On January 19, 2024, the State Administration for Market Regulation of China issued a notice on the draft revision of the Food Safety Law, which intends to adopt registration management for liquid infant formula products. This move is seen as a necessary step to ensure the quality and safety of these products, thus protecting the health and well-being of consumers. Foodmate analyzes the main contents as follows.

I. Characteristics of liquid infant formula

Liquid infant formula, made from water, raw milk, and demineralized whey, undergoes a high-temperature sterilization process to achieve commercial sterility. This product offers convenience features such as no need for powdered milk preparation, being ready to drink upon opening, and easy feeding.

II. Proposed amendments in the draft revision

The proposed amendments in the draft revision include amending the term "infant formula" in the Food Safety Law of the People's Republic of China to "infant formula (including liquid form)". It also mandates that the product formula for liquid infant formula be registered with the State Food Safety Supervision and Administration Department. Additionally, it prohibits the production of infant formula (including liquid form) through repackaging and disallows the use of the same formula by the same enterprise to produce different brands of infant formula (including liquid form).

III.Reasons for incorporating liquid infant formula into registration management

The reasons for incorporating liquid infant formula into registration management include ensuring the quality and safety of these products, thus protecting the health interests of consumers. Liquid infant formula, being highly perishable and nutrient-rich, demands stricter requirements for microbial control, stability, product packaging, and other production quality control compared to infant formula powder. In order to minimize food safety risks and ensure the health and safety of infants and young children, it is necessary to adopt at least the same or stricter management mode as infant formula milk powder, thus it is also necessary to implement registration management at the national level.

IV. Products/Parties that may be affected

According to the draft, there is no production of liquid infant formula in China at present, affected by the short shelf life, high price and eating habits of Chinese people, China's domestic market has not yet formed a scale, and commercially available products are imported. based on this, exporters or manufacturers of imported infant formula foods should pay special attention to the final trend of this revision.

V. Advice to interested parties

If you have already exported liquid infant formula to China, please continue to pay attention to the official release of regulations and future transitional policies for products already exported to China. Meanwhile, it is also necessary to simultaneously consider developing contingency plans to meet future registration management requirements, such as preparing documents (submitting formula research and development reports and other materials indicating the scientific and safe nature of the formula when registering products) and being responsible for the authenticity of the materials. Another important point is that if your company does not have a dedicated technical team to promote registration matters, it is necessary to consider entrusting a professional third party in advance. Foodmate happens to be a professional team that can provide registration services, with rich experience in the field of infant formula food registration, and has completed product registration for many well-known international enterprises.