Dual-Use Substances

In Chinese food and drug regulation, “Dual-Use Substances” refer to botanicals and ingredients that are legally classified as both conventional food and Traditional Chinese Medicine (TCM).

Resolving the Food and Medicine Continuum

Managed by the national-health-commission-nhc (NHC), the dual-use positive list provides a critical legal pathway for specific adaptogens to be used in commercial health foods, helping to resolve beverage-vs-supplement-ambiguity in the Asian market.

Because China operates a strict positive-list-system, adaptogens must appear on this list (or the three-new-foods-system list) to be legally utilized. Recently authorized dual-use botanicals include:

• Ganoderma lucidum (Reishi mushroom)
• American Ginseng
• Astragalus
• Codonopsis pilosula

Usage Restrictions

Even when authorized as dual-use, the NHC mandates strict consumption guidelines. These adaptogens are recommended for moderate consumption following traditional methods and are explicitly restricted from use by vulnerable populations, including pregnant women, lactating women, infants, and young children. Furthermore, certain botanical extracts on this list are explicitly allowed in specialized health foods but remain banned from general conventional food categories.