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How to distinguish between prepackaged food and

by:VIPUTRANS     2020-09-03
   Pre-packaged food is a concept often encountered in food safety supervision work. Accurately defining the connotation and boundaries of the definition of pre-packaged food plays a very important role in carrying out daily food safety supervision in accordance with the law. In regulatory practice, however, there are often situations where prepackaged food is confused with bulk food and naked food. Not only is it difficult for many ordinary consumers to correctly identify it, but even the manufacturer’s own understanding of this is very vague. Or there are different understandings within the regulatory authorities. A few days ago, the Ministry of Health of the People's Republic of China issued the 'GB7718-2011 National Food Safety Standard General Rules for the Labeling of Prepackaged Foods', which provides more detailed regulations on the definition of prepackaged foods, which will help us more accurately grasp the meaning of the definition of prepackaged foods.



The evolution of the definition of prepackaged food

   At present, the definition of prepackaged food mainly comes from 'GB7718-2004 General Rules for Prepackaged Food Labeling', 'Food Safety Law' and 'GB 7718-2011 National Food Safety Standard General Rules for Prepackaged Food Labeling'. GB7718-2004, which was implemented in 2005, defines pre-packaged food as 'food that has been pre-packaged, or packed (filled) in containers, and directly provided to consumers.' Article 99 of the Food Safety Law that came into effect in 2009 defines pre-packaged foods, that is, 'foods that are pre-packaged or made in packaging materials and containers.' GB7718-2011, which will be implemented in 2012, defines pre-packaged food as 'food that is pre-packaged or made in packaging materials and containers, including pre-quantity packaging and pre-quantity production in packaging materials and containers and a certain amount Foods that have a uniform quality or volume mark within the limits.'

   From the nuances of the above three definitions, we can see the evolution of the definition of prepackaged food. In GB7718-2004, two important features of prepackaged foods are emphasized, namely 'pre-quantity' and 'packaged or filled (filled) in containers', but a restrictive condition is made, that is, 'direct to consumers provide'. Regarding the two important features of pre-packaged foods, they have been confirmed in the subsequent Food Safety Law and GB7718-2011, and only 'packaged or filled (filled) in a container' is modified to be more accurate The expression 'wrapped or made in packaging materials and containers'. However, the restrictive conditions proposed in GB7718-2004 were cancelled. The “Food Safety Law” no longer stipulates the condition of “providing directly to consumers”, but GB7718-2011 further clarifies that “this standard applies to the labeling of prepackaged foods directly provided to consumers and indirect provision 'Pre-packaged food labels for consumers', 'not applicable to food storage and transportation packaging labels that provide protection for pre-packaged foods during storage and transportation, as well as labels for bulk foods and on-the-sale foods'. Obviously, in GB7718-2011, prepackaged food includes two forms, namely, prepackaged food directly provided to consumers and prepackaged food not directly provided to consumers.

Discrimination and Analysis of the Definition of Prepackaged Food

(1) The exact meaning of prepackaged food


   From the three definitions mentioned above, we can see that the so-called pre-packaged food has two fundamental characteristics, the first is 'pre-quantity', and the second is 'packaged or made in packaging materials and containers.' Processed foods that possess both of these characteristics are prepackaged foods. If any feature is not available, it will not be a pre-packaged food.



 From the three definitions mentioned above, we can also see that the pre-package actually describes a state in a specific situation, such as 'directly to consumers'. The evolution of the definition also shows that the requirements for the state of a specific situation have been cancelled, that is, pre-packaged no longer only refers to the state when sold to consumers, but also includes the state when sold indirectly to consumers. This is the definition of pre-packaged food A fundamental change in



(2) The connection and difference between prepackaged food and naked food

   We know that processed foods that meet the two characteristics of 'pre-quantity' and 'packaged or made in packaging materials and containers' at the same time are prepackaged foods, and any one of them is not prepackaged food. Foods that have the characteristics of 'packaged or made in packaging materials and containers' can be called packaged foods; correspondingly, foods that do not have the characteristics of 'packaged or made in packaging materials and containers' are naked. food. Packaged food and naked food industry are a pair of opposite concepts. Prepackaged food is definitely packaged food, but packaged food may not be prepackaged food. Prepackaged food is only a part of packaged food. The biggest feature of naked food is that there is no packaging. Obviously, pre-packaged food cannot be naked food.

