Three overlooked gaps after the transition away from the QS mark for food packaging—three hidden risks in 2026 when printers receive new food orders but continue printing the old QS mark

In August 2026, a printing factory in Wuxi that produces pastry packaging received an order from a local long-established pastry shop: 5,000 kraft paper gift boxes. The design file sent by the customer featured the “QS + 12 digits” mark. Believing that this was “a long-standing customer, so let’s just print it,” the printing factory’s sales representative gave the matter little thought and started production.

As a result, when the goods arrived at the customer’s store, the market supervision bureau immediately noticed the QS mark during its spot inspection. Since October 2018, QS had been discontinued and replaced with SC. The QS mark printed on the newly produced packaging directly led to the packaging being deemed “non-compliant.” The market supervision bureau not only penalized the pastry shop but also summoned the printing factory for an interview, requiring it to recall the batch of packaging and submit a corrective action report.

The printing factory owner feels greatly wronged: “The QS mark was included in the customer’s artwork; it was not added by our printing factory without authorization.” However, the market supervision authority replied that printing enterprises have a “primary review obligation” regarding packaging compliance. If the artwork provided by the customer is obviously non-compliant, and the printing factory neither issues written notice nor refuses to print it, it must bear joint liability.

This is not an isolated case. In spot inspections conducted by the market regulation authorities in Wuxi, Suzhou, and Changzhou in 2024-2025, a total of 11 cases were found in which food packaging still displayed the abolished QS mark. In 7 of these cases, the printing companies involved were also penalized.

The QS mark transition has been underway for 8 years, so why is it still appearing in 2026? Because many packaging designs from established brands have been carried over from 2017 or even earlier, and the design departments did not keep track of policy changes, so they continued to include the QS mark in their designs. As the “printing professionals,” the printing plants ended up becoming the “fallback bearers” for clients whose design departments had failed to keep up with the policy.

Category 1 omission: The customer’s artwork still contains the "QS + 12 digits"—the printing plant failed to notice it

The correct format for the QS mark is “QS + 12 Arabic numerals,” representing a 12-digit enterprise license number. However, after October 2018, newly established food enterprises are no longer issued QS certificates and instead use “SC + 14 digits.”

During plate-making, printers typically focus only on color, dimensions, and fonts, and seldom check whether the “QS” has been abolished. As a result, if the customer’s artwork still contains the QS, the printer will simply print it as is.

Real-world case: A certain pastry brand continued using a gift box design from 2016, and the QS mark in the artwork was never updated. The printing plant produced 50,000 units every year for 7 years, until the product was selected for inspection by the market supervision authority in 2024, at which point it was discovered that 350,000 non-compliant packages had been printed over the 7-year period. The final recall costs were shared equally, with the printing plant and the brand each bearing 50%.

The print shop's response: add a "compliance check" to the prepress stage—after the print shop's design/prepress personnel receive the customer's files, they first spend 30 seconds reviewing them against the "Food Packaging Compliance Checklist": Is the QS mark present? Does the SC number have the correct number of digits? Is the allergen label included? Is the net content printed at the required font height? If any non-compliance is found, the files are returned directly to the customer.

Type 2 Error: Incorrect Number of Digits in the Customer's SC Number—the Printing Factory Printed 13-Digit SC Numbers Based on the Artwork

The correct format of the SC mark is “SC + 14 digits.” However, among the new food orders received by the printing plant in 2026, approximately 5% of customers’ manuscripts use a 13-digit or 15-digit SC number—the customer’s design department either wrote the 14 digits incorrectly or continued using an outdated version without updating it.

When the printer’s technician saw the “SC” marking during plate preparation, he assumed that the customer was compliant and did not count the number of digits. After printing, the market supervision bureau found that the number of digits in the SC number was incorrect, and the printer had to bear responsibility.

Real case: In 2025, a printing plant in Suzhou received a packaging order for a nut brand. The SC number in the artwork had 13 digits. The plant printed 8,000 units based on the artwork, but a spot check by the market supervision authority found that the number of digits in the SC code was incorrect. The printing plant was called in for questioning and fined 15,000 yuan.

Printer response: add an “SC number digit-count self-check” to the plate-making process—after receiving the food packaging artwork, the printer’s plate-making personnel mark the SC number directly on the artwork and count the digits; if it is not 14 digits, it is returned directly to the customer.

Type 3 Oversight: Old Inventory Packaging Mixed with New Orders—the Printer Failed to Distinguish “Stock” from “Newly Printed”

By 2026, many food brands may still have packaging in their warehouses that was produced between 2020 and 2023. This packaging bears the QS mark (packaging produced before October 2018 may still be used). If a customer sends old inventory together with new orders to the printing plant for reprinting and the plant fails to distinguish between them, errors are likely to occur.

Real case: In 2025, a printing factory in Changzhou received a “supplementary order” from a snack brand—the customer said, “There are still 2000 left from the previous run, so print another 3000 this time.” The factory printed 3000 units according to the customer’s artwork, but the “production date format” corresponding to the SC number in the artwork was inconsistent with the QS packaging in stock. During an inspection, the market supervision authority found mixed batches and determined that the “packaging date labeling was disorganized,” resulting in a fine of 20,000 for the printing factory.

The printer’s response: Before printing each batch of food packaging, the printer’s sales/planning department asks the client, “Is this a new order or a replenishment order? Will any existing inventory be mixed in?” and records the answer on the production order. When the warehouse dispatches the goods, it separately identifies “inventory packaging” and “newly printed packaging,” preventing the two from being mixed into the same customer order.

Printing Plant “Food Packaging Compliance Self-Inspection Checklist” (Ready for Direct Copying)

After the printing sales or prepress team receives the food packaging design draft, they should scan these 5 items within 30 seconds:

If any of these 5 items is noncompliant, the printing plant must notify the customer in writing and retain evidence (WeChat screenshots/emails), rather than quietly making corrections and continuing production.

How to Respond After Being Interviewed by the Printing Plant

If the printing plant has already been summoned for a talk by the market supervision administration (similar to the pastry shop case), there are 3 things the printing plant should do:

Item 1: Immediately recall the shipped packaging and negotiate cost-sharing with the customer (if the customer's copy is non-compliant, the customer bears primary responsibility)

Item 2: Submit a corrective action report including “A compliance self-inspection checklist has been established + A compliance review has been conducted on all customer drafts”

Item 3: Issue a "Compliance Notice Letter" to the customer, requiring the customer to confirm that subsequent design drafts are compliant and retain evidence

If the printing plant properly handles these 3 items, it can basically avoid penalties of more than 50,000.

The True State of the QS Logo 8 Years After the Transition

When QS exited in October 2018, the industry expected the old inventory to be “fully digested within 1-2 years.” However, the situation in 2026 is as follows: the designs of old brands have not been updated, and the QS mark is still being used; the SC numbering formats of new brands are inconsistent, with the occasional digit-count error; and regulatory spot checks have become increasingly stringent. As of 2025, “joint liability for printing enterprises” has been incorporated into the spot-check procedure.

Printing plant owners must recognize that food packaging compliance is no longer solely the customer's responsibility; it is a shared responsibility of both the printing plant and the customer. By adding a 30-second self-check at the plate-making stage, the printing plant can avoid the vast majority of risks.

Further Reading