In recent years, with the rapid improvement of social medical level and the living standard, Chinese consumers are paying close attention to health. Besides, the outbreak of coronavirus pandemic since the beginning of 2020 has made everyone become more aware of the importance of health and the pursuit of health has become more urgent. Therefore, health food with specific health functions and/or could regulate body functions have gradually become the focus of consumers.
The regulations for health food are different in different countries/regions. To help companies have a better understanding of the general requirements for health food of different countries, CIRS has summarized the requirements of several countries/regions from various aspects such as deification, related regulations and compliance process and made a comparison as follows:
Category Name and Definition
For the health food products, their category names, and definitions are different in different countries/regions.
Table 1 Category name and definition of food supplement
Country/region |
Category name |
Definition |
---|---|---|
China |
Health food |
Health food refers to foods that claim to have specific health functions or supply vitamins and minerals. Health food is specific to certain group, and modifying organic functions in humans, but is not for the purpose of treating diseases, and does not cause any acute, sub-acute or chronic harm to the human body. |
USA |
Dietary supplements |
The term dietary supplement -(1) means a product (other than tobacco) intended to supplement the diet that bears or contains one or more of the following dietary ingredients: (A) a vitamin; (B) a mineral; (C) an herb or other botanical; (D) an amino acid; (E) a dietary substance for use by man to supplement the diet by increasing the total dietary intake; or (F) a concentrate, metabolite, constituent, extract, or combination of any ingredient described in clause (A), (B), (C), (D), or (E); Consumed as in tablet, capsule, powder, soft capsule or liquid; not as traditional foods, or as the only component of a diet. |
EU |
Food supplements |
Food supplements are concentrated sources of nutrients (i.e. mineral and vitamins) or other substances with a nutritional or physiological effect that are marketed in “dose” form (e.g. pills, tablets, capsules, liquids in measured doses). A wide range of nutrients and other ingredients might be present in food supplements, including, but not limited to, vitamins, minerals, amino acids, essential fatty acids, fibre and various plants and herbal extracts. |
Australia |
Complementary medicine |
Complementary medicine means a therapeutic good consisting wholly or principally of 1 or more designated active ingredients, each of which has a clearly established identity and a traditional use. Item Ingredient or kind of ingredient: 1. an amino acid; 2. charcoal; 3. a choline salt; 4. an essential oil; 5. plant or herbal material (or a synthetically produced substitute for material of that kind), including plant fibres, enzymes, algae, fungi, cellulose and derivatives of cellulose and Chlorophyll; 6. a homoeopathic preparation; 7. a microorganism, whole or extracted, except a vaccine; 8. a mineral including a mineral salt and a naturally occurring mineral; 9. a mucopolysaccharide; 10. non-human animal material (or a synthetically produced substitute for material of that kind), including dried material, bone and cartilage, fats and oils and other extracts or concentrates; 11. a lipid, including an essential fatty acid or phospholipid; 12.a substance produced by or obtained from bees, including royal jelly, bee pollen and propolis; 13. a sugar, polysaccharide or carbohydrate; 14. a vitamin or provitamin etc. |
New Zealand |
Dietary supplements |
The definition of dietary supplements is: 1. It is an amino acid, edible substance, herb, mineral, synthetic nutrient, or vitamin; 2. It is sold by itself or in a mixture; 3.It is sold in a controlled dosage form as a liquid, powder, or tablet (which might be described on the label as a cachet, capsule, lozenge, or pastille instead of as a tablet). 4. It is intended to be ingested orally; 5. It is intended to supplement the amount of the amino acid, edible substance, herb, mineral, synthetic nutrient, or vitamin normally derived from food. |
Canada |
Natural health product |
The definition of natural health product includes the purpose and ingredients: 1. purpose of natural health product include: the diagnosis, treatment, mitigation or prevention of a disease, disorder or abnormal physical state or its symptoms in humans; restoring or correcting organic functions in humans; or modifying organic functions in humans, such as modifying those functions in a manner that maintains or promotes health. 2. The raw materials of natural health products are allowed to use a total of 8 categories: 1) plants or plant materials, algae, bacteria, fungi or non-human animal materials; 2) extracts or isolates of the substances described in category 1), the main molecular structure and extraction Or the same before separation; 3) vitamins (biotin, folic acid, niacin, etc.); 4) amino acids; 5) essential fatty acids; 6) Composites of the substances described in categories 2) to 5); 7) Minerals; 8) Probiotics. |
ASEAN |
Health supplements |
Health supplements refer to any product that maintains, enhances and improves human health functions and is used to supply the diet, and contains one or more or a combination of the following: 1) vitamins, minerals, amino acids, fatty acids, enzymes, probiotics and other biologically active substances 2) Substances of natural origin, including animal, mineral, and vegetable substances in the form of extracts, isolates, concentrates, metabolites; 3) Synthetic sources of the ingredients mentioned in the first two items. Health supplements are presented in small dosage units such as capsules, tablets, powders, liquid dosage forms (to be taken) and do not include any sterile preparations (i.e. injections, eye drops) |
Japan |
Health functional food (保健機能食品) |
Health functional food covers 3 categories, including food for specific health use, functional labelled food and nutritional functional food: 1) Foods for specific health use refer to foods that contain health-care functional ingredients that affect the physiological functions of the body, help maintain normal blood pressure, cholesterol, and regulate the stomach and intestines, and are marked with specific health-care purposes. 2) Functional labelled food refers to the food produced based on scientific basis, not targeting patients, and by ingesting the "active ingredients" in such food, it helps to maintain or promote physical health. 3) Nutritional functional foods refer to health functional foods for the purpose of supplementing specific nutrients. |
Korea |
Healthy functional food (건강기능식품) |
Health functional food refers to food produced (including processed) using functional raw materials or raw materials useful to the human body, where "functional" refers to regulating nutrition for human body structure or function, or providing beneficial health care functions, such as physiological functions. |
Taiwan |
Health food (健康食品) |
Health food refers to products that have health benefits and are labeled or advertised to have such benefits. |
Related Regulations and Laws
For health food related products, each country has its own regulation framework. CIRS has summarized some relative regulations with health food in the table below.
