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GBA Elderly Food Standards T/SATA 084-2025 and 085-2025 — What Manufacturers Need to Know

In 2025, the Shenzhen Ageing Industry Association (深圳市老龄事业发展基金会) released two group standards for elderly food that are quickly becoming the de facto Greater Bay Area (GBA) specifications:

These are not government-enforced national standards (国标 GB), but group standards (团体标准 T/) — a tier of voluntary industry standards that in practice act as the baseline for GBA procurement tenders, e-commerce platform onboarding, and institutional care home purchasing. For any manufacturer selling into the Greater Bay Area elderly food market, these are the standards you will be asked about.

Note — dysphagia-specific standard: In September 2025 the Greater Bay Area Standardization Research Centre issued T/SATA 094-2025 — General Requirements of Dysphagia Food (Care for Elderly), the first GBA group standard written specifically for dysphagia food. If your product is explicitly targeted at swallowing difficulties rather than general elderly consumption, T/SATA 094 is the standard you should be asked about — it is complementary to, not a replacement for, 084 and 085. SeniorDeli (Carewells) is a participating drafting unit for T/SATA 094.

This English-language guide explains what each standard covers, how they relate to IDDSI, the testing and labelling requirements, and the practical steps a manufacturer needs to take to comply. We have detailed Chinese versions on the site — this article is a consolidated English reference for international manufacturers, product developers, and food safety officers working in or exporting to the GBA market.

For the detailed Chinese explanations, see:

The two standards — what each one actually covers

T/SATA 084 and 085 are complementary, not overlapping. Knowing which standard applies to your product is the first step.

T/SATA 084-2025 — Elderly Care Food

T/SATA 084 applies to texture-modified foods intended for elderly with chewing or swallowing difficulties — that is, foods targeting the dysphagia and pre-dysphagia population. Products covered include:

It is not a standard for general “elderly-friendly” food like softer rice or less-salty soup — those fall under T/SATA 085.

T/SATA 084 defines 5 texture levels, which are explicitly designed to be interoperable with IDDSI:

T/SATA 084 Level Name (Chinese) IDDSI Equivalent
E5 流质照护食 (Thin fluid care food) IDDSI Level 0-1
E4 稠流质照护食 (Thickened fluid care food) IDDSI Level 2-3
E3 泥糊状照护食 (Pureed care food) IDDSI Level 4
E2 细碎湿润状照护食 (Minced and moist care food) IDDSI Level 5
E1 软质易咬食物 (Soft and easy-to-chew food) IDDSI Level 6

This IDDSI alignment is intentional and is the reason T/SATA 084 has been adopted so quickly — it lets GBA manufacturers use one texture framework that is simultaneously recognised in Hong Kong (HKCSS uses IDDSI), internationally (IDDSI global), and mainland China (T/SATA).

T/SATA 085-2025 — General Elderly Food

T/SATA 085 applies to general elderly-oriented food products — that is, food marketed to elderly consumers even if they do not have chewing or swallowing difficulties. Products covered include:

T/SATA 085 does not impose texture levels — instead it defines nutrition targets, labelling requirements, and claims standards for products marketed to elderly populations. This prevents generic “senior-friendly” marketing claims from being made without substantiation.

In practice: if your product targets dysphagia specifically, comply with 084. If your product targets elderly generally (softer but not texture-modified for dysphagia), comply with 085. Many full-range manufacturers need to comply with both.

T/SATA 084 — Texture testing requirements

T/SATA 084 adopts and adapts the IDDSI testing methods for elderly care food. The core tests a manufacturer must perform and document for every product batch are:

1. Fork drip test (叉子滴落测试)

For pureed (E3) and thickened fluid (E4) foods. A standard stainless steel dinner fork is used. The test liquid or puree is scooped onto the fork, held 5-10 cm above a plate, and the drip pattern is observed.

2. Spoon tilt test (勺子倾斜测试)

For pureed (E3) foods. A standard teaspoon is filled with the puree, then tilted 90°. The puree should fall off the spoon in a single mound, leaving minimal residue. If it runs off in a stream, it is too thin for E3.

