In November last year, China’s State Administration for Market Regulation (SAMR) implemented new regulations to govern the local ‘excessive packaging’ phenomenon in conjunction with the local Ministry of Industry and Information Technology (MIIT), with enforcement to take place starting September 1 2023. These regulations were applied for 31 food product categories from grains to beverages to biscuits and more, as well as 16 cosmetics categories including hair care and toothpaste.
Recently, MIIT published a set of draft regulations suggesting that the standards be kicked up a notch for festival-related food items such as mooncakes (for the annual Mid-Autumn Festival) and rice dumplings (for the annual Dragon Boat Festival), specifically reducing the number of packaging layers for these from four to three.
Under the ‘Requirements of Restricting Excessive Packaging – Foods and Cosmetics’ law, all packaged grains and grain-based products are already limited to three layers of packaging (e.g. for a wheat biscuit the first layer can be the wrapping around one biscuit, the second layer can be the wrapping around the total number of biscuits in the overall pack, and a final third layer with the product brand name can be added as an outer layer), but this was not specified for festive items, which could lay claim to being in the ‘other’ category.
“This amendment clearly states that only three layers of packaging are permitted for mooncakes and zongzi (rice dumplings), and manufacturers also need to ensure that the total packaging costs for all packaging (excluding the innermost packaging that is in contact with the food item) does not exceed over 20% of the product’s overall retail pricing,” MIIT said via a formal statement.
“All manufacturers of these products must also note that the use of precious metals and stones [gold, silver, rubies] or luxury materials such as mahogany are not permitted for usage in the packaging of mooncakes and zongzi.
“In order to avoid complications, mixed packaging for these items are also not permitted – so it is not permitted for mooncakes to be packaged together with other retail items; nor for zongzi to be packaged together with any other retail items that have a higher retail value within the same package.”
These amendments are expected to be implemented on August 1 2022, even sooner than the provisions for general processed foods and other food categories on September 1 2023. This is likely to make it in time for this year’s Mid-Autumn Festival on September 10 2022, and due to the seasonal production and selling of these items.
“All mooncakes and zongzi produced prior to the date of enforcement can continue to be sold on shelves until the expiry date is hit,” MIIT said.
Major implications for Chinese manufacturers
One of the main implications here for F&B manufacturers in China is that mooncakes are no longer able to be made part of ‘Mid-Autumn Festival sets’ where mooncakes might be packaged with other traditional items commonly consumed for the festival such as pomelo, lingjiao (buffalo nuts), nuts or alcohol to be sold as a set. There are similar connotations for rice dumplings, although the other traditional food items (e.g. glutinous rice cakes, tea eggs, etc.) are usually lower-priced.
As such, the impacts are not expected to be limited to only mooncake or rice dumpling producers, but all Chinese firms that either make, purchase or partner with other firms to launch relevant festive sets for retail during the festival season.
The other major implication is the inability for mooncake and rice dumpling producers to heavily promote their mooncakes or rice dumplings using luxury or premium packaging, which would normally be a major factor of interest for consumers in the price and brand-conscious Chinese market.
The government’s aim to implement frugality in the packaging may however push for these manufacturers to make improvements in other areas from marketing to product innovation in order to draw consumers back in based on product quality – which would be a good thing in the long run.
