On February 6, China's National Health Commission released a draft of the "National Food Safety Standards for Pre-made Dishes" for public consultation. The document clarifies the definition of pre-made dishes and strengthens management requirements for raw materials, production, operations, and storage.
According to Wang Jun, Director of the Second Standards Office at the China National Center for Food Safety Risk Assessment, the draft outlines management and control requirements for potential risk factors across all stages of the pre-made dish supply chain—from raw materials and processing to packaging, storage, transportation, and sales. It integrates existing standards on pollutants, food contact materials, process controls, and testing methods, and sets safety control requirements based on different ingredients and processing methods to help manufacturers comply.
The draft further clarifies the scope of pre-made dishes, excluding staple foods, pre-washed vegetables, ready-to-eat foods, and dishes prepared in central kitchens. Pre-made dishes are defined as industrially pre-processed, pre-packaged dishes that require heating or cooking before consumption.
Specifically, the draft states that pre-made dishes are made from one or more agricultural products, with or without seasonings, and without preservatives. They undergo industrial pre-processing—such as mixing, marinating, tumbling, shaping, frying, baking, boiling, or steaming—and may or may not include seasoning packets. They must be heated or cooked before eating. Dishes made in central kitchens are not considered pre-made dishes under this standard.
The draft also defines the scope of pre-processing under the central kitchen model. Industry experts note that if a central kitchen purchases ready-made, industrially produced pre-made dishes for use in its chain restaurants, this is equivalent to the restaurant directly using pre-made dishes in meal preparation and cannot be considered self-made by the central kitchen. Self-made dishes by central kitchens must comply with food safety regulations for the catering sector, such as the "National Food Safety Standards for General Hygiene in Catering Services."
The draft also sets specific requirements for the shelf life of pre-made dishes, taking into account public expectations, nutritional quality, flavor, and industry development. It calls for shelf lives to be as short as possible, with a maximum of 12 months. Drafting experts explained that while shelf life is typically determined by manufacturers based on product characteristics and storage conditions, this standard makes an exception by specifying a maximum duration.
Regarding the use of food additives—a topic of ongoing public concern—the draft prohibits preservatives and encourages minimizing the use of additives. Wang Jun stated that the draft strictly limits the types of additives allowed, permitting only those approved by national standards for use "as needed in production" in various foods.
The standard emphasizes three principles for additive use: they should not reduce nutritional value, mask spoilage or quality defects, or be used for adulteration or fraud. Manufacturers are urged to assess necessity and minimize both the variety and amount of additives used.
To better meet public expectations for nutrition and taste, the draft encourages preserving nutrients and enhancing freshness. For example, it advises against overcooking, promotes advanced technologies to retain nutrients, and encourages balanced ingredient combinations and cooking methods to maintain nutritional quality.
Wang Jun added that the draft encourages manufacturers to control the amount of oil, salt, and sugar added during processing to align with consumer preferences for healthier options. It also supports the use of technologies like modified atmosphere packaging, chilled storage, non-thermal processing, and encapsulation to preserve nutrients and improve taste, flavor, and texture.
On raw material safety, the draft requires that ingredients such as livestock, poultry, aquatic products, eggs, edible fungi, and starch comply with relevant food safety standards. Spoiled ingredients are prohibited, and limits are set for pesticide residues, veterinary drug residues, contaminants, and mycotoxins. Traceability and documentation are also emphasized to ensure source safety.
Liu Zhenyu, Deputy Director of the Standards and Regulations Department at the China General Chamber of Commerce, highlighted that the standard includes specific labeling requirements to help consumers make informed choices. Labels must clearly indicate ingredient quantities or content percentages, as well as cooking instructions—whether the product needs heating, reheating, or full cooking—to prevent undercooking or overcooking, which could affect safety or quality.
Liu further noted that packaging materials that should not be heated with the product must be clearly marked, enhancing both safety and clarity for consumers.
In a related move, on the same day, three state agencies—the State Council Food Safety Commission, the State Administration for Market Regulation, and the Ministry of Commerce—issued a separate draft notice encouraging catering providers to voluntarily disclose the use of pre-made dishes, central kitchen products, or pre-packaged foods to ensure transparency and protect consumer rights.