# GB 23350-2021: all 38 packs failing Shanghai checks since 2023 broke the void ratio limit, none the cost cap

> GB 23350-2021, China's mandatory standard on excessive packaging for food and cosmetics, has applied since 1 September 2023 to sales packs made, sold or imported in mainland China; a pack fails if it has more than three layers (grain products, mooncakes, zongzi and tea) or four (other foods and cosmetics), exceeds the void ratio limit for its net content, or spends more than 20% of the sale price on packaging outside the contact layer.

Publisher: Strategic Packaging Insights  
Published: 2026-11-01  
Last updated: 2026-11-01  
Page: https://www.strategicpackaginginsights.com/insights/gb-23350-2021-china-excessive-packaging-food-cosmetics/

**GB 23350-2021, China's mandatory standard on excessive packaging for food and cosmetics, has applied since 1 September 2023 to sales packs made, sold or imported in mainland China; a pack fails if it has more than three layers (grain products, mooncakes, zongzi and tea) or four (other foods and cosmetics), exceeds the void ratio limit for its net content, or spends more than 20% of the sale price on packaging outside the contact layer.**

Strategic Packaging Insights (SPI) read the standard's limits against four rounds of official spot checks by the Shanghai market regulator, covering 637 batches of cosmetics and health foods. The finding for brand owners is that the box, not the budget, is where packs fail: every one of the 38 non-compliant batches broke the void ratio test, 6 also broke the layer test, and none failed on cost.

## Executive summary

GB 23350-2021, Requirements of restricting excessive package: foods and cosmetics, was issued by the State Administration for Market Regulation (SAMR) and the Standardization Administration of China (SAC) on 10 August 2021 and took effect on 1 September 2023, replacing GB 23350-2009 (SAMR open standards record). It is a mandatory national standard, which NDRC's 2022 interpretation describes as the key basis for judging excessive packaging in enforcement. [Ledger 19](https://www.strategicpackaginginsights.com/insights/china-packaging-rules-ecological-environment-code/) set the standard in China's wider rulebook after the Ecological Environment Code; this piece goes inside the standard itself.

The standard has three tests, and failing any one makes a pack excessive (clause 6). Layers are capped at three for grain products, mooncakes, zongzi and, since 1 March 2025, tea, and at four for other foods and cosmetics. The void ratio, the share of the box not needed by the product after a category allowance, must stay within limits that fall from 85% to 30% as net content rises (Exhibit 2). The cost of every layer outside the one touching the product must stay within 20% of the sale price, or 15% for mooncakes and zongzi above CNY 100 and tea above CNY 200.

The void ratio is where packs fail. Shanghai's market regulator checked 637 batches of cosmetics and health foods in four rounds published between March 2024 and February 2026, and found 38 non-compliant. All 38 broke the void ratio limit; 6 also broke the layer cap; none broke the cost cap (Exhibits 6 and 7). Gift sets carried most of the failures in 2023, but single items carried most in 2025 (Exhibit 8).

The rule is still moving. A third amendment, drafted under the Ministry of Industry and Information Technology (MIIT), was notified to the WTO on 1 June 2026 and enters into force on publication, which had not happened as of the latest official records SPI consulted (Exhibit 9). Its notified changes loosen the coefficients for some canned foods, instant meals in their own containers and drip coffee.

For leaders the action is in the design file. Measure each SKU's box against the band its net content falls in, watch the band edges where a gram more product means a smaller permitted box (Exhibit 1), and keep the cost and layer evidence ready for an inspector.

