A nod to a rising consumer focus on brand trust and quality control, the Chinese government has changed the requirements surrounding claims made by the functional health food industry. In a draft, “Opinions on Health Food Function Claim Management,” published on December 14th, 2016 the Chinese Food and Drug Administration (CFDA) moved to further regulate the industry by requiring explicit wording in the expression of health food claims.

The draft established three separate wording guidelines depending of the type of claim:

Consensus-based claims: “this product has the function of….validated by substantial scientific evidence.”

Credibility–based claims: “this product has the function of…validated by scientific literatures and a small sample of human feeding trials.”

Possibility-based claims: “this product has the function of…validated by scientific literatures and animal test data, but has not undergone randomized human clinical trials.”

This means if a health food product wants to make a functional claim, such as improving circulation or lowering cholesterol, the product’s label must be in accordance with the wording listed above. Any product claiming to have some sort of functional effect must follow these standards. This clarifies a product’s scientifically proven effectiveness and moves to further educate consumers.


As the health food market matures, the government — and consumers themselves — are requiring more information and food safety regulation of producers. Consumers are no longer new to health food and are educated on the potential for false claims and misleading information within the industry. The government is beginning to put down new laws to combat false advertisement from imported producers.

The new standards for health food claims are also a reflection of the ever-increasingly complicated process for foreign functional health food products to enter the Chinese market. It is extremely important for exporters to carefully evaluate their functional claims prior to entering the market, as each claim comes with different requirements and regulations.

If company wants to label their products with any of the claims mentioned in this article, they must register their product as health food. Companies must have foresight when registering their products, as their registration classification impacts their future advertising restrictions in China. For more information on this topic, read this Knudsen&Co article.

As illustrated by this new draft, regulations can be as detailed as controlling the sort of wording required on a certain product’s label. In order to remain compliant with the Chinese government’s regulations, foreign companies must maintain a vigilant watch over the CFDA’s constantly updating guidelines.

It is important to understand that the new wording standards were merely published as a draft. Drafts serve to act as a warning system from the Chinese government to relevant industry actors, demonstrating a future change in guidelines. It also means that the CDFA is able to add further changes to the draft before finalizing it into law. This particular draft was closed on December 30th, 2016 — meaning the public can expect a finalized version in the near future.
This announcement is not only an indication of the increasing consumer education concerning health food claims, but also the power wielded by the Chinese government when controlling imported products in their own market. The draft is merely a small part of the huge undertaking by the government to strictly control food safety in order to insure consumer protection in recent years. In order thrive in China, companies must maintain compliance with regulations that are sure to become even more complex in the future.

CDFA Announcement: Opinions on Health Food Function Claim Management