Research: Investigate Banned Adaptogens under China’s NHC

Summary

This research investigates the regulatory status of adaptogens and functional botanical ingredients in China, primarily overseen by the national-health-commission-nhc (NHC) and the state-administration-for-market-regulation-samr (SAMR). The core finding is that China operates on a strict positive-list-system, meaning there is no specific “banned list” for adaptogens; rather, any substance not explicitly approved is effectively illegal for commercial food and beverage use.

Key Findings

• Positive List Framework: The NHC governs novel ingredients through the three-new-foods-system. If an adaptogen is not on this list or the list of dual-use-substances (Traditional Chinese Medicine approved for food), it cannot be used in conventional beverages.
• Two-Tiered Health Food System: For ingredients not approved for general food, brands must apply through SAMR via a stringent “Registration” track (requiring clinical trials) or a faster “Filing” track (for pre-approved, low-risk ingredients).
• Global Regulatory Pressures: Popular Western adaptogens like Ashwagandha are facing severe regulatory crackdowns in the EU and UK. This international scrutiny heavily influences Chinese supply chains and NHC approval likelihoods.
• Recent Approvals: The NHC is actively expanding its positive lists, recently approving ingredients like Yerba mate, Sakura polyphenol, and dual-use botanicals like Reishi mushroom and American Ginseng, often referencing fda GRAS or european-food-safety-authority-efsa safety data.
• Cannabis Ambiguity: The source notes Cannabis sativa L. on a historical NHC dual-use list, creating a contradiction with broader Chinese bans on CBD/THC, likely indicating an exception strictly for sterilized hemp seeds.