Sinew Consulting Group

What opportunity you can have in Mainland China as you face the needs

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Mainland China is opening the market. She claims to be one of the biggest importing countries. No matter what results will be for the trade war between the US and China, the growing market is the huge opportunity for other countries all over the world.

Let have some examples gave by Jack Ma (the chairman of Alibaba) as an idea for the huge opportunities. He mentioned people in China will need more than 0.6 billion heads of pig plus 15 billion chickens each year.

It is an opportunity and is a challenge as well. Chinese culture got a long history and is quite different from the rest of the world. The differences include the ones from the culture itself and the ones from the social system (under communism). These all affect the concepts of governmental agencies and regulations related to importing goods into Mainland China.

The popularity of cross-board- e-commerce (CBEC) in Mainland China also facilitates this opportunity for the players around the world. Nearly 30% of the CBEC sales was contributed by food products according to the media.

Challenges include facing cultural differences, consumer new trends, stronger competitions from local competitors, players from other countries, and regulatory compliance with stricter rules.

In terms of functional foods and supplements, the conditions described above will be the same as general foods, even though the regulations for functional foods can be more complicated than general foods.

Our advisory

Our critical advice is on regulatory advice. The products that bear claims which may require additional scientific research as Chinese SAMR/CFDA had published draft on function claims to be revised/rephrased/adjusted recently. A feasibility assessment of SAMR/CFDA health food claim regulation on certain product is recommended by our regulatory expert team. Moreover, the regulator had requested the public to suggest other means of testing the effectiveness and validity of these claims. This means that there might even be changes to the testing methods eventually.

Our additional advice is on understanding that there is no [one product can fit all markets] anymore during the R&D process. A patented process does not mean its compliance with all regulations.

For claims that might be rephrased, the terms “aids in” and “alleviate” would be added in. For instance, the present claim “strengthen immunity” /“improving sleep” will be adjusted to “aids in strengthening immunity”/“aids in improving sleep” . We may say it getting into more conservative to avoid to show that the products provide effective cure to consumers. If this change is implemented, the manufacturers and the certificate holder of health food production can directly adjust the product packaging, labelling, instruction on use, and the description of the claims.

On the other hand, SAMR/CFDA keep drafting more ingredients approved on the list (the current Health Food Raw Materials Directory). Five new ingredients, namely co-enzyme Q10, melatonin, fish oil, ground ganoderma lucidum powder, and spirulina, would be announced. The current Health Food Raw Materials Directory consists of only basic vitamins and minerals, and the process of obtaining approval to produce these types of supplements takes up a shorter time - at about six months - as compared to other types of supplements. A feasibility assessment of NHC novel ingredient application on certain ingredient is also recommended by our regulatory expert team.

Thirdly, in addition to the two feasibility assessments, a try-run to Mainland China/’s market is to lunch the product in Taiwan. Taiwan FDA got similar regulatory systems on functional foods and supplements as SAMR/CFDA while there are differences between the two in categorization and requirements.