GACC Decree No. 280 Takes Effect: Imported Dietary Supplements Containing 20 Key Ingredients, Including NMN and Coenzyme Q10, Face Stricter Regulatory Oversight

GACC Decree No. 280 was promulgated on October 14, 2025, and officially entered into force on June 1, 2026.

I. What Has Changed Under GACC Decree No. 280?

The announcement clarifies that imported foods entering the Chinese market for human consumption or for use as food processing materials must declare the China registration number of the overseas manufacturing establishment at the time of import declaration. Products without a valid registration number are not permitted to be imported.

The newly published Catalogue of Imported Foods Subject to Official Recommendation Registration covers 17 categories. Compared with the repealed GACC Decree No. 248, several categories of primary edible agricultural products have been removed from the scope, including oilseeds, fresh vegetables, dried beans, unroasted coffee beans, and cocoa beans.

It should also be noted that, for foods included in the catalogue requiring official recommendation registration, overseas manufacturers may submit their registration applications directly to the Chinese authorities after obtaining an inspection report and recommendation letter issued by the competent authority. Unlike the previous procedure, the competent authority is no longer required to submit the application on the manufacturer’s behalf.

The announcement further specifies that cross-border e-commerce retail imported foods shall continue to be regulated in accordance with the Announcement on the Supervision of Cross-border E-commerce Retail Import and Export Commodities. At present, cross-border e-commerce retail foods are regulated as personal-use imported articles rather than general imported goods.

However, this does not mean that cross-border imported dietary supplements are exempt from stricter oversight. On the contrary, China Customs has simultaneously established and strengthened a List of Key Regulated Ingredients, signaling increasingly stringent supporting regulatory measures.

2. The “Hidden Threshold” for Cross-border Imports: List of 20 Key Regulated Ingredients

Customs has established a list of key regulated ingredients. Products containing ingredients on this list—whether imported via general trade or cross-border channels—are required to provide a certificate of origin and technical documentation.

As of now, the following 20 ingredients are included on the list:

• NMN
• Melatonin
• Coenzyme Q10
• Glutathione
• Quercetin
• PQQ
• Ashwagandha
• Resveratrol
• Ergothioneine
• α-lipoic Acid
• 5-HTP
• DHEA
• Melatonin Derivatives
• Astaxanthin
• Curcumin
• Magnesium Glycinate
• Phenylalanine
• Tryptophan
• Inositol
• L-Carnitine

The new requirements impose a mandatory “three-certification” requirement for products containing any of these key regulated ingredients. All of the following documents must be provided:

• Certificate of Origin;
• Certificate of Free Sale; and
• Official evidence from the country of origin demonstrating the ingredient’s approved food use.

CIRS recommends that companies carefully review the List of Key Regulated Ingredients before introducing new products into the Chinese market. If a product contains any listed ingredient, companies should assess in advance whether the required compliance documentation from the country of origin can be obtained, and ensure that all test reports and certificates of origin are authentic and valid. In addition, companies should avoid inaccurate ingredient declarations or exaggerated product claims to minimize regulatory risks.

Free Webinar

To help companies respond to these policy changes, CIRS Group, together with HPA-Global, is to host a free webinar on the Policy Trends in Cross-Border E-Commerce for Imported Health Foods & Blue Hat Registration and Filing on Wednesday, August 12, 2026, at 12:00-13:00 EST. Please click here for more details.

❤ As a special bonus, all attendees will receive comprehensive guidance on health food registration and filing in China free of charge after the webinar.

About CIRS 

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, 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 24 Chinese Certified Toxicologists (DCST), 2 American Board Certified Toxicologists (DABT), and 2 European Registered Toxicologists (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.