Three Practical Boundaries of Nutrition Claims on Food Packaging — GB 28050 Content Claim Thresholds / “0 Sugar” Labeling Rules / Localization Responsibilities for Imported Formulas: The First 3 Figures a Printer Should Verify When Receiving a “Add a High-Protein Label” Order

In April 2026, a client producing meal-replacement milk powder approached us to print 12000 boxes for a new gift set.

The design draft contained the wording: “0 Sugar High Protein Nutrition Meal Replacement”.

We sent the draft back. The client was confused: “There really is no added sugar in the formula. Why can’t we print it?”

What the client meant by “no added sugar” was no added sucrose, but the formula contained lactose, maltodextrin, and inulin. Whether sugar counts on the nutrition label depends on the mono- and disaccharide portion of available carbohydrates. This is not a calculation the printer can make, but the printer must understand what the client means by “0 sugar.”

This article explains three boundaries: how claim thresholds are calculated, the difference between “0 sugar / sugar-free / no added sugar,” and who is responsible for recalculating imported formulas entering China.

The First Boundary: Content Claims Have Hard Thresholds—Missing the Limit by 0.1 Means Failure

First, establish the framework. In China’s nutrition labeling system, claims are divided into two categories: content claims, such as low sugar, high protein, high dietary fiber, and low sodium; and function claims, such as helping enhance immunity and helping lower blood lipids.

These categories have entirely different implications for printers: content claims are supported by numerical values. The printer must ensure that the client prints these values on the package; otherwise, the claim itself does not hold.

The most common problem is treating “Low Sugar” and “Sugar-Free” as the same thing. Suppose the client’s product is sugar-free, but the design says “Low Sugar.” This is compliant as a “Low Sugar” claim, but it wastes a product advantage: the product actually meets the sugar-free threshold but carries a weaker claim. Conversely, if the product is low sugar at 4.2g/100g but the design says “Sugar-Free,” this is no longer a typographical error; the labels on the entire batch are non-compliant.

Therefore, our practice is: add a field for “claim and corresponding value” to the prepress checklist. The client must provide both, and the file is rejected if either is missing. This is what we tell clients: “You give me a claim, and I need a number to support it. Both numbers must come from the same test report. One cannot come from the formula while the other comes from actual testing.”

There is also a more hidden pitfall: the criteria for a claim follow the test method. Sugar, fat, and protein each have designated testing methods, and different methods may produce results that differ considerably. When a client provides a laboratory report, we do not look only at the values; we also need to determine whether the formula used for this order and the submitted test sample are the same. A common reason for a 0.1g difference is that the submitted sample and the production batch did not use the same raw-material batch.

Our response is: “The formula is the same, but the milk powder batch is different, and the lactose content can differ by 0.3g. This is not about who is right or wrong; a new shipment occurred between the testing day and the production day.”

The Second Boundary: “0 Sugar,” “Sugar-Free,” and “No Added Sugar” Are Three Different Concepts

This boundary produces the most frequent misunderstanding in client communication and is also the most expensive.

Under the regulations, these three terms mean three different things:

• Sugar-Free: This is a content claim with a criterion of sugar content ≤ 0.5g/100g. It means that the product contains little sugar. It may contain sugar substitutes and may contain lactose, provided the total remains within the threshold.
• No Added Sugar / 0 Added Sugar: This is a rule governing ingredient-list and nutrition-label wording. It means that no additional sucrose or added sugar was introduced during production. It does not mean that sugar content is low—sugar naturally present in ingredients, such as lactose, fructose, and maltose, still counts toward the sugar line of the nutrition facts table.
• “0 Sugar”: These four characters are not an official claim term. They are market language. The regulations provide no threshold for “0 sugar,” so the wording must be interpreted as either “Sugar-Free” or “No Added Sugar”—and these have vastly different meanings.

This is why we returned the design draft. Without supporting numerical values, the eight characters in “0 Sugar High Protein” make it impossible to determine which claim the client intends.

Our rejection notice was specific:

“‘0 Sugar’ must be changed to one of the following:

(1) ‘Sugar-Free’ + sugar content ≤ 0.5g/100g in the nutrition facts table, and the product must not claim sweet flavor;

(2) ‘No Added Sugar’ + truthful declaration of sugar content in the nutrition facts table, with no added-sugar ingredients appearing in the ingredient list.

Please have the client confirm one option in writing and provide the corresponding test data.”

Correct. “High Protein” is a content claim, and the package must simultaneously state the protein content and NRV percentage. Our checklist follows this logic: whenever a content-claim term appears in the claims field, there must be a corresponding value; whenever a function-claim term appears, there must be a complete “helping XXX” expression and strict qualification conditions. Function claims have stricter requirements than content claims and cannot be satisfied by merely adding a sentence.

