Pre-packaged dishes must not contain preservatives, and their shelf life should not exceed one year. National standards for pre-packaged dishes open for public consultation today.

The National Health Commission today released the “National Food Safety Standard for Prepared Dishes” (Draft for Comments) (hereinafter referred to as the “Standard”), inviting public comments.

The food safety standard for prepared dishes aims primarily to ensure consumers’ dietary health and to regulate the high-quality development of the prepared dish industry. It focuses on food safety and nutritional health, setting regulations for prepared dish products:

On one hand, it strengthens source and process management, proposing control measures for potential risk factors and risk points across the entire chain, including raw materials, processing, packaging, storage and transportation, and sales.

On the other hand, for the final prepared dish product, it systematically integrates over ten general standards such as “Limits of Contaminants in Food,” over ten product standards like “Animal-derived Seafood Products,” more than ten process norms including “General Hygiene Standards for Food Production,” as well as over ten standards for food contact materials and testing methods. It proposes safety control indicators for prepared dishes made from different raw materials and processing methods, facilitating compliance for producers.

Main contents of the draft for comments include:

1. Reasonable definition and management scope of prepared dishes. Based on food safety risk analysis principles and combined with interpretations of policies from six departments regarding prepared dishes, the standard further clarifies the concept of prepared dishes. It specifies that prepared dishes do not include staple foods, ready-to-clean vegetables, instant foods, or dishes made in central kitchens, all of which are governed by other relevant national standards.

2. Emphasis on managing food contaminants and additives. The standard sets control requirements for key risk factors such as lead, chromium, benzo[a]pyrene, and pathogenic microorganisms in prepared dishes. It also strengthens the management of food additive use, stipulating usage principles: avoiding preservatives, minimizing additive use as much as possible, strictly controlling permissible additives, and not adding them unless necessary.

3. Focus on maintaining nutritional quality. The standard requires that cooking processes avoid overcooking, using advanced technology or equipment to maximize nutrient retention and reduce nutrient loss. It encourages controlling the amounts of cooking oil, salt, and sugar during processing. Additionally, it mandates that producers reasonably set shelf life considering food safety and other factors.

4. Regulations on related consumer tips. To ensure proper consumption, the standard requires clear labeling of how to consume pre-cooked, semi-cooked, and undercooked products, preventing foodborne illnesses caused by insufficient heating or nutritional and sensory quality deterioration due to over-heating.

Why are these types of foods not classified as prepared dishes?

The scope of what constitutes prepared dishes has been a focus of public concern. The standard clarifies that prepared dishes are prepackaged dishes made from one or more edible agricultural products and their derivatives, with or without seasonings, without preservatives, processed through industrial pre-processing methods (such as mixing, marinating, rolling, shaping, frying, baking, boiling, steaming, etc.), and ready to eat after heating or cooking, with or without seasoning packets.

Prepared dishes do not include: staple foods, ready-to-clean vegetables, instant foods, or dishes made in central kitchens. According to experts involved in drafting the standard, this distinction is based on several considerations:

• Prepared dishes should have characteristics of a dish, thus excluding staple foods, which are governed by other standards.
• Prepared dishes should be industrially pre-processed; simple cleaning, peeling, or cutting of raw ingredients still classify as raw materials, thus excluding ready-to-clean vegetables.
• Prepared dishes should require heating or cooking before consumption, excluding ready-to-eat products like pre-packaged ham sausages or marinated chicken feet that do not need reheating.
• Prepared dishes should be prepackaged; products made in central kitchens are typically distributed only to their own chain restaurants and are considered internal processing centers, not prepared dishes, except for externally purchased industrial pre-made products. Central kitchens must comply with relevant food safety standards such as the “General Hygiene Standards for Food Service.”

Shelf life of prepared dishes should not exceed 12 months

The standard also specifies requirements for the shelf life of prepared dishes. Experts involved in drafting explain that shelf life is usually determined by manufacturers based on product characteristics, processing, storage conditions, and testing, and is generally not specified in standards. This particular standard sets a special rule, mainly considering:

• Public consumption habits and needs. Consumers are highly concerned about shelf life and have questioned excessively long labeling periods, finding them psychologically unacceptable. To respond to public opinion, the standard includes specific provisions on shelf life.
• The fundamental attributes of prepared dishes. Although industrially pre-processed, they remain dishes, and maintaining quality and flavor is a core consumer expectation. The standard encourages companies to optimize processing and storage to improve flavor and quality.
• Industry survey data. Based on investigations of over 200 companies and more than a thousand pre-made products, the standard emphasizes shortening shelf life as much as possible, with a maximum of 12 months, balancing consumer expectations and industry needs.

