name, and its location must be displayed in Chinese. Additionally, if necessary to highlight the product's characteristics or usage information, the names and quantities of the product's specifications, grades, and major ingredients should be indicated in Chinese. Furthermore, if there is information that should be made known to consumers in advance, it must be clearly stated on the packaging or provided to consumers in relevant documents. These regulations apply to food, cosmetics, and other general daily consumable products.
If you have further questions regarding this topic, do not hesitate to get in touch with our lawyers for professional legal advice.
