China Unveils Health Food Naming Guidelines 2019

On Nov. 12, 2019, China SAMR promulgated “Health Food Naming Guidelines 2019”, which applies to all health food subject to registration or filing in China. This regulation stipulates that all product names must be accurate and cannot indicate any disease prevention or treatment function. Besides, one registered/filed product formula can only be associated with one product name.

Health food product names consist of the brand name, generic name and attribute name. Here are the corresponding major requirements:

Brand name

The characters used shall conform to “Trademark Law”, and the brand name cannot explicitly or implicitly suggest disease prevention or therapeutic efficacy. For example, products with the function of eye fatigue relief are not allowed to be named as “Good Eyesight” (“好视力”in Chinese).

Generic name

Generally, the generic name of a registered drug cannot be used, with the exception of situations where the active ingredient is approved for use as both a drug and a health food and the drug has already been named after this primary active ingredient. Exceptions also apply in situations where the health food registration was granted prior to drug registration approval.

If the product is made from a single active ingredient, then it shall be named after this active ingredient’s name or its abbreviation. If the product contains multiple active ingredients, the active ingredient with the highest concentration shall be used as the products generic name.

Attribute name

Attribute name indicates the product’s dosage form or food classification, and its naming shall follow the corresponding national food safety standard, industry standard or local standard where applicable. Otherwise the “Chinese Pharmacopoeia” will be the reference used if the dosage form is similar to a drug dosage form as specified within this document.

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