## Key findings

1. GB 23350-2021 was issued on 10 August 2021 by SAMR and SAC, took effect on 1 September 2023 and fully replaced GB 23350-2009; MIIT is the competent department (SAMR open standards record; national standards platform record).
2. Table 1 sets void ratio limits of 85% at 1 g or mL or less, 70% up to 5, 60% up to 15, 50% up to 30, 40% up to 50 and 30% above 50, and does not apply to packs with only one layer of sales packaging (Hunan market regulator, 16 June 2023).
3. **SPI calculation:**  crossing a band edge cuts the largest permitted box by 50.0% at 1 g, 25.0% at 5 g, 20.0% at 15 g, 16.7% at 30 g and 14.3% at 50 g, whatever the product's coefficient.
4. Shanghai's market regulator found 19 of 157 cosmetics batches non-compliant in the second half of 2023, 2 of 240 in 2024 and 8 of 150 in 2025, and 9 of 90 health food batches in 2025; by SPI's calculation that is 38 of 637, or 6.0%, and all 38 failed on void ratio.
5. Amendment No. 2 was published on 25 March 2024 and entered into force on 1 March 2025, cutting tea to three layers, setting a 15% cost cap for tea above CNY 200 and capping tea pack mass at eight times the net content (USDA FAS CH2026-0089; Ganzhou market regulator, 16 September 2026).
6. Amendment No. 3 was notified to the WTO on 1 June 2026 as G/TBT/N/CHN/447/Add.3 and splits canned foods into k = 2.5 for livestock, poultry and aquatic products and k = 8.0 for others; **SPI calculation:**  at the same net content, the largest permitted box for other canned foods would grow 3.2 times.
7. **SPI analysis:**  GB 23350-2021 caps empty space in the sales pack, the layer the EU's PPWR leaves without a numeric cap; Article 24 of Regulation (EU) 2025/40 caps grouped, transport and e-commerce packaging at 50% from 2030 at the earliest (Commission Notice C/2026/3084).

## What GB 23350-2021 covers, and who must act

Clause 1 limits the standard to the sales packaging of food and cosmetics ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)). SAMR's official, interviewed by Xinhua on 1 September 2023, said it applies to food and cosmetics produced, sold and imported within China, and does not apply to exports, to transport packaging, or to products with a zero ex-factory price marked as gifts or not for sale. The official added that a combination of food with non-food goods, or of cosmetics with non-cosmetics, does not form a composite commodity under the standard (Xinhua, 2 September 2023).

Three duties sit on top of the standard. Until 15 August 2026, Article 68 of the Solid Waste Law required producers and traders to comply with the mandatory standard, and Article 105 let county-level and higher market supervision departments order correction and fine those who refused ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)). The State Council General Office notice of 1 September 2022 adds that producers must publish the numbers and names of the packaging standards they follow, and that retailers, online and offline, must not sell goods that breach the limits (Guobanfa [2022] No. 29). The Code that replaced the Solid Waste Law restates the excessive packaging duty, and SPI has not yet confirmed which Code penalty articles now apply, as [Ledger 19](https://www.strategicpackaginginsights.com/insights/china-packaging-rules-ecological-environment-code/) sets out.

Enforcement has a stated focus. The same 2022 notice directs market supervision at chain-type, hidden and high-end gift packaging, names mooncakes, zongzi, tea, health foods and cosmetics as key products, gives consumer complaints priority and says violations will be made public ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/), citing Guobanfa [2022] No. 29). It set 2025 as the year by which a governance system for excessive packaging across production, sale, delivery and recycling should be in place. The Shanghai results in Exhibit 6 follow that list closely: two of the four rounds SPI counted are cosmetics and health foods, and the notices name every failing product and its seller.

The standard took a two-year run-in. Xinhua's report gives a two-year transition from issue, after which non-compliant food and cosmetics could no longer be made or sold from September 2023 (Xinhua, 2 September 2023). The amendments carry their own dates, covered in Exhibit 9.

SPI analysis

The scope sentence that matters most for foreign brands is "imported". A cosmetic made in France and sold in a Shanghai department store is tested in the same way as a domestic one, and the duty to publish the standard followed falls on the producer named on the Chinese label. A cross-border pack shipped in its home-market box will be measured in the box it arrives in.

