Imported Food Labeling Requirements in Taiwan: Chinese Labeling, Nutrition Labeling and Common Pitfalls

For imported food to reach retail shelves in Taiwan, labeling compliance is the first review checkpoint. Article 22 of the Act Governing Food Safety and Sanitation (食品安全衛生管理法) sets out ten mandatory labeling items, and subordinate rules on nutrition labeling, juice product names and mark-based claims interlock with it layer by layer. The notes below cover four areas — the Chinese labeling obligation, nutrition labeling format, juice product name rules, and the handling of imported marks — and collect the omissions most often seen in practice, for reference by retail buyers and overseas brand owners.

1. Chinese Labeling Obligations for Imported Food

Under Article 22, Paragraph 1 of the Food Safety Act, prepackaged food (including imported goods) shall be conspicuously labeled in Chinese and commonly used symbols with the following ten items: product name; names of the contents (in descending order of content); net weight, volume or quantity; names of food additives (sweeteners, preservatives and antioxidants must also carry their functional name); the name, telephone number and address of the manufacturer or the domestic responsible firm (imported goods must show the importer’s details); country of origin (determined by the place of final processing, with beef additionally requiring the country of slaughter); expiration date (which must be printed and may not be affixed separately); nutrition labeling; whether genetically modified food ingredients are present; and other items announced by the central competent authority — allergen advisory statements fall under the announcement delegated by this last item.

Allergen labeling requirements took effect on July 1, 2020, expanding the mandatory list from the 6 items under the previous rules to 11 (crustaceans, mango, peanuts, milk from cattle and goats, eggs, tree nuts, sesame, gluten-containing grains, soybeans, fish, and sulfites/sulfur dioxide where the residual level reaches 10 mg/kg or more). A common omission is carrying over the brand owner’s overseas labeling (the EU’s 14 items, for example) without checking it against Taiwan’s 11 — soybeans being one of the main differences. Most importers close the gap by applying a Chinese-language label sticker to supply the information above.

2. Key Points on Nutrition Labeling Format

The Regulations on Nutrition Labeling for Prepackaged Food Products (包裝食品營養標示應遵行事項) require 8 mandatory nutrients: calories, protein, fat (including saturated fat and trans fat), carbohydrate (including sugars), and sodium. The format shall present two columns, “per serving” and “per 100 g (or mL)”, or a single “per serving” column annotated with the percentage of the daily reference value; the number of servings per package must be stated at the same time.

Units are an easy place to go wrong in practice: solids are labeled in grams (g) and liquids in milliliters (mL); semi-solids (such as mayonnaise and peanut butter — viscous products that do not flow freely) follow the solid convention and are labeled in grams. The Chinese label must convert to metric units and may not carry over ounces (oz).

Numeric disclosure has thresholds as well: fat and sugars reaching 0.5 g or more per 100 g (or mL) must be shown as actual values, and below that threshold may be labeled “0”; the equivalent threshold for sodium is 5 mg per 100 g (or mL); trans fat uses 0.3 g per serving as the zero-claim threshold. The base unit differs from one threshold to the next, so this needs attention. Imported prepackaged food almost never falls within the situations exempt from nutrition labeling (such as a smallest-package surface area of 100 square centimeters or less with no claims made, or fresh agricultural produce), and complete nutrition labeling shall still be prepared.

3. Juice Product Name Labeling Rules

The Regulations on the Labeling of Prepackaged Beverages Claiming to Contain Fruit or Vegetable Juice (宣稱含果蔬汁之市售包裝飲料標示規定) use a total fruit and vegetable juice content of 10% as the dividing line for product names and labeling. Products at 10% or above may use “juice” as the product name, but must conspicuously state the juice content percentage on the front of the outer packaging (for example, “juice content 20%”). Products below 10% may not be labeled “juice” or with wording of equivalent meaning; the product name shall instead use terms such as “flavor” or “flavored” (for example, “orange-flavored beverage”), and the front must state “fruit (vegetable) juice content less than ten percent” or wording of equivalent meaning.

Whether the product name discloses every type of fruit and vegetable is separately regulated: where the product name already lists all fruit and vegetable names, they shall be labeled in descending order of content; where not all are disclosed, wording such as “mixed juice” or “blended juice” must be added, so that consumers do not misread the actual composition.

CNS 2377 (the national standard for fruit and vegetable juice beverages, last revised January 5, 2023) divides products into four categories — pure natural juice and juice from concentrate (both requiring 100% juice content), juice (≥10%) and juice beverage (<10%) — and sets reference values for soluble solids (°Brix) for each type of juice.

4. Principles for Handling Imported Marks and Claims

Article 28 of the Food Safety Act provides that food labeling and advertising shall not be false, exaggerated or likely to mislead; this is the overarching principle for all voluntary claims, whether or not they carry official certification. In practice the assessment can follow three steps: first, confirm whether Taiwan has a corresponding statutory certification system (organic, for instance, is governed by a dedicated act); if there is no dedicated act, verify whether the substance of the claim is true and, where necessary, obtain supporting documents from the supplier; finally, assess whether the Chinese sticker needs to translate that claim at all.

Take the Non-GMO (非基因改造) claim as an example. Under Article 4 of the applicable labeling regulations, only ingredients for which commercialized genetically modified varieties already exist internationally (such as soybeans, corn, cottonseed, canola and beet sugar) may be labeled “non-genetically modified”; wheat, rice, oats and others with no commercialized genetically modified varieties may not make the equivalent claim. For marks such as Gluten-Free and Fair Trade, Taiwan has no corresponding statutory certification system, but the claim must still be true and the relevant certification held (where applicable) before the brand owner’s original labeling may be retained.

Common Pitfalls at a Glance

• Expiration date affixed as a sticker rather than printed
• Additives listed by name only, omitting the functional name for sweeteners, preservatives and antioxidants
• Carrying over the brand owner’s overseas allergen labeling without checking it against Taiwan’s 11 mandatory items (soybeans in particular)
• Fruit and vegetable juice content below 10%, yet the word “juice” still appears in the product name or on the packaging
• Mixed juice labeled with only some of the fruit names, without adding “mixed” or “blended”
• Claiming “non-genetically modified” for ingredients with no commercialized genetically modified varieties (wheat, for example)
• Carrying over customary liquid units (such as ounces) without converting to the metric units Taiwan requires

The points above cover only common situations; for any specific case, checking item by item against the product’s ingredient list is still recommended.

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This article is a general reference, not legal advice; for actual applications, refer to the latest announcements of the Taiwan Food and Drug Administration (衛生福利部食品藥物管理署).