Classification of products

In Chinese law, so-called health foods are foods that provide specific nutrients or claim clearly defined health benefits.

The most important practical distinction for an exporter who wants to know how to sell food supplements in China is as follows.

• If the product only supplements vitamins or minerals contained in the official catalogue, you may opt for the filing route.
• However, if you declare one of the health functions recognised by the Chinese framework, or if you use raw materials not covered by the archive catalogue, you will need to apply for a more stringent registration.

What can be filed and what requires registration

• The filing is intended for nutrient supplements included in the recognised directory. These are widely known vitamins and minerals (such as vitamins A, D, C, E, K and B group vitamins, and minerals such as calcium, magnesium, iron, zinc and selenium), in addition to other entries in the catalogue that the regulator has been consolidating. In these cases, the label must use standardised nutritional function claims.
• Registration is required when the product claims a health function permitted by the system (e.g., helps improve sleep, contributes to the regulation of the microbiota, or supports the maintenance of healthy levels of certain parameters), or when the formula includes materials that do not fit into the archive catalogue. Here, the requirements are more stringent: the dossier must demonstrate safety and efficacy using predetermined evaluation methods. Depending on the function, animal testing and/or human trials may be required, in addition to stability, method validation and consistency between the approved composition and the composition actually marketed.

One aspect that often raises questions is the treatment of certain raw materials that are popular globally but subject to specific restrictions in China. When dealing with any novel ingredient, it is prudent to verify its regulatory status and, if necessary, explore alternatives in formulas or adjust the claim to fit within the current framework.

Dosage forms and labelling

The regulations cover different dosage forms for products that are accessed by file, including tablets, hard and soft capsules, granules, powders, oral liquids, and gelatinised confectionery.

In practice, when considering how to sell food supplements in China, the market is receptive to convenient formats that are easy to dose, and values clarity in information about recommended daily doses and the population groups for which the product is intended.

In general commerce, the information must be displayed on the product page and in the accompanying document, including:

• Distinctive health food logo
• Registration or file number
• Declared function or approved claim
• Target audience and unsuitable population
• Warnings and other information required by applicable regulations

The use of stickers as a substitute for direct printing is not permitted. This point requires early coordination between regulatory and operational teams, as it affects packaging manufacturing, procurement lead times, and inventory management.

Differences between general trade and CBEC

General trade is the route that enables sales across all channels, including physical retail sales. For an importer, this means complying with the registration of the foreign facility in the corresponding customs system, processing the product file or registration with the market authority, and complying with labelling, sampling, and post-marketing surveillance. This also provides the opportunity to build a stable brand, with a presence in retail chains, pharmacies and specialised shops, and the ability to work with distributors who can re-market the product.

Cross-border e-commerce (CBEC), meanwhile, allows for faster entry into the cross-border online channel. It is possible to sell to end consumers through platforms such as Tmall Global, JD Global or Douyin with simplified regulatory requirements compared to general trade. In return, the exporter accepts restrictions such as no B2B resale, and the existence of “blacklists” and internal standards for each sales platform.

A common strategy is to start with CBEC to validate demand, learn about price sensitivity, adjust messaging and optimise the format, while simultaneously preparing the regulatory dossier for those references with the greatest traction for the leap to general commerce.

Do you have questions about trademark or intellectual property registration? At Get One Mark, our spin-off dedicated to patent and trademark registration, we can advise you on this process. Contact us!

Cross-cutting requirements that should be planned for

• Labelling and claims in general trade. The label must be printed in Chinese and include the distinctive logo, the registration or file number, the declared function, the population groups for which it is intended and those for which it is not suitable, and the mandatory warnings. Nutritional or health function claims must comply with the approved wording.

How to sell food supplements in China step by step

Phase 0 — Internal preparation and brand protection

1. Register the trademark in China in the relevant classes and subclasses, also considering effective transliteration. Activate monitoring to detect attempts at occupation and contractually reflect ownership and limits of use with distributors, agents, and platform operators. Count on Get One Mark to do this for you!
2. Analyse the portfolio by access route. Classify candidate references for CBEC (for rapid validation) and strategic references for general trade (for omnichannel distribution). Identify which ones are eligible for archiving because they are catalogue nutrients and which ones will require registration by function or raw material.
3. Conduct a regulatory analysis. Compare ingredients, daily doses and claims with current directories; adjust the wording of messages to comply with literal requirements; and estimate the test package required for registration. Document batch traceability and analytical methods from the outset.

Phase 1 — CBEC for rapid learning

4. Select platform (Tmall Global, JD Global, Douyin) and local operator with proven experience in health and nutrition. Define expectations, commercial calendar, deliverables and metrics (conversion rate, repeat purchases, campaign ROI, etc.) in agreements with clear service levels.
5. Configure compliance in CBEC. Prepare Chinese product sheets with accurate translations of labels, include visible risk warnings, and gather basic safety and quality evidence. Review negative lists and internal platform standards to avoid last-minute surprises.
6. Design logistics. Choose between customs warehouse or direct shipping, depending on demand forecasts and inventory control. Establish replenishment, stock control and returns management processes in line with peak seasons.
7. Launch marketing and channel operations. Plan live sales sessions with creators, optimise product pages, test variations in claims and formats, encourage verified reviews, and monitor sales, turnover, and incidents on a daily basis. Agility in response is key to maintaining traction on these platforms.

Phase 2 — General commerce for multiple channels

8. Complete the registration of facilities in the corresponding customs system for each plant that manufactures products destined for China. Without this registration, goods cannot be cleared at the border.
9. Determine the regulations for each product. In the archive, prepare the file with the formula, process, proposed labelling, analytical reports on batches and stability. In the registry, add the safety and efficacy testing plan in accordance with the claimed function, together with the validation of the methods used.
10. Execute the testing plan. Include, where applicable, toxicity studies (e.g., acute, genotoxicity, and repeated at 28 days), efficacy studies (in animals and/or humans, depending on the function), and stability studies under controlled conditions. Align laboratories, protocols, and schedules from the outset.
11. Adapt packaging and artwork. Print the label in Chinese with all mandatory elements and ensure consistency between the approved file and the final product. Verify that the supply chain can support specific packaging runs for the Chinese market without penalising the unit cost.
12. Prepare import operations. Establish procedures for customs declarations, import sampling, maintaining traceability records, and responding to requests from authorities.

Phase 3 — Hybrid commercial development

13. Negotiate with distributors and offline chains based on data generated in CBEC. Sales, ratings, and repeat rates provide objective data on product acceptance and facilitate better entry conditions, point-of-sale visibility, and campaigns.
14. Build the trade fair and business development agenda. Prioritise sector meetings that bring together relevant buyers and facilitate meetings with potential partners, both for the physical and digital channels. Prepare clear dossiers and sales pitches focused on rules, safety and benefits.
15. Establish pricing policy and channel control. Define recommended retail prices, identify signs of free riding or inventory diversion, and set contractual clauses that protect positioning and margins. Monitor parallel resale and act quickly in the event of incidents.