In the past, many comrades had misunderstood the definition of prepackaged food in GB7718-2004. The 'or' in 'pre-packaged, or packed (filled) in a container, directly provided to consumers' is understood as pre-packaged food includes 'pre-packaged' food and 'filled (filled) There are two types of food in the container. This led to the error of understanding all packaged foods as prepackaged foods, and then the error of equating naked foods with bulk foods. In fact, the 'or' here refers to the choice of packaging form, either 'packing' or 'packing (filling) into a container' can be selected, but the premise is 'pre-quantity'. The introduction of GB7718-2011 clearly explained the definition of pre-packaged food, which effectively clarified past misunderstandings.



(3) The connection and difference between prepackaged food and bulk food

Regarding the definition of bulk food, my country currently has no laws, regulations or standards. The main basis is the 'Notice on Printing and Distributing the Sanitation Management Regulations for Bulk Food' issued by the Ministry of Health in 2003 (Health Law Jianfa [2003] No. 180). In this normative document, bulk food is defined as 'non-prepackaged food, food raw materials and processed semi-finished products, but excluding fresh fruits and vegetables, and raw grains that need to be cleaned and processed, fresh frozen livestock and poultry products, and aquatic products.'

Foods with 'pre-quantitative' characteristics can be called pre-quantified foods; correspondingly, foods that do not have 'pre-quantitative' characteristics are bulk foods. Bulk food refers to food that is sold by weighing, that is, food that is priced based on the basic unit of measurement without pre-determining the sales unit and sold directly to consumers. Pre-quantified food and bulk food are a pair of opposite concepts. Obviously, pre-packaged foods are pre-quantified foods, but pre-quantified foods are not necessarily pre-packaged foods. Pre-quantified foods also include unpackaged pre-quantified foods, and pre-packaged foods are only part of pre-quantified foods. The biggest feature of bulk food is that it is not 'pre-quantified.'

In the past, many comrades equated bulk food with naked food. In fact, this is also inaccurate. Nude packaging and bulk packaging are different categories and do not have the same identity. Naked food refers to unpackaged food, which is a concept corresponding to packaged food. Bulk food refers to food with no pre-determined quality or volume. It is a concept corresponding to pre-quantified food. The biggest feature of naked food is that it is not 'packaged or made in packaging materials and containers', while the biggest feature of bulk food is that it is not 'pre-quantified.' Bulk food can be packaged, such as candy sold in pieces; or unpackaged, such as rice sold in pieces. The presence or absence of packaging is not a sign that distinguishes pre-quantified food from bulk food. There is an intersection between naked food and bulk food. Unpackaged bulk food is naked food, and packaged bulk food is not naked food.

Grasping the definition of prepackaged food in practice




(1) Accurately grasp the status of pre-packaged food
We have noticed that the so-called pre-packaged food is a state under certain circumstances. From GB7718-2004 to GB7718-2011, the most significant change in the definition of pre-packaged food is the removal of the restrictive condition of 'providing directly to consumers.' Before the formal implementation of GB7718-2011, the pre-packaged food we refer to refers to the pre-packaged food when it is directly provided to consumers, that is, when selling to consumers, if a certain food is pre-quantified and packaged, then it is Pre-packaged food. After the formal implementation of GB7718-2011, pre-packaged food not only includes pre-packaged food directly provided to consumers, but also pre-packaged food indirectly provided to consumers. Pre-packaged food no longer only refers to the state when it is sold to sellers. In any state, as long as a certain food is pre-quantified and packaged, it can be regarded as pre-packaged food. Of course, pre-quantification also needs to comply with the requirement of 'a uniform mass or volume mark within a certain limit of quantification'.



(2) Accurately grasp the concept of pre-quantitative
Pre-quantitative means to have a certain amount after packaging. According to GB7718-2011, the determined value should be 'have a uniform mass or volume mark within a certain quantitative limit', that is, its value is uniform. If a company has packaged its products and marked the net content after weighing, but the net content is not uniform, there are 0.5kg, 0.6 kg or 0.7kg, then they are still not prepackaged foods, or bulk foods .



(3) Accurately grasp the scope of application of GB7718
GB7718 is a technical regulation on the labeling of prepackaged food. We noticed that GB7718-2004 regulates the labeling of pre-packaged food directly to consumers, but GB7718-2011 has been expanded to include all pre-packaged foods. In particular, although some food production enterprises produce bulk foods, when they are sold in large packages that are pre-quantified and 'have a uniform quality or volume mark within a certain quantitative limit', the labels on the large packages should comply with the indirect provision Labeling requirements for prepackaged foods for consumers.

