36Evidence A

If you care about what’s in your food, buy pre-packaged products: loose goods at retail counters aren’t legally required to list ingredients

The law only mandates ingredient lists for pre-packaged foods; loose goods have no such requirement. For loose products, retailers only need to display the product name, production date, shelf life, and manufacturer details. So, the absence of any mention of additives does not mean they were not added — it simply means the law does not require them to be listed. If you care about what’s in your food, opt for pre-packaged versions where both the full ingredient list and additive details are clearly printed.

Cost

No cost at all. Pre-packaged versions of the same items ar…

Benefit

Article 67 of China’s Food Safety Law stipulates that all pre-packaged foods must carry a label containing nin…

Cost

No cost at all. Pre-packaged versions of the same items are usually a bit pricier than loose ones. Checking the ingredient list takes just a few seconds.

Benefit

Article 67 of China’s Food Safety Law stipulates that all pre-packaged foods must carry a label containing nine mandatory pieces of information. The second item on this list is the “list of ingredients or components,” and the seventh item is “the generic names of any food additives used, as defined in national standards.” Article 68 contains far fewer requirements for loose foods: it only requires retailers to display the product name, production date or batch number, shelf life, and the manufacturer’s name, address, and contact details on the packaging or container. There is no mention of ingredient lists or additives here. This distinction is most evident in frozen seafood products. GB 2760—2024 permits the use of phosphoric acid and phosphates as moisture retention agents — commonly referred to as water-retaining agents — in frozen seafood, with a maximum permitted usage level of 5.0 g/kg calculated as phosphate. Use within this limit is fully legal. The main issues arise from excessive usage and the practice of adding ice to increase product weight. Following a 2025 exposé by China Central Television’s 3·15 Gala, which revealed that some shrimp producers illegally added excessive amounts of water-retaining agents (composite phosphates) and added extra ice to boost weight, regulatory authorities mandated that all such products must clearly list water-retaining agents like phosphates, net weight (excluding ice coating weight), and full ingredient lists on their labels (this requirement applies nationwide, per the third 2025 amendment to China’s Food Safety Law, effective 1 December 2025).

Original sources

全国人大常委会 (2025 年第三次修正). 中华人民共和国食品安全法(第六十七、六十八条,2025 年 9 月 12 日公布,2025 年 12 月 1 日施行). https://flk.npc.gov.cn/detail?id=7b5a76d0461745a08d3f964916b87ef3;国家卫生健康委员会、国家市场监督管理总局 (2024). 食品安全国家标准 食品添加剂使用标准(GB 2760—2024,附录 A 表 A.1「磷酸及磷酸盐」项下食品分类号 09.02.01 冷冻水产品;A.3 规定表 A.1 列出的食品添加剂按照规定的使用范围和最大使用量使用). https://www.gov.cn/zhengce/zhengceku/202403/content_7001729.htm;六安市市场监督管理局 (2025). 关于水产制品及使用保水剂的相关企业提醒告诫函(2025 年 3 月 24 日). https://scjgj.luan.gov.cn/zwzx/tzgg/5414606.html

Open source link
Book note

The fact that additives are not listed on a product does not mean they were not added — it simply means the law does not require them to be disclosed. If you want to know exactly what a product contains, always choose pre-packaged versions. For frozen shrimp, fish fillets, and similar items, the net weight listed on pre-packaged packaging already excludes ice coating weight; using this figure to calculate unit price gives a much more accurate cost estimate. For loose products priced by weight, the actual edible weight after thawing may drop significantly. Water-retaining agents are legal and not a safety hazard as long as they are used within permitted limits — do not mistake them for toxic substances. Excessive usage and added ice are purely commercial issues: you end up paying a premium price for mostly water content. Conversely, loose goods counters may also fail to display the four mandatory details required by Article 68: product name, production date, shelf life, and manufacturer contact information. Failure to display any of these constitutes a violation of the law. Consumers can choose not to purchase such products or file a complaint via the 12315 hotline. For business owners looking to sell packaged foods, specific labeling requirements are outlined in Section 12, Article 9 of this guide. This item delivers the highest level of benefit to both you and your family.

My note