Labeling and Traceability: Dates, Lot Numbers, Barcodes
What Must Frozen Foods Be Labeled With?
Article 22 of the Act Governing Food Safety and Sanitation (食品安全衛生管理法) requires food containers or outer packaging to clearly show, in Chinese and commonly used symbols:
- Product name.
- Names of contents; for mixtures of two or more, listed in descending order of content.
- Net weight, volume, or quantity.
- Names of food additives.
- Name, phone number, and address of the manufacturer or domestic responsible company.
- Place (country) of origin.
- Expiration date.
- Nutrition labeling.
- Genetically modified food ingredients.
- Other matters announced by the central competent authority.
Frozen foods are also subject to labeling rules for prepackaged frozen foods (市售包裝冷凍食品標示規定): in addition to the items above, storage methods and conditions must be added; for products that must be heated or cooked before eating, heating and cooking conditions must also be added. Frozen dumplings and buns mostly fall into the latter category, which is why packaging commonly says "Store at -18°C or below" along with instructions like "boil for about X minutes" or "steam for about X minutes."
The Ministry of Health and Welfare has separate announcements on matters such as allergens and the origin of meat, so check whether they apply based on your product's contents.
How to Write the Expiration Date
Article 13 of the Enforcement Rules of the Act Governing Food Safety and Sanitation (食品安全衛生管理法施行細則) requires the expiration date to be printed on the container or outer packaging, showing the year, month, and day in a conventionally recognizable way; for products with a shelf life of 3 months or more, only the year and month may be shown, with the last day of that month as the end date.
How is the expiration date set? Article 14 of the Regulations on Good Hygiene Practice for Food (食品良好衛生規範準則) requires food manufacturers to set expiration dates based on shelf-life testing or other reasonable documentation, keep records of the test results, and retain samples of products until their expiration date.
How to Assign Lot Numbers
The regulations don't prescribe a lot number format, but a lot number should let you "trace everything back from a single package": what day, which line, and which shift made it, and which lots of raw materials were used. Common formats:
- Date + line + shift: for example, the year, month, and day followed by a line code and shift code.
- Date + serial number: when there are multiple batches in a day, distinguish them with a serial number.
- Paired with a raw material lot table: The lot number itself doesn't need to contain raw material information, but production records must link finished product lot numbers to raw material lot numbers.
The finer you divide lots, the smaller the scope of any recall. Article 29 of the Enforcement Rules of the Act Governing Food Safety and Sanitation provides that when products are confiscated and destroyed, or ordered to be disinfected, reprocessed, or subjected to safety measures within a deadline, the scope extends to products with the same expiration date or lot number; where no expiration date is labeled or the lot number can't be identified, the scope extends to all products.
Printing and Barcode Equipment
- Thermal transfer and inkjet printers: Mounted on the packaging machine, printing the expiration date and lot number during packaging.
- Laser coding: Suits certain materials, with markings that don't rub off easily.
- Barcode labels: Barcodes on outer cases make warehouse and shipping scanning easier.
Regularly confirm the equipment prints clearly and the date is correct, and always double-check at date and lot changes; misprinted dates are a common cause of recalls.
How Far Does Traceability Need to Go?
Article 9 of the Act Governing Food Safety and Sanitation requires food businesses to keep source documents for raw materials, semi-finished products, and finished products; businesses in categories and scales announced by the central competent authority must establish a traceability or tracking system.
Article 4 of the Regulations Governing Traceability and Tracking Systems for Foods and Related Products (食品及其相關產品追溯追蹤系統管理辦法) lists the minimum items manufacturers must manage, including: raw material supplier, name, quantity, lot number, expiration date, receiving date, and origin; product name, main and secondary ingredients, food additives, packaging containers, storage and transport conditions, expiration date, and manufacturing date; identification marking; product distribution (logistics provider, non-natural-person direct buyers, lot number, delivery date, recall and return handling); inventory and disposal records, and more. Article 8 requires records to be kept in full for at least 5 years, in paper or electronic form.
In addition, Article 16 of the Regulations on Good Hygiene Practice for Food requires food manufacturers selling products to non-natural-person direct buyers to have data or records that allow distribution to be traced.
FAQ
Q: Do frozen dumpling packages have to state how to cook them?
A: Frozen foods that must be heated or cooked before eating must add heating and cooking conditions under the labeling rules for prepackaged frozen foods.
Q: Can the expiration date show only the year and month?
A: For products with a shelf life of 3 months or more, only the year and month may be shown, with the last day of that month as the end date.
Q: How should lot numbers be assigned to be legal?
A: There's no fixed format in the regulations; the key is being able to trace back to production date, line, shift, and raw material lot numbers.
Q: How many years must traceability records be kept?
A: Article 8 of the traceability and tracking system regulations requires at least 5 years.