Major Upgrade to the China's Regulation of Complementary Foods for Infant and Young Children: Classified as Special Foods and Subject to Strict Filing Requirements

On October 10, 2026, the State Administration for Market Regulation publicly solicited comments on the “Draft Amendment to the Food Safety Law of the People’s Republic of China (Draft for Public Comment),” explicitly proposing to formally classify infant and young children complementary foods as special foods under regulatory oversight and implement strict filing requirements. This amendment addresses regulatory gaps in the oversight of infant and young children complementary foods, establishing a comprehensive safety management system covering all categories of  infant and young children foods.

What are the specific provisions in the draft Food Safety Law?

Article 81 incorporates infant and young children complementary foods into the strict regulatory framework for special foods.

Article 89 stipulates that manufacturers of infant and young children complementary foods must file the following information to the market supervision and administration departments of the people's governments of provinces, autonomous regions, and municipalities directly under the Central Government: food ingredients, food additives, product formulas, production processes, labels, and packaging materials that come into direct contact with food.

What are the considerations behind classifying infant and young children complementary foods as special foods and implementing a filing system?

An official from the Food Coordination Department of the State Administration for Market Regulation provided a detailed explanation:

Infant and young children complementary foods refer to infant cereal-based, canned, and nutritional supplements for complementary feeding intended for infants aged 6 to 36 months. The Food Safety Law, revised in 2015, clearly stipulates that infant formula is subject to strict supervision and management as a special food. Since infant complementary foods share the same target population as infant formula and serve as an important source of nutrition for infants and young children, they should be subject to the same strict supervision and management model to strengthen oversight. Therefore, it is necessary to explicitly include them within the scope of special foods.

Given that infant and young children complementary foods (such as rice cereal, fruit purees, and nutritional supplements) are designed to supplement breast milk or infant formula—typically using grains, legumes, fruits, and vegetables as base ingredients, with targeted additions of key nutrients such as iron, zinc, calcium, or vitamins—and have relatively simple formulations, implementing a filing system can effectively ensure the quality and safety of these products.

Upgraded Regulation of Infant and Young Children Complementary Foods: Why a Filing System Rather Than a Registration System?

Following the inclusion of infant and young children complementary foods under the special food regulatory framework, many have asked: Why not implement a registration system, as is done for infant formula? The official explanation is clear—to balance safety standards with the practical realities of industry development.

The formulation systems for infant formula are generally complex, with nutrient ratios requiring precise design; therefore, registration and review are mandatory. In contrast, infant and young children complementary foods are based on natural ingredients such as grains, legumes, fruits, and vegetables, with only targeted additions of key nutrients like iron, zinc, calcium, and vitamins. Their formulation structures are relatively simple, and their production processes are well-established and clear, making the filing system a more suitable approach.

Some worry that the filing system might lead to laxer regulation, but in fact, through source registration, traceability, and end-to-end oversight, non-compliant products, those without proper labeling, and those with falsely labeled nutritional information will be effectively intercepted, ensuring that the baseline for food safety is firmly maintained. At the same time, the filing system also helps avoid the excessive regulation that would result from simply adopting the registration system, preventing companies from shouldering an overly heavy compliance burden.

Ultimately, we must be strict where necessary and flexible where appropriate. The filing system can help the infant and young children food industry move beyond unregulated growth and toward standardization and normalization.

Summary

There are no minor issues when it comes to infant and young children food safety. This amendment to the Food Safety Law has established a comprehensive, all-encompassing safety net for infant and young children foods. With the official implementation of the new regulations, China's infant and young children complementary food industry will enter a new stage of standardized, higher-quality development, safeguarding the safety of babies’ meals with rigorous standards.

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