China’s prepared food standard open for consultation: No preservatives, max 1-year shelf life

    The National Health Commission today released the “National Food Safety Standard for Pre-cooked Meals” (Draft for Comment) (hereinafter referred to as the “Standard”) for public consultation.

    The food safety standard for pre-cooked meals primarily aims to safeguard consumer dietary health and regulate the high-quality development of the pre-cooked meal industry. It focuses on establishing provisions for pre-cooked meal products from the perspectives of food safety and nutritional health:

    On one hand, they strengthen source and process management by proposing control measures for potential risk factors and critical control points across the entire chain—from raw materials, production and processing, product packaging, storage and transportation, to operation and sales.

    On the other hand, for the final pre-cooked meal products, the Standards systematically integrate over 10 existing general standards (such as the “Limits for Contaminants in Foods”), over 10 product standards (such as the “Animal-Based Aquatic Products”), the “General Hygiene Specifications for Food Production,” and over ten standards for food-related products and testing methods, such as those for food contact materials. This integration establishes safety control indicators for pre-cooked meals based on different ingredients and processing methods, facilitating implementation by manufacturers.

    The key content of the standard for public comment includes:

    First, it reasonably defines the scope and management framework for pre-cooked meals. Based on food safety risk analysis principles and interpretations of relevant policies from the six-department Notice, the standard further clarifies the concept of pre-cooked meals. It specifies that pre-cooked meals do not include: staple foods, pre-washed vegetables, ready-to-eat foods, or dishes prepared in central kitchens. These food categories are regulated by other corresponding national food safety standards.

    Second, it emphasizes strengthened management of food contaminants and additives. The standard sets control requirements for key risk factors in pre-cooked meal products, including lead, chromium, benzo[a]pyrene, and pathogenic microorganisms. It also reinforces the management of food additive usage, stipulating principles for their application. Beyond prohibiting preservatives, it mandates minimizing additive use whenever possible, strictly controlling permissible additive types, and adhering to the principle of “add only when necessary.”

    Third, the standard emphasizes maintaining nutritional quality. It requires avoiding overcooking during preparation, utilizing advanced technologies or equipment to maximize retention of raw material nutrients and minimize nutrient loss, and encourages controlling the addition of cooking oil, salt, and sugar during processing. Additionally, manufacturers are required to reasonably set shelf life while ensuring food safety, taking into account multiple factors including nutritional quality.

    Fourth, the standard provides relevant consumption guidance. To ensure proper consumption, the standard mandates clear labeling of consumption methods for pre-processed cooked products and pre-processed uncooked or partially cooked products. This prevents foodborne illnesses from insufficient heating of uncooked or partially cooked items, or excessive heating that compromises nutritional quality and taste.

    Why are these food categories not classified as pre-cooked meals?

    The scope of pre-cooked meals—what is and isn't included—remains a public focus. The standard clarifies that pre-made dishes are pre-packaged meal products made from one or more edible agricultural products and their derivatives. They may or may not use seasonings or other additives, contain no preservatives, and undergo industrial pre-processing (such as mixing, marinating, tumbling, shaping, stir-frying, deep-frying, baking, boiling, or steaming). They may or may not include seasoning packets and require heating or cooking before consumption.

    Pre-cooked dishes exclude: staple foods, pre-cleaned vegetables, ready-to-eat foods, and dishes prepared in central kitchens. According to experts involved in drafting the standard, the exclusion criteria were based on several considerations:

    First, pre-cooked dishes must possess the characteristics of a cooked meal. Therefore, staple foods were excluded from the standard, as they are already regulated and standardized by corresponding national food safety standards.

    Second, pre-cooked meals must undergo “industrial pre-processing.” Pre-washed, peeled, or portioned vegetables that retain their fundamental raw material properties remain classified as food ingredients, hence excluded from the standard. Such products are regulated by separate national food safety standards.

    Third, pre-prepared dishes must require heating or cooking before consumption. Thus, the standard excludes ready-to-eat foods (e.g., pre-packaged ham sausages or pickled chicken feet that require no reheating or cooking before eating). Ready-to-eat foods are governed by applicable national food safety standards.

