In China, the art of gift-giving has long been an integral part of social and business interactions, with elaborate packaging often seen as a symbol of respect and value. However, this cultural practice is now facing a significant challenge as China steps up its efforts to combat excessive packaging in the food industry. The implementation of GB23350-2021, a stringent regulation aimed at curbing over-packaging, marks a pivotal shift in China’s approach to sustainability and waste reduction.
Understanding GB23350-2021: China’s Stance on Excessive Packaging
Key Provisions of GB23350-2021
- Interspace Ratio Redefined
- Previous standard: Based on product categories
- New standard: Determined by net content of individual products
- Example: For products weighing 30-50g, interspace ratio must not exceed 40%
- Necessary Spatial Coefficient Updates
- Old standard: Uniform 0.6 coefficient
- New standard: Varied coefficients based on product type
- Examples:
- Beverages: 5.0
- Biscuits: 10.0
- Toothpaste: 5.0
- Packaging Layer Restrictions
- Maximum of three layers for most food products
- Specific exceptions may apply for certain categories
- Material Selection Guidelines
- Emphasis on recyclable and biodegradable materials
- Restrictions on certain types of plastics and non-sustainable materials
- Cost Restrictions
- The cost of all packaging materials, except those in direct contact with the product, must not exceed 20% of the product’s sales price
- This provision aims to reduce the financial burden of excessive packaging on consumers
Implementation Timeline
- Published: August 10, 2021
- Effective Date: September 1, 2023
- Transition Period: Two years for industry adaptation
Detailed Breakdown of GB23350-2021 Requirements
1. Scope of Application
The standard applies to the packaging of food and cosmetics products sold within the territory of the People’s Republic of China. It covers both domestically produced and imported items.
2. Packaging Layer Definitions
- First Layer: The innermost layer in direct contact with the product
- Second Layer: The layer immediately outside the first layer
- Third Layer: The outermost layer of packaging
3. Interspace Ratio Calculation
The interspace ratio is calculated using the following formula:
Interspace Ratio = (Package Volume – Product Volume) / Package Volume × 100%
Maximum allowed interspace ratios based on product net content:
- ≤ 30g: 55%
- 30g to ≤ 50g: 40%
- 50g to ≤ 100g: 30%
- 100g to ≤ 250g: 25%
- 250g to ≤ 500g: 20%
- 500g: 15%
4. Necessary Spatial Coefficient
The necessary spatial coefficient is used to determine the maximum allowable package volume:
Maximum Package Volume = Product Volume × Necessary Spatial Coefficient
Coefficients for common food products:
- Beverages: 5.0
- Biscuits and Pastries: 10.0
- Candies and Chocolates: 8.0
- Tea: 12.0
- Health Food: 12.0
5. Packaging Cost Restrictions
- The cost of packaging materials (excluding those in direct contact with the product) must not exceed 20% of the product’s sales price
- For gift packages containing multiple items, the total packaging cost must not exceed 20% of the total product value
Impact on Food Exporters
- Product Redesign
- Necessity to reassess and potentially redesign packaging for the Chinese market
- Focus on minimalist, functional designs that meet regulatory requirements
- Cost Implications
- Initial investments in packaging redesign and material sourcing
- Potential long-term savings from reduced material usage
- Need to balance packaging costs with product pricing to comply with the 20% cost restriction
- Market Access
- Non-compliant products may be barred from production, sale, or import after the transition period
- Brand Perception
- Opportunity to align with China’s sustainability goals
- Potential for improved brand image among environmentally conscious consumers
Strategies for Compliance
- Conduct Thorough Packaging Audits
- Assess current packaging against GB23350-2021 standards
- Identify areas requiring modification
- Invest in Sustainable Materials
- Explore eco-friendly alternatives that meet both regulatory and functional requirements
- Consider partnerships with local sustainable packaging suppliers
- Optimize Package Design
- Utilize advanced design software to minimize unnecessary space
- Balance product protection with compliance requirements
- Stay Informed on Regulatory Updates
- Monitor for any amendments or clarifications to GB23350-2021 and related standards
- Engage with local regulatory consultants for expert guidance
Related Standards and Regulations
- GB 4806.1-2016: General Safety Requirements for Food Contact Materials and Articles
- Sets safety standards for materials that come into direct contact with food
- Ensures that packaging materials do not transfer harmful substances to food products
- GB 9685-2016: Standard for the Use of Additives in Food Contact Materials and Articles
- Regulates the use of additives in food packaging materials
- Aims to prevent chemical contamination of food products
- Law on the Prevention and Control of Environmental Pollution by Solid Wastes
- Effective since September 1, 2020
- Requires manufacturers and operators to comply with mandatory standards restricting excessive packaging
Non-Compliance Penalties
China strictly enforces GB23350-2021 packaging regulations. Local authorities conduct inspections and impose penalties for violations. Minor infractions may receive warnings, while serious offenses face fines up to 100,000 RMB. Non-compliant products could face recalls or import bans.
Reputational damage from violations can harm brand image and consumer trust. Severe cases may lead to legal action under environmental laws.
The government also provides education and guidance to help businesses comply. Given the potential consequences, food exporters should proactively ensure compliance through expert advice, audits, and quality control measures.
Conclusion
The implementation of GB23350-2021 represents a significant shift in China’s approach to packaging, particularly in the food sector. While it poses challenges for exporters, it also offers opportunities for innovation and improved sustainability practices. Companies that proactively adapt to these new standards will be better positioned to succeed in the evolving Chinese market.
Call to Action
Don’t let packaging regulations become a barrier to your success in China. Contact our regulatory experts today for a comprehensive assessment of your product packaging and tailored compliance strategies.