On January 13, the State Administration for Market Regulation issued a public consultation on the "Announcement on the Release of the Directory of Health Functions Allowed for Health Food Claims for Non-Nutrient Supplements (2022 Edition) and Supporting Documents" (Draft for Solicitation of Opinions).
1. Categories of Health Food
Health food is a common term for health supplements. In the market, health supplements generally refer to health food. Health food is a kind of functional food that belongs to the category of food. It is only suitable for specific groups of people to consume, has the function of regulating human body functions but does not aim at treating diseases, and does not cause any toxicological harm to the human body. It includes two major categories: nutrient supplements and food with specific health functions. Nutrition-enhanced health food has the function of strengthening nutrition, which can specifically supplement the nutrients lacking in the human body, restore the body to its normal state, and assist in the treatment of diseases caused by lack of certain nutrients. It has no definite effect but has a certain nutritional value. The effects will be apparent after supplementation, and symptoms will improve, but appropriate supplementation is required, as excessive intake can be harmful to the body. For example, health food that supplements nutrients such as calcium, magnesium, iodine, iron, zinc, selenium, VA, VC, VD, VE, B vitamins, carotene, folic acid, amino acids, proteins, dietary fiber, etc. Functional health food, which is the food with specific health functions allowed to be claimed in this announcement, is mainly extracted from biological sources and made into compound products, which have certain health benefits for the body. Among them, the extracted functional components can regulate human body functions by activating enzyme activity or other ways, and their value lies in health maintenance and regulation, rather than nutrition.
2.Changes in Health Function Claims for Health Food between Old and New Versions
The draft consultation document proposes to cancel three health functions that are inconsistent with the current positioning of health functions, namely, promoting lactation, improving growth and development, and improving skin oiliness. It also proposes to cancel four health functions that the former Ministry of Health no longer accepts for approval, including inhibiting tumors, assisting in tumor inhibition, anti-mutation, and delaying aging. After adjustment, 24 health functions such as "enhancing immunity" have been retained, and the corresponding expressions have been adjusted and standardized accordingly. After research, argumentation, and standardization, the adjusted health functions are more scientific and feasible in the following aspects: Firstly, they comply with the health function positioning set by the "Directory Management Measures", which aims to "maintain and improve the health status of the body or reduce the risk factors for disease occurrence"; secondly, they have sufficient scientific basis, evaluation methods, and judgment standards; thirdly, there are clear appropriate and inappropriate target populations; fourthly, they are in line with international standards, and there are similar functional claims and related products internationally; fifthly, the naming of health functions is more scientifically rigorous, easy to understand, and can be correctly understood and recognized by consumers, avoiding confusion with drug prevention and treatment effects.
3.Management Transition of Health Food
The announcement states that, from the date of issuance, the production of products related to the seven canceled health function claims, including promoting lactation, improving growth and development, improving skin oiliness, inhibiting tumors, assisting in tumor inhibition, anti-mutation, and delaying aging, should be immediately stopped. Those already produced can be sold until the expiration date. In addition to the seven health functions that are no longer included in the health function directory, for the approved health functions that have not been canceled and are not included in the health function directory, they will be converted based on the transition of old and new health function claims and the latest evaluation requirements. If they cannot be converted, suggestions for inclusion or adjustment to the health function directory can be proposed to the review agency in accordance with the "Directory Management Measures", and those that meet the requirements will be included or adjusted in the "Functional Directory". For health functions that have already been included in the "Functional Directory", the transition of old and new health functions will be implemented in accordance with the supporting interpretation measures of the "Functional Directory". For approved health food products where all health functions have been canceled, the functions can be changed in accordance with the "Measures for the Registration and Filing of Health Food"; for those where some health functions have been canceled, adjustments will be made based on the transition of health function claims. Except for products with canceled health functions, health food products with health functions that do not comply with the "Functional Directory" should stop production and sales five years after the issuance of this announcement.
4.The Relationship between Natural Products and Health Food
Natural products possess significant advantages in the development of health food due to their natural, safe, and low-toxicity characteristics. Currently, more and more health food products directly or indirectly incorporate extracts of plant-based natural products, which play a significant role in promoting human health and immune system regulation without causing any toxic or side effects. Commonly used active ingredients include saponins, polysaccharides, oligosaccharides, flavonoids, and fatty acids.
Among them, Chinese herbal medicines containing saponins, such as ginseng, American ginseng, astragalus, and calendula, primarily achieve effects like relieving fatigue, antioxidation, and promoting growth and development. Chinese herbal medicines containing polysaccharides, including ganoderma lucidum, Cordyceps sinensis, angelica sinensis, safflower, tremella fuciformis, and wolfberry, primarily achieve effects like assisting in reducing blood lipids and enhancing immunity. The Chinese herbal medicine containing oligosaccharides is konjac, which helps prevent constipation, improves gastrointestinal function, and aids in weight loss. Chinese herbal medicines containing flavonoids, such as ginkgo biloba leaves, pollen, and nuts, primarily achieve effects like lowering blood pressure and reducing blood lipids. Additionally, traditional Chinese medicines with both medicinal and edible uses that contain fatty acids, such as vegetable oil and shark oil, primarily achieve effects like assisting in reducing blood lipids.
Moreover, there are other widely used Chinese herbal medicines in the development of health food, such as kudingcha (Ilex kudingcha), licorice root, rosa roxburghii, pumpkin, gastrodia elata, and Chinese yam, which achieve effects like enhancing human immunity, protecting the liver, and aiding in weight loss.
5.Development Trends of Health Food
In recent years, with the younger generation's emphasis on health maintenance, the consumer group structure and purchasing habits in the health food market have also undergone changes, with a trend of younger consumers emerging in the domestic nutrition and health food market. According to the "Post-90s Health Maintenance Diary" released by Ipsos, emotional health, body management, and sleep improvement are the top three health demands for the post-90s generation, with health food being one of the many options. The consumption demand for health food among young people is vastly different from that of middle-aged and elderly groups. They reject taking health food like medicine and prefer nutritional supplements that are both tasty and convenient like snacks, while still possessing health benefits.
The trend of snackification in nutrition and health food has also brought about product innovations in the upstream and downstream industrial chains of the nutrition and health food industry, with dosage form innovation being the most prominent. Traditional health food products in the form of capsules, powders, and other formats are not convenient to consume. The traditional "medicine-like" dosage forms of health food are shifting towards snack-like formats that are preferred by young people, such as candies and bottled drinks. This has led to the emergence of numerous innovative products that attract young consumer groups.
Health food contains a certain amount of functional ingredients that target specific populations, able to regulate human body functions, achieve specific effects, and satisfy people's different psychological needs for health. However, it cannot replace medication and is only a supplement for bodily function regulation. From the current types of health food products on the market, most are those that contain certain functional factors or ingredients, targeting specific populations to perform supplementary and regulatory functions, allowing the health benefits to be fully realized. With the implementation of relevant regulations and standards, making full use of abundant, nutritious, and health-promoting raw material resources, such as coarse cereals and edible fungi, combined with modern food processing technologies, will enable the development of unique and highly nutritious health food products with greater market potential.
References
[1] https://www.samr.gov.cn/hd/zjdc/202201/t20220113_339092.html
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About the Author: Xiaomichong, a researcher in pharmaceutical quality, has been dedicated to pharmaceutical quality research and verification of drug analysis methods for a long time. Currently, she works in a large domestic pharmaceutical research and development company, engaged in drug inspection analysis and verification of analytical methods.
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