GB7718-2011 also states that the standard “does not apply to food storage and transportation packaging labels that provide protection for pre-packaged foods during storage and transportation, as well as the labeling of bulk foods and ready-made foods for sale”. Therefore, in these three cases, it does not apply. Implement GB7718-2011 regulations.

In addition, Chapter 5 of the 'Agricultural Product Quality and Safety Law' 'Agricultural Product Packaging and Labeling' has made special provisions on the packaging and labeling of edible agricultural products. The Ministry of Agriculture has also formulated the 'Agricultural Product Packaging and Labeling Management Measures' (Ministry of Agriculture Order No. 70 ). Therefore, the labeling of edible agricultural products does not comply with the provisions of GB7718-2011.



(4) Accurately grasp bulk food
  From the perspective of the manufacturer, all products should be packaged when they leave the factory. According to the interpretation of the 'Product Quality Law' by the Legislative Affairs Committee of the Standing Committee of the National People's Congress, 'The so-called'product packaging' refers to products used in accordance with certain technical methods to protect products and promote sales during product transportation, storage, and sales. The general term for the operation activities carried out on containers, materials and attachments with relevant marks attached to the packaging.' According to this interpretation, the purpose of packaging food is for transportation, storage, and sales. We know that the production form of food production enterprises is centralized production, and distributed sales to consumers through the circulation link. This form of production and operation is different from doing and selling, and also different from the catering link. The main characteristics of making-to-sell are on-site production, on-site sales, and direct to consumers; the main characteristics of the catering link are on-site production, on-site sales and on-site consumption. Therefore, naked foods can be allowed to exist in the ready-made and catering links. Since most of the products of food production enterprises need to be provided to consumers through transportation, storage, sales, etc., according to law, food must be protected from external pollution during transportation, storage, and sales. Therefore, the products of food production enterprises must be There are packaging.

Of course, this packaging can be pre-packaged or transport packaging. Pre-packaged food is of course packaged, and bulk food should also be transported. The 'General Rules for Food Quality and Safety Market Access Review (2004 Edition) Practical Instructions' pointed out that 'the food produced in food production and processing enterprises is packaged, some are pre-packaged, and some are transported. As long as there is a large transport package, it should be carried out. Labeling. If a food production and processing enterprise loads the produced food into a tanker, container or transfer box for transfer, it shall provide a food label and corresponding food inspection report'. The Ministry of Health's 'Notice on Printing and Distributing the Hygiene Management Regulations for Bulk Food' (Weifa Jianfa [2003] No. 180) also stipulates that special transportation vehicles must be used to transport bulk food and transported in a state that meets the food storage conditions; Food must be sealed and packaged with packaging materials and containers that meet the requirements of hygienic standards.

In the process of food production and processing, all food sold at the factory is packaged (including pre-packaged and transport packaged). Packaged pre-quantified food is pre-packaged food. Therefore, we can further simplify the opposition between pre-quantified food and bulk food into the opposition between prepackaged food and bulk food.

There are two sources for the production of bulk food. One is the widespread dismantling of zero sales in the circulation. For example, 100kg/bag of rice is a pre-packaged food for the production company when it leaves the factory; but after the distribution company dismantles it, the rice will no longer appear in a pre-quantified form, but will be converted into bulk food. In this case, food production and processing enterprises should mark the label information on the outer packaging of their products in accordance with the provisions of GB7718. Circulation enterprises should do a good job of labeling in accordance with the regulations on labeling in the sale of bulk food in the Food Safety Law and the requirements of the documents of the Ministry of Health.

The second is bulk food delivered in packaging. There are two situations here, one is to leave the factory in a pre-quantified bulk package. Although the bulk package contains bulk food, the bulk package itself still meets the definition of prepackaged food that is not directly provided to consumers in GB7718-2011. Therefore, the label of the bulk package must still comply with the provisions of GB 7718-2011. The second is to leave the factory in non-pre-quantified bulk packaging. At this time, the bulk package contains bulk food, and the bulk package itself does not meet the definition of prepackaged food that is not directly provided to consumers, so it is only a transport package, and its label should be marked in accordance with the regulations of the Ministry of Health. In the above two cases, if the bulk food contained in a large package is packaged, the label on the package should also be marked in accordance with the regulations of the Ministry of Health.
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