There is also a related rule every printer must know: when a product makes a “Low Sugar” or “Sugar-Free” claim, claims related to sweetness are restricted. A common client error is printing both “0 Sugar” and “sweet and fragrant taste.” The key issue is whether the latter is a sensory description or a claim, determined by whether it implies a source of sweetness. If it implies that sugar was used, the claim conflicts.

The Third Boundary: When an Imported Formula Enters China, the Translation Issue Becomes a Recalculation Issue

This boundary is most common in export-to-domestic-sales and imported barcode orders in 2026.

A client provides a packaging design for an overseas market and asks us to “make a Chinese version based on this.” On the surface, this is a translation task, but in reality three elements must be redone:

Of these three elements, claims are the most likely to cause problems, because they appear correctly on the overseas package and also appear to be fine after translation.

There was a real case in March 2026: an importer of snacks had an overseas package labeled “High Protein” at 18g per 100g and needed a Chinese version for sale in China. At 18g/100g, the corresponding NRV is approximately 30%, which meets the threshold for “High Protein.” However, the client also wanted to claim “Low Fat.” Fat measured in the overseas version was 3.1g/100g, which barely met the low-fat threshold, while China’s low-fat threshold is 3g/100g, which it missed.

We removed the words “Low Fat” and changed them to a truthful statement of fat content. The client’s sales representative asked: “Does a difference of 0.1g really matter?”

Our response was: “The threshold is the threshold, and 0.1g is 0.1g. When imported products are spot-checked in domestic sales channels, the first thing checked is whether the claims match the values.”

Another common client question is: “Can the labels for imported foods retain the layout used in the original overseas market?”

No. Labels on imported prepackaged foods must be in Chinese, and the labels themselves must comply with China’s mandatory requirements, including the nutrition facts table, claim rules, allergen declarations, and all items under general labeling requirements. Foreign-language text may be retained, but Chinese-language labeling must fulfill the mandatory Chinese labeling obligations. The printer’s action on this issue is clear: we produce the Chinese label layout, while the original overseas version is used only as a reference.

The 3 Sets of Figures to Verify First When Accepting a Nutrition-Claim Order

In practice, for every order involving claims, we require three sets of data before printing and do not proceed with layout if any set is missing:

• Set 1: Claim terms and corresponding values. Each content claim must be paired with a value per 100g / per 100ml / per serving, and each function claim must be paired with a complete expression and qualification conditions. The values must come from a test report using the same formula and the same raw-material batch as this order, not from a previous batch and not from theoretical values supplied by a supplier.
• Set 2: Compatibility conclusions between claims. Conflicts between sugar-related claims and sweetness wording, whether content and function claims can coexist, and conflicts involving low sodium or foods for special populations—all of these combinations must be checked one by one.
• Set 3: Label-system classification. Determine which category of prepackaged food the product is managed as under Chinese rules, including whether it is a food for special dietary use and whether it falls within the permitted scope of nutrient fortification. This determines whether the general food rules or the rules for foods for special dietary use apply, and the permitted scope of claims for foods for special dietary use is clearly narrower.

The client’s final remark is usually: “You’re just printing a box. We’ll handle the label ourselves when we sell it.”

Our response is: “We create the layout. If the layout is non-compliant, the printed box becomes a non-compliant product. Legally, the label is the one that enters the market that gets checked, regardless of who designed the layout. So we need these three sets of figures, and the client must provide them.”

There is also a more practical point: claims are among the few packaging fields that can add value when printed correctly. A label crowded with compliance statements will not attract another glance, but a statement such as “20g protein per 100g” or “0 sucrose” is far more recognizable on the shelf than a long ingredient list. The problem is that when such a statement is printed incorrectly, the consequences go beyond returns—they can lead to a product recall. Therefore, it is better for the printer to ask one more question.

Further Reading

• 6 Types of Mandatory Food Packaging Labels—Ingredients / Allergens / Shelf Life / Nutrition Facts / Net Content / Origin—Claims are a set of rules connected to the nutrition facts table, while the article on basic mandatory labels covers the required elements.
• 5 Regulatory Red Lines in Food Packaging Design—Labels / Warnings / Allergens / Nutrition / Net Content—This article explains how violations of nutrition requirements are penalized.
• A Clear Guide to the GB 4806 Series—Material requirements and labeling requirements are two separate systems, yet clients often ask about them together.
• 3 Types of Genuine Compliance for Packaging Exported to Brazil—The same food-labeling logic applies, but ANVISA uses different thresholds.