## Test 1: the void ratio, and why net content decides the box

The void ratio is X = (Vn minus k x V0) / Vn, where Vn is the volume of the sales pack, V0 the volume of the contents counted at 1,000 cubic millimetres for each gram or millilitre, and k the necessary space coefficient for the category in Appendix A ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/) rule notes; Hunan market regulator). The volume is measured three times, by instrument, by hand or by displacement, and two results must sit within 10% of their mean ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)). Table 1 then sets the ceiling by net content (Exhibit 2).

Two features shape design choices. First, the limit is set in steps, not on a curve. Exhibit 1 shows the effect: a pack whose net content moves from just under to just over a band edge loses 14.3% to 50.0% of the box it may use, because the multiple in Exhibit 2 falls at each step. Second, the coefficient k, not the band, sets the scale. A category with k = 15.0 is allowed three times the volume of one with k = 5.0 at the same net content.

**SPI calculation:**  a 50 g jar of loose powder (k = 15.0) may sit in a pack of up to 15.0 x 0.05 litres / 0.60 = 1.25 litres. Add one gram, to 51 g, and the ceiling becomes 15.0 x 0.051 / 0.70 = 1.09 litres, a cut of 12.6% for a product that grew by 2.0%. A team that raises fill weight to add value, without touching the carton, can turn a passing pack into a failing one.

### The coefficients that set the scale

Appendix A gives k by category for food and for cosmetics. Exhibit 3 lists the values SPI holds from the standard, its amendments and the Amendment No. 3 draft table, and turns each into the largest permitted pack for 100 g or mL of product.

The Amendment No. 3 draft also carries the adjustments that sit around the table: products that need a brewing machine take 3.5 times the category value, units under 10 g take 5 times, gas-filled packs take 2 times, and freeze-dried, puffed and spray-dried products have their own values (Amendment No. 3 draft text). The 2024 Quanzhou question-and-answer note adds two counting rules: dried edible fungi have no void ratio limit but are still tested for layers and cost, and in a mixed tea product only the tea counts as contents (Quanzhou market regulator, 23 September 2024).

SPI analysis

The coefficient is a product decision as much as a packaging one. A category assignment that moves a SKU from "other foods" to a named category, or the reverse, can move the permitted box more than any redesign. Every SKU needs its category, and the reason for it, written down before the pack is measured.

## Test 2: layers, and what does not count

Layer counting starts at the pack that touches the product, which is layer 1, and runs outward to layer N (Hunan market regulator). The caps and the counting rules sit in Exhibit 4.

The layer test fails less often than the void test, but it fails in a recognisable way. In Shanghai's 2023 checks the 4 layer failures were all in multi-piece skincare sets, and in 2025 both layer failures were sets: a men's moisturising set and a two-product sun care combination (Shanghai market regulator, 8 March 2024 and 13 February 2026). Each extra tray, sleeve or inner box that holds one piece of a set adds a layer for that piece.

SPI analysis

The layer cap and the void ratio pull the same way. A designer who cuts the outer box to pass the void test is often tempted to keep the inner tray for presentation, which adds a layer; a designer who drops the tray needs a box that fits the products tightly. The pack that passes both is usually the one with fewer, closer-fitting components, not the one with the cheapest board.

## Test 3: the 20% cost cap

The cost test is Y = C / P x 100%, where C is the cost of every layer except the one in direct contact with the contents and P is the sale price ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)). The cap is 20%. Amendment No. 1 lowered it to 15% for mooncakes and zongzi priced above CNY 100, and Amendment No. 2 to 15% for tea priced above CNY 200 (USDA FAS CH2023-0128 translation; Beitun note). Precious metals and rosewood are barred from mooncake, zongzi and tea packs (Ganzhou market regulator). The mooncake and tea cost effects are worked in Ledger 19; Exhibit 5 applies the base 20% cap to a cosmetics gift set.

**SPI calculation:**  the lowest sale price at which a pack passes is its outer cost divided by 0.20. An outer pack costing CNY 20.00 needs a price of at least CNY 100.00, one costing CNY 45.00 needs CNY 225.00, and one costing CNY 80.00 needs CNY 400.00. The same box can pass on a premium line and fail on a value line.

