Name game: China’s SAMR releases new manual for naming of health foods

The document, written based on the Food Safety Law and Health Foods Registration and Filing regulations, was published earlier this month. 

The new document​ was produced following a one-month public consultation in October last year.

There are four parts to the document, including the different components of the product name, basic principles for naming the products, banned content, and assessment criteria for health foods naming.

A basic principle is that each product should have a unique name.

The manual also listed out the types of expression or wordings that are banned for use.

For instance, names of people and places and pinyin should not be used.

False, exaggerated, extreme expression, local dialect, and reference to human organs and cells are also prohibited.

According to Chinese regulatory consultancy firm CIRS Group, examples of banned expression would include “passed down from the ancestors (祖传)”, “most”, and “number one”.

The names should also refrain from explicit expression or drop hints on the ability of the product to prevent of treat diseases.

Other points​

To avoid confusion, the manual also instructed manufacturers to follow the standardised names of ingredients as approved by the ministry.

This is applicable to firms that wish to state the ingredient used as part of the product name. They are required to use the standardised version of the ingredient name.

For instance, instead of using the name “田七” for panax notoginseng, they should use the standardised version “三七”。

Also, vitamin or mineral-based dietary supplements cannot be named based on only one single vitamin or mineral. They must be named as a multivitamin or multimineral if they contain at least three types of minerals or vitamins. 

If the product contains less than three types of vitamins and/or minerals, the product name should state all the vitamins and/or minerals used. 

Recommendations for manufacturers​

CIRS has advised firms that have not yet receive the registration or filling approval for their products to strictly follow the manual’s instructions.

For firms that have received the registration or filling certificates for their products, but with product names that do not meet the manual’s criteria, they are advised to change the product name.

They are also advised to include the previous name of the product when reintroducing the product with its new name.