China Consults on Health Food Naming Guideline

On Oct. 22, 2018, China SAMR opened “Health Food Naming Guideline (Draft)” for public feedback and any comments could be sent back prior to Nov. 16, 2018. The draft states that a health food’s name consist of different parts including its brand name, common name and generic name. Detailed requirements below:

Prohibited words in brand name & common name

• False, exaggerated or absolute words

• Words that indicate diseases treatment or prevention

• Vulgar or superstitious words

• Use of names of human organs

• Symbols except “®”

• Other misleading words

Furthermore, there are some additional restrictions for common name, including:

• Registered common name of drug cannot be used except that the product is named after ingredient or the name have been registered by health food before the drug name registration.

• A name indicating a physiological parameter..e.g. digestion (digestease)

• Misleading ingredient abbreviation is not allowed.

Inspection requirements for health food name

Brand name

The brand name cannot express, suggest or allude to any health care function. For example, if the product function is weight loss then the brand name could not be named “Good Figure”.

Common name 

The substance’s standard name should use the actual name of the active (functional) ingredients response for the products ability to impact physiological parameters or its ability to supplement vitamin/minerals. For instance, “Panax notoginseng” (the scientific name) shall be used to name the product rather than “pseudo-ginseng”

If the ingredient used in health food is extracted by some special technique and its characteristic are significantly different from the substance from which the active ingredient was derived, then the product cannot be named after the source material. For example, if the health food product contains soy isoflavone or soybean extract, “soybean” cannot be used to name this product.

For nutrient supplements, vitamin and mineral substances contained within the product should all be listed with their full name, such as “Vitamin C” and “Calcium”. If there are over 3 Vitamin/mineral substances, it could say “multi- Vitamin and/or mineral substances”.

Generic name

If the product is manufactured in a format/shape which already has a corresponding national food safety standards (biscuit, beverage, candy) then the generic name should follow the naming rules listed within the corresponding national standard. If this rule does not apply then the generic name should follow the “China Pharmacopeia”.