Clear requirements for raw materials and production process safety

The safety of raw materials is the foundation of product safety, focusing on whether raw materials are spoiled, contaminated with pesticide or veterinary drug residues, heavy metals, or other pollutants, and whether sources are traceable. The standard mandates that raw materials such as livestock, aquatic products, eggs, grains, edible fungi, and starch products meet relevant food safety standards, avoiding spoiled ingredients, and ensuring residues of pesticides, veterinary drugs, pollutants, and mycotoxins are within limits. Suppliers must provide certificates and pass inspections to ensure traceability and safety.

The production process must focus on controlling cross-contamination risks, temperature management, and hygiene. The standard requires that the entire process complies with relevant norms such as the “General Hygiene Standards for Food Production,” “Hygiene Standards for Food Business Operations,” and “Hygiene Standards for Cold Chain Logistics,” with more specific regulations:

• Facility and hardware requirements. To prevent cross-contamination, the standard specifies the division of work areas, independent pre-processing zones, and requirements to avoid mixing cleaning equipment and utensils. For example, processing areas for raw aquatic products should have separate slaughter/de-shelling, cleaning, and washing zones; fresh produce processing should have separate sorting and washing areas.
• Management and operational requirements. To strengthen control over key production steps, the standard stipulates requirements for thawing raw materials, recording ingredient addition, water quality for contact use, storage and dispatch of additives, etc. For instance, frozen products should reach a core temperature of no higher than -18°C; refrigerated products should be maintained at 0°C-10°C.

Minimize use of preservatives and food additives

The standard emphasizes principles for additive use: they should not reduce the nutritional value of the food, mask spoilage or quality defects, or be used for adulteration or falsification. Additives should be used only when necessary, with full evaluation of process requirements, and their types and quantities should be minimized.

Building on this, to guide companies in improving processes and reducing reliance on additives, the standard requires that, besides avoiding preservatives, the use of additives should be as limited as possible, strictly controlling the types allowed according to the “Food Safety National Standard for Food Additives” (GB 2760), and only using those permitted for “appropriate use” in various foods without specified limits.

Avoid overcooking and focus on freshness

To better meet consumer demands for nutrition and taste, the standard sets clear nutritional requirements:

• Emphasize nutrient retention and pairing. Cooking should avoid overcooking; advanced techniques or equipment should be used to maximize nutrient preservation and reduce loss, ensuring safety and sensory quality. It encourages balanced nutrition through proper ingredient pairing and cooking methods.
• Implement the “Three Reductions” (less oil, salt, sugar). Companies are encouraged to control the amounts of cooking oil, salt, and sugar during processing to meet consumer demands for healthier options.
• Focus on freshness and flavor retention. Use technologies like modified atmosphere packaging, cold storage, and non-thermal processing to preserve nutrients and improve taste, texture, and overall product quality.

Ensure packaging safety and compatibility with heating and consumption

Packaging safety is also a concern. To ensure safety and convenience during production, storage, transportation, sales, and heating, the standard specifies:

• Safe packaging design and materials. Packaging should be suitable for the product, with materials complying with relevant standards for food contact. They should have sufficient barrier properties, and for frozen products, adequate cold resistance to maintain flavor and quality.
• Compatibility with heating and consumption. For products that are heated or cooked in packaging, materials must withstand heat without sticking, discoloring, or deforming.
• Packaging integrity and sealing. Products should be fully packaged, without deformation, damage, or defects. Seals must be tight and secure, with no leaks.

Additionally, the standard encourages the use of environmentally friendly, innovative packaging materials that meet food safety standards and are suitable for intended use cases, such as heating.

Clear labeling to inform consumers at a glance

To protect consumer rights and guide purchasing, the standard makes specific labeling requirements:

• Labeling of raw material or ingredient quantities. Clear indication of raw material proportions or ingredient content in the final product helps consumers understand the product’s true nature.
• Labeling of consumption methods. Since some prepared dishes are only marinated or semi-cooked, and others are fully cooked but require reheating, labels must specify the appropriate consumption method—e.g., “Requires heating or reheating before eating” for cooked products, and “Requires cooking before eating” for raw or semi-cooked items.
• Packaging material warnings. For packaging that cannot be heated with the product, clear prompts should be provided to ensure safety.

(Source: CCTV News Client)