What are Foods for Special Dietary Uses in China, and How to Import Them? - Regulatory News - Food & Food Contact Materials

Different with general foods in China, foods for special dietary uses 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 foods for special dietary uses in China from different aspects, to help enterprises understand how to get access to China market successfully.

Definition

Foods for special dietary uses refer to the specially processed or formulated food to meet the special physical or physiological conditions and/or to meet the special dietary needs of diseases, disorders, etc. There are 2 characteristics on these products:

1) Have specific suitable crowds.

2) The nutrient contents are significantly different with the similar general foods.

The Current Categories of Foods for Special Dietary Uses in China

At present, there are 10 kinds of foods for special dietary uses in China as follows.

Category	Details	Need Registration or not?
Infant formula	Infant Formula (GB10765-2010)	Infant formula milk powder registration under SAMR (former CFDA)
	Old Infant and Young Children Formula (GB10767-2010)
Infant complementary foods	Cereal based complementary foods for infants and young children (GB10769-2010)	Registration is not needed
	Canned complementary foods for infants and young children (GB 10770-2010)
Foods for special medical purposes (FSMP)	FSMP for infants under the age of 12 months (GB25596-2010)	Registration under SAMR
	FSMP for patients over the age of 12 months (GB 29922-2013)
Others	Complementary nutritional supplements (GB 22570-2014)	Registration is not needed
	Sports nutrition food (GB 24154-2015)
	Nutritional supplements for pregnant women and nurse (GB31601-2015)
	Foods for the elderly (GB XXXX-XXXX (draft))

PS. SAMR refers to State Administration for Market Regulation

The Products Categories without Registration Requirements

At present, except infant formula milk powder and FSMP, there is no registration requirement for other foods for special dietary uses, which means, the importation of these products will be very similar with general food. If your products can be classified into these categories and meet relevant GB requirements, it will be much easier to import them to China than the foods needing registration.

Infant Complementary Foods

Infant complementary foods are suitable for infants and young children who are over 6 months old. This food category is very familiar to public.

Categories	Details
Cereal based complementary foods for infants and young children	Cereal-based complementary foods (e.g., infant rice flour) High-protein cereal-based complementary foods (e.g., high-protein infant rice flour) Raw cereal-based complementary foods (e.g., infant noodles) Biscuits or other cereal-based complementary foods (e.g., infant biscuits)
Canned complementary foods for infants and young children	Mash (paste) canned foods (e.g., infant fruit and vegetable paste) Granular canned foods (e.g., infant fruit and vegetable granule) Juice canned foods (e.g., infant fruit juice)

Complementary Nutritional Supplements

Definition	Supplement containing a variety of micronutrients (e.g. vitamins and minerals), which contains (or not) base materials and other accessories.
Categories	Complementary food for nutrients supplement Complementary tablet for nutrients supplement Complementary powder/granule for nutrients supplement
Product characteristics	I. Target for infant of 6-36 months and children of 37-60 months. II. A variety of vitamins & minerals, as well as other nutrients such as DHA can be used in this product category.

Sports Nutrition Food

Definition	The specially formulated food for exerciser, to meet their physiological metabolism, exercise capacity and special needs of nutrients. PS. 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.
Categories	For energy supplement, for energy control, for protein supplement, for speed-strength sports, for endurance sports and for post exercise recovery.
Product characteristics	More nutrients are available than similar general food, such as caffeine, creatine, Mn, Mo, Cr, Se, etc. And the nutrient density is higher.

Nutritional Supplements for Pregnant Women and Nurse

I. Definition

The 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.

II. Differences with the formulated milk powder for pregnant women

There is a general food category of formulated milk powder for pregnant women in China as well, which is different with nutritional supplements for pregnant women and nurse, but may be easily confused by public.

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.	The nutrients are all optional to add.

Foods for the Elderly

This is the first time that China government formulates the national standard of foods for the elderly. The draft was issued in September 2018.

Definition	Foods used to aid the elderly in chewing and/or swallowing food, and or satisfy dietary or nutrition needs of malnourished elderly, which are processed by improving the physical properties of food and/or adjusting the types and contents of dietary ingredients.
Categories	I. Easily ingested food	Suitable for elderly people suffering from dysphagia. It can be classified into 6 groups, including 1) soft food, 2) food chopped into small pieces, 3) puree food, 4) food with high degree of viscosity, 5) food with medium degree of viscosity, 6) food with low degree of viscosity.
	II. Elderly nutrition food	Can satisfy the basic nutrition requirements of elderly people, which is suitable for the elderly who cannot eat normally. It can be used as the meal replacement of the elderly.
	III. Elderly nutrition supplement	Supplement nutrients for elderly people with inadequate dietary intake. It is suitable for the elderly who do not have a balanced diet.

How to Import Those Products without Registration Requirements?

Relevant overseas companies are suggested to conduct below regulatory compliance procedures before importing products to China.

S.N.	Items	Detailed requirements
1	Product GB analysis	Evaluate the product category, to find out the suitable GB standard based on the formula, final product form and etc.
2	Formula check	I. Analyze if all food raw materials and food additives are allowed to be used in this product. II. Analyze if the dosages of all ingredients are compliant.
3	Nutrition test	Conduct nutrition tests according to the product nutrition information, which includes the energy, protein, fat, carbohydrate, sodium, added nutrients, etc.
4	GB item test	GB item test (such as sensory, physical and chemical indicators, microorganisms) in qualified lab before importing is an effective way to guarantee the product quality and avoid unnecessary rejection.
5	Chinese label preparation	I. Design the Chinese label in accordance with GB 13432-2013 and the corresponding product GB. II. Confirm if there is any forbidden claim or risk claim on the original label.

In summary, these foods for special dietary uses 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. On the other hand, although they are not required to apply for registration, the product quality requirements are significantly higher than general food, it is recommended to conduct pre-review before entering China market.

If you have any questions, please do not hesitate to contact us at service@cirs-group.com

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