and DaiGou (the latter means “purchasing on behalf of” in
Mandarin; i.e., an overseas person purchases goods for a
customer in mainland China). One of the most talked about
items is Pola White Shot, which claims beauty benefits of
anti-hyperpigmentation, whitening, minimizing pores with
actives like L-cysteine and vitamins C, E, and B2.
A prosperous China is fueling domestic demand in nearly all beauty- and wellness-related sectors, including inner
beauty products. The question here should not be “if,” but
“when;” especially after recent regulatory adjustments toward more open administration of nutraceuticals.
Based on the current China regulatory system, nutraceuticals fall into two different categories: conventional food and
functional food (including both health food/beverage and nutritional supplements). While neither is allowed to make any
claim on therapeutic effect or replacing medical treatment,
the two are subject to very distinctive regulatory controls.
Specifically, conventional foods can make statements
about the presence or amount of nutrients (content claims)
or the functions of nutrients on normal physiology (general
function claims). However, they cannot contain any ingredient listed in the Functional Food Raw Materials Directory,
or make any health claims. Functional foods are defined
as food/beverage/supplement products that have specific
health functions or replenish nutrients, and are required to
make clear statements on the specific groups of people they
are suitable and unsuitable for, as well as the exact amount
to be consumed.
It is also worth noting that when it comes to health
claims for functional foods, only the subcategory of health
food/beverage is allowed to make ones specified in the
Functional Food Health Claims Directory, and nutritional
supplements can only claim nutrients, mainly vitamins and
minerals. A Blue Hat symbol is labeled on any approved
functional food to help distinguish it from other non-ap-proved ones and conventional food, giving consumers safety
and efficacy assurance.
Got all that? Regulators have intended to clarify issues
with the Administrative Measures on the Registration and
Recordation of Functional Foods, which came into force July
2016, the Functional Food Raw Material Directory (Part I)
and the Functional Food Health Claims Directory (Part I)
issued in January 2017, and the Proposal for Reinforcing
Supervision of Functional Foods (Draft for Public Comment) posted in April by CFDA (China State Food and Drug
All of these measures reflect CFDA’s new way of think-
ing. While there are still two types of policies (registration
and recordation filing) for functional food produced or mar-
keted in China, registration will largely replace recordation
filing, which as a result relaxes market entry but tightens
up raw material management and post-launch supervision.
In order to facilitate the changes, CFDA is also expected
to expand the Raw Materials and Excipients Directory
for Functional Food. Along with those materials listed in
Medicinal and Edible Product Directory and New Food Re-
source Directory, there should be much room to play for nu-
traceutical manufacturers in China.
Ingredients in Activity
Players in China’s inner beauty market need to pay particular attention to claims as well as ingredients before marketing any product to consumers. There is no such generic
claim as “beautifying” or “skin care” allowed by legislation
for either conventional or functional foods, however, some
specific claims and/or ingredients could be used to help
products convey beauty-related messages, and avoid food
For health food/beverages, among the 27 health claims
specified by the Functional Food Health Claims Directory,
quite a few can do the job, ranging from anti-acne and anti-chloasma to improve skin hydration, balance skin oil and
antioxidation. Others could also be translated into similar benefits in a more holistic way, like: improve immune
function; assist protecting from harmful radiation; improve
nutritional anemia; weight loss; regulate intestinal microbiota; improve sleep quality; and alleviate fatigue.
In contrast, conventional food and beauty supplements
are only allowed to state nutrient content instead of physiological effect. Therefore, companies can manage to use
materials listed in the New Food Resource Directory and
Medicinal and Edible Product Directory to imply beauty
benefits of their products. The latter actually reflects an
ancient Traditional Chinese Medicine (TCM) theory, called
medicine-food homology, meaning certain Chinese medicinal materials can be used as foods due to their same origins.
Expected to be issued soon, the directory is largely in line
with the government attempt to promote TCM both nationally and internationally.
Among 116 exempt TCM materials listed in the Medicinal and Edible Product Directory, quite a few are already in
widespread applications in inner beauty products, such as
jujube red date (Chinese date) and Job’s Tears (Coix lacry-ma-jobi). Donkey-hide gelatin (gelatin obtained from donkey skin), known as EJiao in TCM, is particularly successful here. EJiao-based products improve anemia and have
antioxidant properties, which Chinese consumers interpret
as improving skin complexion.
Another approach to ensure the legality of claims and
ingredients is to use the materials as “new food resources”