State Administration for Market Regulation (SAMR)
The State Administration for Market Regulation (SAMR) is a comprehensive central regulatory body in the People’s Republic of China, established during a major government restructuring in 2018. It serves as the primary authority for broad domestic market supervision, business registration, drug safety, quality inspections, and the enforcement of food, beverage, health food, and consumer product regulations.
The Tripartite Regulatory System
For global beverage conglomerates and food manufacturers entering the Chinese market, SAMR is one pillar of a tripartite regulatory system:
- SAMR oversees domestic market supervision, quality inspections, and finished product registrations.
- The national-health-commission-nhc (NHC) drafts food safety standards and manages blanket registrations for new and raw ingredients for general food use via the positive-list-system.
- The general-administration-of-customs-of-china-gacc (GACC) handles border enforcement and customs clearance.
Health Food Registration and the “Dual Pathway”
SAMR plays a critical role in how international and domestic beverage brands navigate functional-beverage-regulations and resolve beverage-vs-supplement-ambiguity in China.
While the NHC manages the approval of raw novel food ingredients for general use, SAMR governs the specialized “Health Food” sector. For adaptogens and functional ingredients not approved for general food use, brands must apply through SAMR, which provides an alternative “dual pathway” for ingredient clearance via a two-tiered system:
- Registration Track: A highly stringent process required for novel ingredients or products making specific health claims (e.g., immunity or joint health support). This track requires extensive human or animal clinical trials to prove efficacy. During this process, SAMR reviews the safety and efficacy of the specific ingredients within that exact formulation. If approved, the functional ingredient is deemed acceptable for use exclusively within that specific finished product. This allows beverage manufacturers to bring functional drinks containing novel botanicals to market without waiting for the raw ingredient to receive blanket approval from the NHC.
- Filing Track: A faster, streamlined process restricted to “low risk” ingredients (such as standard vitamins and minerals) that already appear on the pre-approved Health Foods Raw Materials Directory.
Labeling, Enforcement, and Compliance
SAMR works jointly with the NHC to enforce rigorous labeling requirements for prepackaged beverages. For example, the two bodies jointly released the General Principles for the Labeling of Prepackaged Foods (GB 7718-2025), which mandates new digital labels and batch code formats starting in March 2027.
In the domestic market, SAMR actively polices the boundary between permissible structure-function-vs-drug-claims and illegal medical claims in beverage marketing. Brands utilizing novel botanicals or adaptogens must ensure their marketing complies with SAMR’s domestic supervision standards, even if the ingredients themselves were approved via the NHC or SAMR’s finished-product pathway.
SAMR also enforces strict broadcast quotas and sensory regulations to ensure NoLo (no- and low-alcohol) beverages and functional drinks are legitimate products rather than mere marketing vehicles for master alcohol brands.
Additionally, there is noted jurisdictional overlap between SAMR and GACC regarding the enforcement of mislabeled imported prepackaged foods post-entry, requiring brands to maintain strict compliance across both agencies’ purviews.