Positive List System

A Positive List System is a regulatory framework where only explicitly approved substances are legally permitted for use in consumer products. Anything not explicitly listed on the positive list is effectively banned by default.

Impact on Beverage Formulation

This system stands in stark contrast to “negative list” frameworks (where everything is permitted unless explicitly banned) or flexible self-affirmation systems like the US fda’s gras-generally-recognized-as-safe pathway.

In the context of the Asian functional beverage market, particularly under China’s national-health-commission-nhc (NHC), the positive list system fundamentally alters formulation strategy. There is no specific “banned list” of adaptogens; rather, the absence of approval is the ban. If a botanical extract is not explicitly approved via the three-new-foods-system or listed as dual-use-substances, it is illegal to use in commercial food and beverages.

This forces multinational beverage brands to secure mandatory pre-market approval or pivot to the stringent Health Food registration tracks managed by the state-administration-for-market-regulation-samr before launching functional products in these jurisdictions.