The cost cap has not produced a failure in the Shanghai data (Exhibit 6), but that says as much about how cost is checked as about how packs are built. An inspector can measure a box in minutes; the cost test needs the producer's own cost records. The 2023 second-half cosmetics round did not list cost among the items tested at all (Shanghai market regulator, 8 March 2024).

## What inspectors find: four Shanghai rounds

Shanghai publishes its excessive packaging spot checks by round, with every failing product named. SPI took the four cosmetics and health food rounds published from March 2024 to February 2026 and counted the results (Exhibit 6).

The first round came weeks after the standard took effect, and its list reads like a catalogue of festive skincare sets from domestic and international groups. The 2024 round found two failures in 240 batches. The 2025 round rose again, and its failures were different in kind: two were single-dose ampoule serums, one a children's toothpaste, one a men's fragrance (Shanghai market regulator, 13 February 2026).

In practice: Shanghai cosmetics, second half of 2023.

The regulator listed 19 non-compliant batches, all for void ratio and 4 also for layers. They included a Lancôme foundation gift box from L'Oréal (China), a L'Oréal product series from Suzhou Shangmei International Cosmetics, three 温碧泉 (Wetcode) sets from Guangzhou Qiaomei Cosmetics, two of them also over the layer cap, and two Pechoin sets from Shanghai Pechoin E-commerce, both also over the layer cap (Shanghai market regulator, 8 March 2024).

In practice: Unilever (China) and Chongqing Dengkang, 2025.

In the 2025 cosmetics round, a Clear men's moisturising set produced by Unilever (China), sampled at a Shanghai supermarket, failed on both layers and void ratio, and a Lengsuanling children's toothpaste produced by Chongqing Dengkang Oral Care failed on void ratio. The regulator's notice records that several companies, Dengkang among them, had already made corrections (Shanghai market regulator, 13 February 2026).

In practice: health foods sold online, 2025.

All nine non-compliant health food batches failed on void ratio, and the regulator lists each with the online shop and platform it was bought from: Douyin Mall, Pinduoduo and Taobao (Shanghai market regulator, 13 February 2026). The products were mostly capsules and softgels, and none failed on layers or cost.

### A framework: four pack archetypes and the test that bites

SPI sorted the 38 failures by what the product names say about the pack: a multi-piece gift box or set, a single-dose multipack, a small single item, or a standard single item. The archetypes help decide where to look first (Exhibit 8).

SPI analysis

The shift from sets to single items suggests the industry learned the gift box lesson first. Sets are the obvious target, and the 2024 round found almost none failing. The 2025 failures sit in formats where the box is set by shelf presence or by a dose count, and where a small product in a standard carton sits in a low band with a small multiple. The likely next frontier for inspectors is online sellers, as the health food round shows.

## Amendments: three so far, the third not yet published

GB 23350-2021 has been amended twice and a third amendment is pending (Exhibit 9). The national standards platform lists MIIT as the department that organised the drafting, and the SAMR open standards record listed Amendment No. 2 as the latest when SPI consulted it on 1 November 2026.

**SPI calculation:**  because the largest permitted box is proportional to k, Amendment No. 3 would let a can of fruit or vegetables use a pack 3.2 times as large as today, an instant noodle bowl 57.9% larger (15.0 against 9.5) and a box of drip coffee bags 77.8% larger (8.0 against 4.5), at the same net content. By SPI's reading, these would be the first changes to the standard that relax a limit rather than tighten it. **SPI analysis:**  the three categories share a physical reason for space: a can is rigid, a self-contained noodle bowl needs room for water, and a drip bag needs its frame.

> "At the time of this report, Amendment No.3 has not been officially published in China."

***USDA Foreign Agricultural Service** , Beijing post, [GAIN report CH2026-0089](https://agriexchange.apeda.gov.in/MarketReport/100770508202672416578470.pdf), 9 July 2026*

The same report says the notified text enters into force on the date of publication, and that the notification carried no comment period. A brand selling canned goods or drip coffee therefore gets no run-in when it lands; the change works in the brand's favour, but packs designed to the tighter limit will not need to change.

