导航菜单
Cross-border e-commerce (CBEC) has made it easier for overseas dietary supplement brands to reach Chinese consumers without following the conventional import and market-entry route. However, CBEC does not remove the need to meet applicable Chinese requirements.
For products containing novel, functional, or otherwise sensitive ingredients, compliance considerations may arise across ingredient status, formulation, import documentation, labeling, online claims, and post-import operations.
In other words, a product legally sold as a dietary supplement in another country cannot necessarily be marketed in China through CBEC in the same way.
For dietary supplements, ingredient status is often the first compliance issue to consider. China's 2025 Opinions on Further Strengthening Full-Chain Food Safety Supervision proposed establishing a negative list for food products imported through CBEC retail channels, with dynamic adjustments. However, a national-level negative list specifically identifying "high-risk ingredients" for CBEC dietary supplements has not been publicly issued to date.
Therefore, ingredients that may warrant particular attention should not automatically be interpreted as prohibited from CBEC import. Their regulatory status needs to be assessed based on factors such as source, plant part used, extraction or manufacturing process, purity, specifications, applicable standards, and available safety evidence. This is particularly relevant to botanicals, concentrated extracts, isolated compounds, and functional ingredients that may have a different regulatory status in China.
The examples below are not an official list of prohibited or restricted ingredients. They represent ingredients that may warrant closer regulatory review depending on their specific identity, source, formulation, dosage, and intended use.
Examples include milk thistle, mugwort, saw palmetto, ashwagandha, Berberis aristata root, Epilobium parviflorum, Paullinia cupana, damiana, chamomile, sennosides, and Polypodium leucotomos extract.
For these materials, the botanical name alone is not enough to establish regulatory status. Companies should verify the species, plant part, extraction method and solvents, material specifications, quality standards, and legal basis for food use in the country of origin, as the regulatory status may differ between a whole botanical, an extract, and a highly purified constituent.
Ingredients such as quercetin, berberine, resveratrol, astaxanthin, and 5-hydroxytryptophan (5-HTP) may require a different assessment from the plant materials from which they are derived.
A compound that naturally occurs in a plant does not automatically have the same regulatory status as the plant itself. Once a substance has been isolated, purified, concentrated, or otherwise processed, its regulatory status should be assessed based on the resulting ingredient rather than simply its botanical origin.
Ingredients such as NMN, NAD+, ergothioneine, glutathione, NAC (N-acetylcysteine), and alpha-lipoic acid (ALA) are widely encountered in overseas dietary supplement products.
For these ingredients, companies should establish a clear documentary basis for the product, including, where applicable, evidence of lawful food use in the country of origin, evidence of lawful sale, product specifications, and quality and safety documentation.
Some ingredients already have defined regulatory treatment in China.
For example, folic acid and pantothenic acid are subject to the rules governing nutrient fortification and may only be used in specified categories of food. Melatonin and coenzyme Q10 are included in China's catalogue of raw materials for health food.
Accordingly, the assessment should take into account the finished product category, formulation, dosage, applicable standards, and intended use, rather than relying on the ingredient name alone.
For products containing ingredients that warrant additional regulatory review, documentation should be prepared before the product enters China.
Depending on the product and jurisdiction, useful supporting documents may include:
official evidence that the ingredient is permitted for use in food;
a certificate of free sale;
food hygiene or health certificates;
certificate of origin;
food production licenses;
product standards and specifications;
manufacturing and quality-control documentation; and
relevant safety data.
These documents can help establish the identity, lawful use, quality, and safety basis of the ingredient and finished product in the country of origin.
Companies should cross-check the information provided across the formulation, ingredient specifications, manufacturer details, overseas label, Chinese label, test reports, and import documentation.
Discrepancies between documents can create questions during customs clearance or subsequent regulatory checks, particularly where the differences relate to ingredients, quantities, manufacturers, or product identity.
Compliance does not stop with the product itself.
Product detail pages on e-commerce platforms, advertisements, social media content, and other promotional materials should also be reviewed before launch.
Claims that may be acceptable for a dietary supplement in the country of origin may not be appropriate in China. In particular, companies should avoid presenting food products as capable of preventing or treating diseases where such claims are not permitted.
For CBEC products, the compliance review should therefore cover both the product entering China and how the product is represented after it enters the market.
Ingredient status should not be confused with substances that are expressly prohibited for use in food in China.
For example, on November 4, 2025, the State Administration for Market Regulation of China identified yohimbine and its derivatives, as well as yohimbe bark containing these compounds, as toxic and harmful non-food substances.
For expressly prohibited substances, lawful use overseas does not provide a basis for marketing them in China. A regulatory gap is not the same as a regulatory prohibition.
For overseas dietary supplement companies, CBEC compliance should start with the product and its regulatory status, not simply the import channel.
Key considerations include:
"Ingredient status → formulation → supporting documents → import requirements → labeling → claims → post-import operations."
The presence of an ingredient requiring additional attention does not, by itself, mean that a product cannot enter China through CBEC. The specific ingredient, formulation, product category, documentation, and claims should be assessed against applicable Chinese requirements.
CBEC is an import channel, not a compliance exemption.
