What are Special Dietary Foods in China and How to Import them - Regulatory News - Food & Food Contact Materials

Different with general foods in China, special dietary foods are formulated for certain groups (e.g. infant, pregnant woman, exerciser) who have special dietary requirements. With the growing pursuits for healthy lifestyle, such products with balanced nutrients and customization features have become a trend. Here CIRS will introduce the basic conditions of special dietary foods in China, and help you better understand how to get access to China market successfully.

What are Special Dietary Foods in China?

I. The special dietary foods are specially processed or formulated food that meet the special physical or physiological conditions and/or meet the special dietary needs of diseases, disorders, etc. The nutrients contents are significantly different with the similar general foods.

II. There are several kinds of special dietary foods in China as follows.

Category	Details	Registration or not
Infant formula	Infant Formula (GB10765-2010)	Infant formula milk powder registration under CFDA
	Old Infant and Young Children Formula (GB10767-2010)
Infant complementary foods	Cereal based complementary foods for infants and young children (GB10769-2010)	No registration
	Canned complementary foods for infants and young children (GB10770-2010)
Foods for special medical purposes (FSMP)	Infant foods for special medical purposes (GB25596-2010)	Registration under CFDA
	Foods for special medical purposes (GB29922-2013)
Others	Complementary nutritional supplements (GB22570-2014)	No registration
	Sports nutrition food (GB24154-2015)
	Nutritional supplements for pregnant women and nurse (GB31601-2015)

Except infant formula milk powder and FSMP, there is no registration requirement for other special dietary foods, which means, the importation of those products will be very similar with general food.

If your products can be classified into those categories and meet relevant GB requirements, it will be much easier to import them to China than the foods need registration (such as health food). As the infant complementary foods are more familiar to public, here we will focus on the following 3 kinds of special dietary foods.

Part I Complementary Nutritional Supplements

Definition

I. Complementary nutritional supplements refer to supplements containing a variety of micronutrients (e.g. vitamins and minerals). This kind of supplements may (not) contain base materials and other accessories.

II. They are used in the instant complementary foods for infant of 6-36 months, and they can also be used for children of 37-60 months.

Product Advantages

I. A variety of vitamins & minerals are available

Components of the products include Ca, Fe, Zn, Vitamin A, Vitamin D, Vitamin B1, Vitamin B2, Vitamin K1, Niacin, Vitamin B6, Folic Acid, Vitamin B12, Pantothenic Acid, Choline, Biotin, Vitamin C, and DHA.

II. Suitable for infant and children

Compared with similar health food, there is no registration or filing requirement for this product currently;
Compared with general food, the suitable crowd of this kind of supplements, infants or children, can be claimed on the label with sufficient legal basis.

Part II Sports Nutrition Food

Definition

I. Sports nutrition food is the specially formulated food for exercisers, to meet their physiological metabolism, exercise capacity and special needs of nutrients.

II. The exercisers refer to the groups that participate in physical exercise 3 or more times per week, with the duration of 30mins or above for each time, and each exercise intensity reached moderate or above.

Product Advantages

I. Target at exercisers

II. More nutrients are available than general food

Nutrients, such as creatine, Mn, Mo, Cr, Se, which are not allowed to use in most general foods are available for sports nutrition food.

Part III Nutritional Supplements for Pregnant Women and Nurse

Definition

The nutritional supplements for pregnant women and nurse are foods that specially processed with high-quality proteins and a variety of micronutrients (e.g. vitamins and minerals), which are suitable for pregnant woman and nurse to supplement nutrients.

Comparison with the formulated milk powder for pregnant women

There is a general food category for pregnant women in China as well, which is formulated milk powder for pregnant women. This kind of food products is different with nutritional supplements for pregnant women and nurse. The public may confuse the two different products easily.

Differences	Nutritional supplements for pregnant women and nurse	Formulated milk powder for pregnant women
Product standard	GB 31601-2015	GB 19644-2010 milk powder
Labeling standard	GB 13432-2013	GB 7718-2011, GB 28050-2011
Nutrients content	This product contains high density nutrients, and the nutrient contents are significantly higher than the other one. Some nutrients are only allowed for this product, e.g., DHA, biotin.	The nutrients are all optional to add. Some nutrients are only optional for this product, e.g., Mg, Cu.

Part IV How to Import these 3 Kinds of Special Dietary Foods?

S.N.	Items	Detailed requirements
1	Importer and exporter record	The overseas food exporter or his agent should apply for the record to AQSIQ. The importer should apply for the record to the local CIQ.
2	Product GB analysis	Evaluate the product category, to find out the suitable GB standard based on the formula, production process, final product form and etc.
3	Formula check	The product formula shall comply with relevant product GB standard; The usage of food additives and nutrition enhancers added in the products shall comply with GB 2760-2014, GB 14880-2012 and relevant NHFPC Notices.
4	Nutrition information report	The nutrition information report of imported food should be submitted when importing, which includes the energy, protein, fat, carbohydrate, sodium, added nutrients, and other nutrients with nutrition claims. Currently in Guangzhou CIQ, the report shall be issued by qualified lab within 3 months when importing, and the results shall be re-tested every half year. (based on the information from Guangzhou CIQ website)
5	GB test report	GB test in qualified lab before importing is an effective way to guarantee the product quality and avoid unnecessary rejection. Currently in Shanghai CIQ, the test report covers all items listed in corresponding GB standard is required for the first imported complementary nutritional supplements products. And for the re-import, the additional test report is also required. (based on the information from Shanghai CIQ website)
6	Chinese label	The Chinese label shall be designed in accordance with GB 13432-2013 and the corresponding product national standard. The original label shall be checked to confirm if there is any forbidden claim or risk claim in China.
7	Material preparation	Contract, invoice, parking list, certificate of origin, and other relevant certificates are required when importing.

In summary, these special dietary foods can be processed with more nutrients, and the suitable crowds are very clear. Enterprises can consider finding out if their products can be imported under these categories. Besides, although they are not required to apply for registration before importing, the product quality requirements are significantly higher than general food, and different local CIQs may have some detailed different requirements. Therefore, it is recommended to conduct pre-review before entering China market.

If you have any needs or questions, please contact us at service@cirs-group.com.

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