> "On September 15, 2023, China notified an amendment to the National Food Safety Standard for Restricting Excessive Packaging for Foods and Cosmetics (GB 23350-2021) to the World Trade Organization (WTO) under G/TBT/N/CHN/447/Add.2."

***USDA Foreign Agricultural Service** , [GAIN report CH2023-0128](https://www.fas.usda.gov/data/china-wto-notified-amendment-excessive-packaging-national-standard), 25 September 2023*

The report's title for the standard is its own; GB 23350-2021 is a packaging standard rather than a food safety standard. It offers an unofficial translation of the amendment, which is the English text SPI uses for the cost thresholds above. SPI has not yet confirmed whether a second consultation draft of Amendment No. 3, circulated by a trade body in May 2026, changed the coefficients the WTO notification lists.

## One gift box, several tests: the wider Chinese stack

GB 23350-2021 governs the sales pack. The parcel around it answers to other rules, and the 2025 and 2026 changes on the parcel side matter for any brand that sells online (Exhibit 10).

Article 3 of the 2021 measures excludes the product's own packaging from express packaging, so a gift box is tested once as a sales pack and the courier bag around it once as a parcel ([PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/)). Decree No. 806, signed on 13 April 2025, encourages carriers to work with manufacturers and e-commerce firms on shipping goods in their original packaging, to cut the second layer (Decree No. 806, Article 40). The express standard that took effect on 1 July 2026 sets three core indicators, box fit, layers and tape, each with three control levels (Xinhua, 2 July 2026).

SPI analysis

Original-package shipping links the two regimes. A sales pack strong enough to travel without an outer carton saves the parcel layer, but it has to pass GB 23350-2021 as a sales pack first, and a heavier, larger shelf pack built for transit will fail the void ratio sooner. Brands should design the shelf pack and the shipping case together.

## How GB 23350-2021 compares with the EU's empty space cap

The EU reached the same problem from the other end. [Ledger 63](https://www.strategicpackaginginsights.com/insights/ppwr-minimisation-weight-volume-empty-space-grouped-transport/) sets out the PPWR's minimisation and empty space duties for grouped and transport packaging; Exhibit 11 puts the two regimes side by side.

The European Commission's [Notice C/2026/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084) of 10 June 2026 quotes Article 24(1) of the PPWR: from 1 January 2030, or three years after the implementing acts on the calculation method enter into force, whichever is later, economic operators that fill grouped, transport or e-commerce packaging must keep the maximum empty space ratio at 50%.

SPI analysis

The two rules rarely clash, because they measure different layers, but they meet in a gift set shipped to both markets. A cosmetics set that passes China's void ratio at its net content is tightly boxed; the same set in an EU e-commerce carton must then keep the carton below 50% empty. A brand that designs one global gift set should design to China's sales pack limit, which is the stricter of the two for small items, and to the EU's 50% for the case and parcel.

## Industry reaction

Chinese regulators, not trade bodies, have done most of the public talking on GB 23350-2021, and their tone has been instructional. NDRC's interpretation of 13 September 2022, written by the head of the resources and environment branch of the China National Institute of Standardization, called the mandatory standard the key basis for judging excessive packaging and listed 31 food categories it covers, from pastries and alcoholic drinks to tea, beverages and health foods. SAMR's official told Xinhua on 1 September 2023 that consumers could check three things themselves: whether the outer pack is lavish or made of costly material, whether it has too many layers, and whether the box is larger than allowed.

Consumers back the rule. The China Consumers Association's survey, reported on 3 April 2023, found 80.7% of respondents opposed excessive packaging in most cases, while 92.2% were not familiar with the criteria for identifying it (Xinhua, carrying China News Service, 3 April 2023). Local regulators keep publishing explainers: Ganzhou's guide of 16 September 2026 restates the base limits and both amendments, three years after the standard took effect.