Table 2 Food supplement relative regulations
Country/region |
Related regulations and laws |
---|---|
China |
Health Food Registration and Filing Regulation Guidelines for application of health food registration Health Food Filing Work Guide GB 16740-2014 Food national standard health food |
USA |
Federal Food, Drug and Cosmetic Act (FD&C Act) Dietary Supplement Health and Education Act (DSHEA) Nutrition Labeling and Education Act (NLEA) Current Good Manufacture Practice in Manufacturing, Packaging, labeling, or Holding Operations for Dietary Supplements (CGMP) |
EU |
2002/46/EC EC No 1924/2006 |
Australia |
Therapeutic Goods Act 1989 Therapeutic Goods Regulation 1990 Australian regulatory guidelines for complementary medicines |
New Zealand |
Dietary Supplements Regulations |
Canada |
Natural Health Product Regulation Pathway for licensing natural health products making modern health claims Pathway for licensing natural health products used as traditional medicines |
ASEAN |
ASEAN Health Supplements Agreement |
Japan |
Health Promotion Act Food Sanitation Law Revision of Operation and Guidance Points for Examination of Specified Health Foods Nutrition Labeling Standards |
Korea |
Healthy Functional Food Law Implementation Regulations of the Healthy Functional Food Law Enforcement Decree of Health Functional Food Law Healthy Functional Foods Codex |
Taiwan |
Healthy Food Control Law Enforcement Rules of the Healthy Food Management Law Health Food Application Licensing Measures Principles of Health Food Inspection and Registration Review |
Table 3 Regulatory requirments in different countries/ regions
Country/region |
Authority |
Compliance process |
---|---|---|
State Administration for Market Regulation and the market supervision and administration departments of provinces, autonomous regions and municipalities directly under the Central Government |
1) Registration: Use the ingredients outside the raw material dictionary and excipient dictionary 2) Filing: Use the ingredients listed in the raw material and excipient dictionary |
|
USA |
Food and Drug Administration (FDA) |
1 Responsible by the manufacturers and distributors: most products 2 Notification/registration: including the dietary supplement contains a new ingredient etc. |
EU |
The European Commission and the competent authorities of the Member countries. |
The compliance process is different in different EU member states, mostly notification/registration |
Australia |
Therapeutic Goods Administration (TGA) |
1) Registration: such as using the ingredients outside of the therapeutic Goods Listing Notice 2) Listed: Listed medicines are considered to pose a low risk to consumers than registered medicines, use the ingredients in the therapeutic Goods Listing Notice 3) Assessed listed: Use the ingredients in the therapeutic Goods Listing Notice but the added level exceeds the limit. |
New Zealand |
Medsafe |
1) No pre-approval process for most dietary supplements: dietary supplement must comply with the regulations and the sponsor shall be responsible for ensuring the product complies with the law. 2) Submit the declaration: dietary supplements containing folic acid |
Canada |
Nature and Non-prescription Health Products Directorate (NNHPD) |
Tiered registration (depending on product safety and feature claims) |
ASEAN |
ASEAN Consultative Committee on Standards and Quality (ACCSQ) and the authorities of member states |
Each member countries approves their own products (mostly registration) |
Japan |
Consumer Affairs Agency |
1)Registration: Food for Specified Health Use 2) Filing: functional labelled food 3)Self-certification: nutritional functional food |
Korea |
Ministry of Food and Drug Safety (MFDS) |
1) Registration: specific health functional food 2) Record: general health functional food |
Taiwan |
Health authority |
"Dual-track" inspection and registration: 1) Check and register according to the principle of case-by-case review (Track 1) 2) Comparing with the existing specifications and standards for inspection and registration (the second track system, currently only red yeast rice and fish oil) |
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