Top Chinese Officials Outline Future of Special Foods in China

From Oct. 30th 2018 to Nov 1st, The 3rd China Special Food Conference was held by China Nutrition and Health Food Association. The conference was attended by officials from China’s food safety competent authorities and also by industry experts. Special food and food for special dietary uses were the focus of the conference. Notable attendees included the Director of Special Food Safety Supervision Department Zhou Shiping, Han Yi prominent official of China’s General Administration of Customs (GAC), Zhang Zhiqiang member of China National Health Commission (NHC) and Han Junhua official of China Food Safety Assessment Center (CFSA).

Director of Special Food Supervision Department: Zhou Shiping

1.SUPERVISION DYNAMICS

Infant Formula

2018 marked both the inaugural formation of China’s Special Food Supervision Department and was also the 10th anniversary of the Sanlu melamine scandal. Other important milestones in 2018 included: 

• Draft versions of the new GB 10765/10766/10767 (infant formula product standards for each product stage) were opened to public comments for one month and about 250 responses were received for each standard

• Administrative Measures For Infant Milk Powder Recipe Registration is being amended

• Administrative Measures For Filing Of Infant Food and Technical Guidance For Change Of Registered Infant Milk Powder are under development

• Review of application materials, inspection and supervision were strengthened precipitating a crackdown on false advertisements and non-compliant labeling of infant formula sold in maternal stores.

As of Oct. 17, a total of 1195 infant formula products have been granted registration certificates and 168 products had simple changes made to their registration information, such as change of factory site, sample label, legal representative etc.. (see table below)

Health Food

China is planning to prioritize, develop and expand the filing system used for health foods and deprioritize the role of registration.

• Currently 30 ingredients are under investigation in the 2018 Research on Health Food Ingredients List. Currently China’s health food filing system operates using a positive list, however the scope of this positive list currently only includes vitamins and minerals. There are plans to expand the positive list to include a more diverse range of active ingredients whose efficacy has previously been established (previously registered). The system would more closely mimic EFSA’s functional food registration system (active ingredient based compared to China’s current product orientated regulation).  

• Health Food Naming Guidance is currently in its consultation period

• Regulations for On-Site Inspection During Special Food Registration are under development after already undergoing consultation

• The health food registration procedure will also be optimized

Food for Special Medical Purposes

NHC consulted on Standards for Clinical Application of Food for Special Medical Purposes and three product standards for nutritionally complete FSMPs (for patients suffering from cancer, diabetes and inflammatory bowel disease). The authority has received a lot of feedback from industry and intends to consult with more industry insiders. The standard for clinical application of FSMP is centered on “Who can consume”, “Who shall not consume”, “How to use (including diagnosis and treat procedure)” and “When to prescribe”.

According to statistics shared by Chen Wei, nutrition expert at Peking Union Medical College Hospital, application of FSMP lead to an average reduction of hospitalization time and cost of 21%.

However, only 18 FSMPs have been granted approval by SAMR: 3 are domestic, 15 are imported, leaving several categories of FSMP without any registered products (see table below).

Food for Special Dietary Uses

At present CFSA is revising GB 10769 Standard for Cereal Based Supplementary Infant Food and GB 10770 Standard for Canned Supplementary Infant Food. This is the 4th revision: 1st in 1989, 2nd in 1997 and 3rd in 2010. Key revision goals are:

• Expand scope of permitted raw materials to include commonly used raw materials

• Add more product categories to cover all the products on the market, such as “ready-to-eat canned rice-paste infant food”.

• Unify and clarify calculating method of energy and carbohydrate

• Add maximum limits for more contaminants such cadmium (already published by NHC in June)

• Replace test methods with new ones

• Simplify product standards by citing requirements for food additives and contaminants of GB 2760 standard for food additives and GB 2762 standard for contaminants in food.

2. MARKET OUTLOOK

Infant Formula

The number of new infant milk powder products and premium products marketed in 2018 was more than in 2017.

Health Food

Average individual annual consumption of health foods has grown steadily from $16.6 in 2002 to $77.8 in 2016. There is still a sizeable gap in per capita health food consumption between China and developed countries which is generally considered as a marker of health food market growth potential in China.  .

Food for Special Medical Purposes

China’s domestic FSMP industry is immature with significant growth potential and therefore an enticing prospect for large multinationals. This potential is offset by demanding market entry barriers primarily erected by stringent technical barriers/regulatory compliance demands. In the past this category of product was considered a pharmaceutical and subject to GMP requirements, clinical trials etc. The promulgation of China’s Food Safety Law in 2015 saw FSMPs reclassified as a special food. However, despite this distinction, it would be best to consider the FSMPs as a borderline product with characteristics of both a food and a drug, and corresponding compliance demands tend to support this working model. According to the General Secretary of China Nutrition and Health Food Association Liu Xuecong “patience, scientificity and collaboration amongst manufacturers” is necessary to propel this fledgling industry into the next stage of its development.  

Supplementary Infant Food

In 2014, the whole infant food market was valued at 70.9b RMB. The supplementary infant food sector represented 7.9b RMB of this sector and is projected to reach 12.8b RMB based on its annual growth rate of 16%.

Interestingly China’s foremost dairy industry expert Song Liang was animated in his assertion that China’s infant formula and infant food sector had reached saturation point in terms of competition and advised investors to “seek fortune and development in other health industries such as foods for the elderly and teenagers, nutritional foods and health foods”.