3. Fork separation test (叉子分离测试)

For minced and moist (E2) and soft (E1) foods. Pressure is applied to a sample with the side of a fork (about 17 kPa — the pressure easily achievable by pushing down with the tines). Particles should separate cleanly.

4. Flow test (流动测试) for thin liquids

For E5 (thin fluid) products. Uses a standardised 10 ml syringe (IDDSI flow test syringe). The liquid flows through for 10 seconds; the volume remaining is measured.

All four tests must be performed and recorded on product development, on every batch run, and included in the product quality record.

Homogeneity requirement

A crucial specific requirement of T/SATA 084 that manufacturers often miss: the texture must be homogeneous throughout the entire batch. A puree that is Level 4 at the top of the pot and Level 5 at the bottom (common with starch-thickened products that settle) fails the standard.

This has practical implications:

T/SATA 084 — Nutrition requirements

Beyond texture, T/SATA 084 specifies minimum nutritional parameters for elderly care foods, because pureed food is often nutritionally diluted compared to regular food.

Per 100 kcal of finished product:

Per meal-sized serving:

Products that do not meet these minima cannot be labelled as “照护食” (elderly care food) under the standard. They can still be sold, but not under that claim.

T/SATA 084 — Labelling and packaging requirements

A product compliant with T/SATA 084 must display:

  1. The T/SATA 084 texture level (E1-E5) on the front of pack, in at least 14-point font.
  2. The IDDSI level equivalent (optional but strongly recommended for export and HKCSS-directory compatibility).
  3. The target user group — e.g., “适用于咀嚼吞咽障碍人群” (suitable for chewing and swallowing difficulties).
  4. Preparation instructions — reheating time, target temperature, any stirring requirement before serving.
  5. Storage and shelf life — including post-opening shelf life.
  6. Nutritional panel in the GB 28050 national food labelling format.
  7. A visual texture reference — a photograph or illustration showing the correct finished texture, so caregivers can verify.
  8. An allergen statement — GB 7718 compliant.
  9. A manufacturer contact including a customer service number for adverse event reporting.
  10. Batch number and production date.

Missing any of the above means the product is not compliant and cannot use the “T/SATA 084 compliant” claim.

T/SATA 085 — Nutrition and claims requirements

T/SATA 085 is more about what you can and cannot claim for elderly-marketed foods than about physical texture.

The key substantiation requirements:

“Senior-friendly” (适老) claims require the product to:

“Easy to chew” (易咀嚼) claims require the product to:

“Low sodium” (低钠) — must meet ≤120 mg sodium per 100 g solid or 100 ml liquid (consistent with GB 28050 definitions).

“High protein” (高蛋白) — must meet ≥12 g protein per 100 g, or contribute ≥20% of energy from protein.

“Sugar-free” (无糖) — must meet ≤0.5 g sugar per 100 g / 100 ml (this is the same as T/SATA 084 for care foods, aligning with Hong Kong Cap. 132W and Cap. 362 regulations).

Products marketed to elderly without substantiation for these claims are in breach of the standard and can be challenged by retailers, regulators, or competitors.

How T/SATA standards relate to other frameworks

A key reason T/SATA 084 has been adopted so rapidly in the GBA is its explicit interoperability with other relevant frameworks:

IDDSI (international) — T/SATA 084 levels E1-E5 map directly to IDDSI levels, with identical or near-identical testing methods. A product compliant with T/SATA 084 Level E3 is by construction also compliant with IDDSI Level 4. This allows single-product dual-market positioning.

HKCSS Care Food Directory (Hong Kong) — The Hong Kong Council of Social Service maintains a Care Food Directory listing products suitable for the elderly with dysphagia. HKCSS uses IDDSI as its texture framework. Products compliant with T/SATA 084 and using IDDSI labelling can qualify for HKCSS directory listing with minimal additional testing.

JSDR (Japan) — The Japan Society of Dysphagia Rehabilitation (JSDR) maintains its own texture framework (JSDR 2013 and 2021 editions). T/SATA 084 and IDDSI both map approximately to JSDR levels, though the Japanese framework has finer gradations. See our JSDR vs IDDSI mapping article (forthcoming).

