Summary: China’s updated national food standard, GB 7718-2025 (General Standard for the Labeling of Prepackaged Foods), officially takes effect on March 16, 2027. Under the new regulations, packaging artwork and images are legally defined as food labels and subjected to strict GACC compliance checks. This quick guide outlines the critical packaging updates foreign food manufacturers and exporters must make to avoid shipment detentions, customs rejections, or forced relabeling at Chinese ports.
Why Packaging Artwork Rules Matter for China Food Imports
In the past, many global brands viewed packaging imagery simply as brand marketing or serving suggestions. Under the newly issued GB 7718-2025 and the Administrative Measures on Food Labeling, all real photography, digital illustrations, artwork, and graphic design elements on product packaging are strictly regulated as official food labels.
Using inaccurate or misleading artwork will be flagged by China Customs (GACC) as “false advertising” or “consumer deception,” resulting in import clearance delays, product rejections, or mandatory returns.
4 Core Rules for Packaging Images Under GB 7718-2025
1. Real Photography Requires Real Ingredients
- Actual Ingredients Present: Real photography of fruits, crops, or raw materials is ONLY permitted if the ingredient is physically included in the formulation (e.g., real strawberry juice or strawberry pulp).
- Flavoring-Only Products Prohibited: If a product relies solely on artificial food flavorings (e.g., strawberry-flavored candy containing no real strawberries), real photography is strictly forbidden. Foreign brands must use cartoon or vector illustrations instead, accompanied by a prominent disclaimer such as “Image for flavor reference only” (“图案仅供口味参考”).
2. Strict Regulation on AI-Generated Artwork
With many exporters using generative AI tools for product packaging design, GB 7718-2025 introduces specific oversight: If AI-generated graphics are visually indistinguishable from real photography, GACC will regulate them under the strict rules governing real photos.
3. Prohibition of Health or Disease Prevention Claims
Any imagery, diagrams, or visual layout implying that the food product or its ingredients can prevent, treat, or cure medical conditions is strictly prohibited on prepackaged foods.
4. Mandatory Disclaimers for Serving Suggestions
For condiments, instant meals, or pre-packaged dishes showing ingredients not included in the package (such as a flavor packet showing a completed beef noodle bowl), a clear disclaimer must be placed adjacent to the graphic stating: “Image for serving/cooking reference only” (“图片仅供烹饪搭配参考”).
Compliance Reference Matrix (GB 7718-2025)
| Product Formulation | Permissible Graphic Types | Required On-Pack Disclaimer |
|---|---|---|
| Contains Real Ingredient | Real photos, illustrations, vector graphics | None required (unless explicitly emphasizing content) |
| Uses Flavoring Only | NO real photos allowed (illustrations/cartoons only) | Mandatory: “Image for flavor reference only” |
| AI-Generated Graphics (Photorealistic) | Regulated as real photography | Depends on actual ingredient presence |
| Serving Suggestion (Includes extra foods) | Allowed (showing prepared dishes) | Mandatory: “Image for serving reference only” |
Key Timeline & Action Plan for Foreign Exporters
- Mandatory Enforcement Date: March 16, 2027
- Recommended Action: Modifying packaging artwork, printing new materials, and executing GACC label audits require significant lead time. Foreign manufacturers and trade partners should audit their existing SKUs before late 2026 to ensure seamless customs clearance.
Work with China Food Import & Customs Experts
Navigating China’s evolving GACC regulations requires local expertise and proactive compliance. As dedicated specialists in China food import clearance, we provide end-to-end solutions for global food and beverage brands:
- GB 7718-2025 Packaging & Artwork Pre-Audit
- GACC Overseas Manufacturer Facility Registration
- Customs Declaration, Label Compliance, and Port Clearance Support
Planning to export prepackaged food or beverage products to Mainland China? Contact our compliance specialists today to request an expert artwork review and secure your entry into the Chinese market.