    Fourth, pre-cooked meals must possess the attributes of pre-packaged products. Food products or semi-finished goods produced by central kitchens in compliance with regulations are distributed exclusively to their own chain restaurant outlets. Therefore, central kitchens are essentially “internal centralized processing and distribution centers for chain restaurants,” equivalent to the kitchens owned by individual outlets. Consequently, dishes prepared by central kitchens are not included in the scope of pre-cooked meals (except when the central kitchen uses externally purchased, industrialized, ready-made pre-cooked meal products). Central kitchens must adhere to food safety regulations and standards applicable to the catering sector, such as the National Food Safety Standard: General Hygiene Specifications for Catering Services.

    The maximum shelf life for pre-prepared meals should not exceed 12 months.

    The standard also specifies requirements for the shelf life of pre-prepared meals. According to experts involved in drafting the standard, shelf life is typically determined by food manufacturers through experimental research and quality assessment based on product characteristics, production processes, and ingredient storage conditions. Specific shelf life requirements are generally not stipulated in standards, making this pre-prepared meal safety standard an exception. The establishment of this clause is primarily based on the following three considerations:

    First, it aligns with public consumption habits and demands. Consumers have expressed significant concern over the shelf life of pre-prepared meals, questioning excessively long labeling periods and stating psychological discomfort with such claims. To effectively address public sentiment, the standard specifically includes provisions on shelf life to meet widespread consumer expectations.

    Second, it incorporates the fundamental attributes of pre-prepared meal products. Although industrially pre-prepared, these dishes remain within the culinary category. Maximizing quality and flavor retention is the core public demand for food products. Therefore, to ensure the safety and nutritional quality of pre-prepared dishes, the standard enumerates factors that should be comprehensively considered when setting shelf life. It also encourages enterprises to enhance product flavor and quality retention through measures such as optimizing production processes and storage/transportation methods.

    Third, the standard incorporates findings from industry surveys. Based on an analysis of over 200 enterprises and more than 1,000 commercially available pre-cooked meal products—examining parameters such as “pre-processing methods, storage methods, and shelf life”—the drafting team comprehensively considered public expectations, nutritional quality, flavor and texture, and industry development. Consequently, the standard mandates that shelf life be minimized as much as possible, with a maximum duration not exceeding 12 months. Overall, the 12-month limit balances public demands with the practical operational needs of enterprises.

    Establishes Clear Requirements for Raw Material and Production Process Safety

    Raw material safety is the foundational safeguard for pre-cooked meal product safety, focusing on aspects such as:

- Whether spoiled or deteriorated raw materials are used;

- Whether pesticide residues, veterinary drug residues, heavy metals, and other contaminants exceed permissible limits;

- Whether raw material sources are traceable. The standard stipulates that all raw materials—including poultry, aquatic products, eggs, grains, edible fungi, and starch products—must comply with respective food safety standards. Spoiled or deteriorated ingredients are prohibited. Pesticide residues, veterinary drug residues, pollutants, and mycotoxins must meet specified limit requirements. Documentation verification and acceptance inspections are mandatory to ensure safe, reliable, and traceable sourcing.

    The production process of pre-cooked meals requires focused control of cross-contamination risks, along with proper temperature management and hygiene practices. Accordingly, the standard first requires that the entire production and operation process of pre-cooked meals comply with production and operation standards such as the “National Food Safety Standard: General Hygiene Specifications for Food Production” (GB 14881), the “National Food Safety Standard: Hygiene Specifications for Food Operation Processes” (GB 31621), and the “National Food Safety Standard: Hygiene Specifications for Food Cold Chain Logistics” (GB 31605). Building upon these, it establishes more specific provisions:

    First, requirements for premises and hardware conditions. To effectively prevent cross-contamination risks, the standard specifies operational zone divisions, independent pre-processing workshop areas, and prohibitions against mixing cleaning facilities, equipment, and utensils. For example, pre-processing workshops using fresh aquatic products as raw materials must have separate slaughtering/shelling, cleaning, and washing zones; those using fresh fruits and vegetables must have dedicated de-stoning and washing zones.

    On the other hand, management and operational requirements are stipulated. To strengthen control over critical stages throughout the production process, requirements are set for raw material thawing, ingredient batching records, water quality for food contact, and food additive storage and issuance management. For instance, it is specified that the core temperature of products requiring freezing must not exceed -18°C upon completion of freezing, while products requiring refrigeration must maintain a core temperature between 0°C and 10°C.

    Preservatives are prohibited, and food additives should be minimized.