The two USDA reports quoted above are the clearest English statements of status, and the European Commission's notice is the EU counterpart. SPI found no published position from a cosmetics or food trade body on Amendment No. 3; the canned food, convenience food and coffee changes it notifies read as a response to category-specific concerns, but SPI has not yet confirmed who raised them.

## Fines and enforcement after the Code

Until 15 August 2026, Article 105 of the Solid Waste Law set the penalty: an order to correct, then a fine of CNY 2,000 to 20,000 for refusing to correct, or CNY 20,000 to 100,000 in serious cases ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)). The Ecological Environment Code repealed that law from 15 August 2026 by its Article 1242 (Jiangmen municipal government). SPI has not yet confirmed the Code penalty articles that now apply to excessive packaging, so these amounts are the position before that date.

SPI analysis

The structure of the old penalty matters more than its size. A fine followed a refused correction, so a failed spot check first meant a public listing and an order, as Shanghai's notices show. For a consumer brand the listing, with brand and product named on a government site, is the larger cost. The Haleon profile in the [SPI Packaging Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) records that SPI has not yet confirmed whether Haleon's toothpaste lines in China fall within the standard; the Appendix A toothpaste coefficient and the 2025 Shanghai toothpaste case suggest that oral care brands should assume they do.

## What leaders should do now

1. **Packaging development, before the 2027 Spring Festival range is frozen:**  measure every China SKU against the Exhibit 2 band for its net content and its Exhibit 3 coefficient, using the three-measurement method, and flag any SKU within 10% of a band edge (Exhibit 1).
2. **Product and marketing teams, at every fill weight change:**  re-run the void ratio before a larger fill or a new size goes on sale; a gram more product can mean a smaller permitted box.
3. **Finance, at each price change and promotion:**  keep a cost file per SKU and price point that shows outer packaging cost under 20% of price, or 15% for mooncakes, zongzi and tea above the thresholds (Exhibit 5).
4. **Regulatory affairs, by 31 December 2026:**  publish the packaging standards each product follows, as the 2022 notice requires, and record the Appendix A category and reason for each SKU.
5. **E-commerce teams, in Q1 2027:**  sample your own online listings the way Shanghai did, and check that sellers on Douyin, Pinduoduo and Taobao ship the compliant pack rather than old stock.
6. **Canned food, instant meal and coffee brands, when Amendment No. 3 is published:**  decide whether to keep current packs or use the larger coefficients, and update the category file the same day, since there is no transition.
7. **Global packaging leads, in 2027 design cycles:**  design gift sets to China's sales pack limits and the EU's 50% grouped and e-commerce cap together, using [Ledger 63](https://www.strategicpackaginginsights.com/insights/ppwr-minimisation-weight-volume-empty-space-grouped-transport/) for the EU side.

## Questions for your board

- How many of our China SKUs sit within 10% of a Table 1 band edge, and who measured them?
- Which of our products would fail if a regulator used the promotional price for the cost test?
- Do we publish the packaging standard each product follows, as the 2022 notice requires?
- What share of our China online sales ship in a pack that has been measured against GB 23350-2021?
- If one of our products appeared on a regulator's non-compliant list tomorrow, how fast could we correct it?
- Are our global gift sets designed to the stricter of China's and the EU's limits?

## What to watch

- **No date set:**  publication of Amendment No. 3, which takes effect on that day.
- **No date set:**  Ecological Environment Code penalty articles for excessive packaging, once SPI confirms them.
- **Q1 2027:**  Shanghai's 2026 cosmetics and health food spot check results, on the pattern of the February 2026 release.
- **1 March 2027:**  two years of the Amendment No. 2 tea limits.
- **1 September 2027:**  four years of GB 23350-2021 in force.
- **1 January 2030 at the earliest:**  the EU's 50% empty space cap for grouped, transport and e-commerce packs.