GB 29921 (mainland China national standards for functional food) — T/SATA standards are group standards (团体标准) and do not override national food safety standards (国标 GB). A product must comply with all applicable GB standards for microbiology, additives, pesticide residues, packaging, and labelling in addition to T/SATA 084/085.

Taiwan 國民健康署 elderly food guidelines — Taiwan’s Health Promotion Administration publishes elderly food recommendations that are broadly compatible with T/SATA 084. Cross-strait manufacturers can use a single product formulation with minor labelling changes for both markets.

Compliance pathway for a new product

For a manufacturer developing a new T/SATA 084 and/or 085 compliant product, the typical pathway is:

Stage 1 — Product design (4-8 weeks)

Stage 2 — Pilot production (2-4 weeks)

Stage 3 — Third-party testing and certification (4-8 weeks)

Stage 4 — Documentation package and T/SATA registration (4-6 weeks)

Stage 5 — Market launch

The total pathway is typically 4-6 months for a well-planned product, and up to 9 months for a first-time manufacturer.

Common pitfalls we see in the GBA market

Having worked with GBA manufacturers on dysphagia food compliance, we see the same mistakes repeatedly:

  1. Using starch as the primary thickener and failing homogeneity testing. Starch settles, digests in saliva, and creates batch-to-batch variance. Xanthan gum or xanthan-blend thickeners are the reliable choice for T/SATA 084 compliance.

  2. Claiming “低钠” (low sodium) without meeting the <120 mg / 100 g threshold. Products often have sodium in the 150-250 mg range and still use “low sodium” marketing. This is non-compliant.

  3. Not verifying homogeneity throughout the pack size. A 500 g tub of puree often has texture that varies top-to-bottom after 48 hours of refrigeration. The standard requires the product to be homogeneous at time of consumption, not time of packaging.

  4. Using “IDDSI compatible” claims without third-party verification. Self-declared IDDSI compliance is not acceptable under T/SATA 084 for commercial claims. You need documented testing.

  5. Missing the photograph-based texture reference on the label. This is a specific T/SATA 084 requirement that manufacturers often overlook.

  6. Claiming “易咀嚼” (easy to chew) on products that actually require chewing. The “easy to chew” claim has a specific testing methodology under T/SATA 085 — you cannot use it as a generic marketing line.

  7. Marketing to dysphagia patients without complying with T/SATA 084. Simply being an elderly-oriented food under T/SATA 085 is not enough if you imply the product is safe for people with swallowing difficulties. If your marketing targets dysphagia, you need 084, not 085.

The bigger picture

T/SATA 084 and 085 are fast becoming the default elderly food standards for the Greater Bay Area and increasingly for other first-tier mainland cities (Shanghai, Beijing, Hangzhou). For any Hong Kong or mainland manufacturer serving the elderly market, compliance is moving from “nice to have” to “required for serious retailers and care home purchasers.”

The good news is the standards are well-designed, internationally compatible (especially with IDDSI), and have reasonable compliance pathways for competent manufacturers. A product built correctly to T/SATA 084 can simultaneously serve the mainland GBA market, the Hong Kong HKCSS-directory market, and the international IDDSI-aligned market with a single formulation — a rare case of regulatory alignment reducing cost rather than increasing it.

For Hong Kong social enterprises and startups entering elderly food, T/SATA 084 / 085 compliance should be built into the product from day one, not bolted on after launch. Retrofitting is expensive and often requires reformulation.


This article is part of the SeniorDeli Dysphagia Knowledge Hub, a free public resource from Carewells Limited (華瓏有限公司), a Hong Kong social enterprise providing texture-modified care food for elderly with swallowing difficulties. We publish regulatory and standards guidance because we believe better-informed manufacturers produce better food for the people we all serve. This article is for general guidance; compliance with T/SATA standards requires engagement with an authorised tester and SATA itself — please consult their official published text and an experienced food safety consultant for implementation.