    The standard further emphasizes principles for food additive usage: additives must not diminish the inherent nutritional value of food, mask spoilage or quality defects in the food itself or its processing, or be used for adulteration, falsification, or counterfeiting. Their process necessity must be fully evaluated, adhering to the principle of “add only when necessary” while minimizing both the variety and quantity of additives used.

    To guide food enterprises in enhancing the safety and nutritional quality of pre-cooked meals through improved processing techniques, thereby reducing reliance on food additives at the technical source, the standard requires not only the prohibition of preservatives but also the minimization of food additive usage. It strictly controls the permitted types of food additives, limiting them to those specified in the “National Food Safety Standard: Food Additive Usage Standard” (GB 2760) as additives that can be “used in appropriate amounts as needed for production” in various foods (i.e., those without specified maximum usage limits).

    Avoid overcooking and prioritize freshness preservation

    To better meet public expectations for both nutritional value and taste in pre-cooked meals, the standard sets clear requirements for nutritional quality:

    First, emphasize nutrient retention and balanced composition. The standard mandates avoiding overcooking during preparation; it encourages the use of advanced technologies or equipment to maximize nutrient preservation in raw materials, minimize nutrient loss, and satisfy both food safety and nutritional requirements as well as consumer sensory preferences. Advocating adherence to nutritional balance principles, maintaining dish nutritional characteristics through rational ingredient combinations and appropriate cooking methods.

    Second, actively implementing the “Three Reductions” requirements. The standard encourages enterprises to control the addition of cooking oil, salt, and sugar during processing to meet consumer demands for “reduced oil, salt, and sugar.”

    Third, emphasize freshness preservation and flavor retention. The standard encourages the use of preservation-enhancing technologies such as modified atmosphere packaging and ice-temperature preservation, alongside nutrient and flavor stabilization techniques like non-thermal processing and encapsulation. These methods minimize nutrient loss while improving product qualities like taste, flavor, texture, and flavor restoration.

    Ensuring Packaging Safety and Compatibility with Heating/Consumption Methods

    The health and safety of pre-cooked meal packaging are also closely scrutinized. To ensure safety and convenience throughout production, storage, transportation, sales, and heating/cooking processes, the standard specifies clear packaging requirements:

    First, packaging design and material safety must be guaranteed. Packaging design should be tailored to the characteristics of pre-cooked meals, with appropriate packaging processes selected. Inner packaging materials must comply with national standards for food contact materials. Packaging materials must possess adequate barrier properties. For frozen products, packaging materials should also exhibit sufficient cold resistance to preserve the product's intended flavor and quality.

    Second, packaging must accommodate heating and consumption methods. For products designed to be heated/cooked in their packaging, inner packaging materials must be heat-resistant, non-stick, non-discoloring, and non-deforming when heated.

    Third, ensure packaging integrity and sealing. Products must be packaged intact without visible deformation, defects, or damage. Sealed packaging must be complete with secure, robust closures free from damage or leakage.

    Additionally, the standard encourages the use of eco-friendly, innovative packaging materials. By employing packaging materials compliant with national food safety standards and suitable for intended applications (e.g., heat resistance), safety is ensured.

    Detailed labeling requirements ensure consumers can understand at a glance

    To protect consumer rights and guide consumers in selecting pre-cooked meal products, the standard sets forth targeted requirements.

    First, it mandates labeling of ingredient quantities or finished product content. The standard provides detailed specifications for indicating the quantities of raw materials or ingredients used in pre-cooked meal products, or their content in the finished product. This allows consumers to understand the product's true nature at a glance through the label, playing a key role in guiding consumer selection.

    Second, labels must indicate preparation methods. Some pre-cooked meals are only seasoned or marinated, some are partially cooked and not ready-to-eat, while others require reheating before consumption. Therefore, to ensure consumers understand the preparation method and select appropriate subsequent processing and consumption methods, the standard mandates that labels clearly indicate consumption instructions. This prevents foodborne illnesses from undercooked or incompletely cooked products due to insufficient heating, while also avoiding overheating of fully cooked pre-cooked meals that could compromise nutritional quality and taste. Specifically: Pre-processed undercooked or partially cooked items must be labeled “Must be cooked before consumption.”

    Third, packaging materials require specific warnings. Packaging materials that cannot be heated/cooked with the product must also be clearly marked. This ensures consumer food safety and helps consumers understand proper consumption methods.