## Methodology

- **Data used:**  SPI rules [PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/) and [PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/) and the China profile in the [SPI Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/), whose GB 23350-2021 text is the copy attached to a Hong Kong Trade and Industry Department trade circular; the SAMR open standards and national standards platform records; explainers by the Hunan, Ganzhou, Quanzhou and Beitun market regulators; Xinhua's 2023 interview with SAMR; NDRC's 2022 interpretation; USDA FAS GAIN reports CH2023-0128 and CH2026-0089; four Shanghai spot check releases; Commission Notice C/2026/3084. Consulted 1 November 2026 unless the sources list gives 14 October 2026.
- **Translations:**  English wording of the cost thresholds and Amendment No. 2 follows USDA FAS's unofficial translation. Chinese official text is paraphrased, not quoted; product names from Shanghai's lists are given in their usual English brand names where one exists.
- **Counting rules:**  Shanghai batch counts are the regulator's own. Failure rates, totals and the archetype split in Exhibit 8 are SPI's work from product names; the regulator does not publish pack sizes.
- **Calculations:**  labelled SPI calculation, from the void ratio formula, Table 1 and Appendix A, for a single product and a single unit, and in CNY only for cost. They show how the limits behave and are not test results for any product.
- **Limitations:**  SPI has not yet confirmed the Ecological Environment Code penalty articles for excessive packaging, the full cosmetics coefficient table against an official copy, the content of the May 2026 second draft of Amendment No. 3, or whether a promotional or regular price is used in the cost test.

## Sources

1. SAMR open standards: GB 23350-2021 限制商品过度包装要求 食品和化妆品, record page, [https://openstd.samr.gov.cn/bzgk/std/newGbInfo?hcno=30366DF41D69DA50E3EEABC0CE18A241](https://openstd.samr.gov.cn/bzgk/std/newGbInfo?hcno=30366DF41D69DA50E3EEABC0CE18A241), consulted 2026-11-01.
2. National Public Service Platform for Standards Information: GB 23350-2021 record, [https://std.samr.gov.cn/gb/search/gbDetailed?id=CAEA4CD20E9E8EECE05397BE0A0AB82F](https://std.samr.gov.cn/gb/search/gbDetailed?id=CAEA4CD20E9E8EECE05397BE0A0AB82F), consulted 2026-11-01.
3. GB 23350-2021 text, copy attached to a Hong Kong Trade and Industry Department trade circular (SPI rule PR-CN-003), [https://www.tid.gov.hk/english/aboutus/tradecircular/cic/asia/2023/files/ci2023318a.pdf](https://www.tid.gov.hk/english/aboutus/tradecircular/cic/asia/2023/files/ci2023318a.pdf), consulted 2026-10-14.
4. Hunan Provincial Administration for Market Regulation: 限制茶叶过度包装相关规定解读, 16 June 2023, [http://amr.hunan.gov.cn/amr/xxx/xtdtx/202306/t20230616_29377676.html](http://amr.hunan.gov.cn/amr/xxx/xtdtx/202306/t20230616_29377676.html), consulted 2026-11-01.
5. Xinhua: 限制商品过度包装新国标9月实施, SAMR (SAC) official explains implementation, 2 September 2023, [https://www.news.cn/fortune/2023-09/02/c_1129841458.htm](https://www.news.cn/fortune/2023-09/02/c_1129841458.htm), consulted 2026-11-01.
6. NDRC: 完善标准体系 夯实商品过度包装执法标准基础, 13 September 2022, [https://www.ndrc.gov.cn/xxgk/jd/jd/202209/t20220913_1335476.html](https://www.ndrc.gov.cn/xxgk/jd/jd/202209/t20220913_1335476.html), consulted 2026-11-01.
7. State Council General Office: 关于进一步加强商品过度包装治理的通知 (Guobanfa [2022] No. 29), [https://www.gov.cn/zhengce/content/2022-09/08/content_5708858.htm](https://www.gov.cn/zhengce/content/2022-09/08/content_5708858.htm), consulted 2026-10-14.
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