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

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). 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). 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 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, 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.

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 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). 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).

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.

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). 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).

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).

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.

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.

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). 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).

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

The EU reached the same problem from the other end. Ledger 63 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 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%.

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). 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.