China SAMR Seeks Public Comments on Draft Amendment to the Food Safety Law: Health Food Filing Process Expected to Be Simplified

On October 10, 2026, China’s State Administration for Market Regulation (SAMR) released the Draft Amendment to the Food Safety Law of the People’s Republic of China for public comment.

The proposed amendments introduce several notable regulatory updates for the health food, aimed at streamlining approvals and updating product labeling requirements.

Key Proposed Changes & Industry Impact

1. Article 84 of the draft stipulates: After organizing a technical review, the SAMR shall conduct on-site registration inspections based on risk classification and grading. Products that meet the requirements for safety, functional claims, and quality control shall be granted registration; those that do not meet the requirements shall be denied registration, with the reasons stated in writing.

CIRS Interpretation: “Conducting on-site registration inspections based on risk classification and grading” may imply that, in the future, low-risk health foods—such as products with simple formulations and manufacturing processes—may be exempt from on-site inspections or have their on-site inspection requirements simplified, thereby significantly improving the approval efficiency for registration-based health foods.

2. Article 84 of the Draft stipulates: For health foods imported for the first time that use ingredients listed in the Catalog of Health Food Ingredients Subject to Filing and meet the filing requirements, the registration review and approval procedures may be appropriately simplified, except for those intended to supplement nutrients such as vitamins and minerals.

CIRS Interpretation: Under current regulations, for health foods using ingredients such as coenzyme Q10 that are listed in the catalog, domestically produced products must undergo filing, while products imported for the first time must undergo registration. According to the draft for public comment, although the aforementioned health foods imported for the first time are still required to undergo the registration process, the review and approval procedures are expected to be streamlined. This is undoubtedly a major benefit for imported health foods.

3. Article 85 of the draft stipulates: The labels and instructions for health foods must state, “Health foods are not drugs and cannot replace drugs in treating diseases.”

CIRS Interpretation: According to the current Food Safety Law and the “Measures for the Administration of Filing and Registration of Health Foods”, the labels and instructions for health foods must state, “This product cannot replace drugs.” Once the above provision is officially promulgated and implemented, the content under the [Precautions] section of the label and instruction drafts may need to be adjusted accordingly when submitting health food applications.

What Can CIRS Do for You

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services, from regulatory compliance, laboratory testing, and R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

The vast majority of members in CIRS Food Business Division have over 10 years of professional experience in food compliance, with more than 80% holding Master’s or Doctoral degrees in food-related disciplines. The CIRS toxicology expert team consists of 24 Chinese Certified Toxicologists (DCST), 2 American Board Certified Toxicologists (DABT), and 1 European Registered Toxicologist (ERT). CIRS has provided one-stop food compliance services to over 1,000 domestic and international food and related enterprises. Leveraging its technical expertise, diverse resources, and global network, the CIRS Food Business Division offers global food compliance services, including but not limited to:

• Health food registration and filing in China;
• Application for “Three New Foods (new food additives, new food raw materials and new food-related products” in China;
• U.S. GRAS, NDI, and CAP notifications;
• EU Novel Food, food additives, and food enzymes applications; and
• Application for new feed ingredients and feed additives in China, the U.S., and the EU.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.