Can I Advertise Food Products with Health Claims in China?

In China, you cannot advertise health claims for Regular Food (普通食品, pǔtōng shípǐn). To legally make a health claim, your product must be officially registered as a Health Food (保健食品, bǎojiàn shípǐn) with the State Administration for Market Regulation (SAMR). There are currently only 24 officially approved health function claims (保健功能, bǎojiàn gōngnéng) that can be used in advertising, and these are strictly tied to products holding a “Blue Hat” (蓝帽子, lán màozi) registration. Violating these rules can result in fines exceeding RMB 1 million and mandatory product recalls.

The allure of the Chinese health food market — valued at over RMB 300 billion in 2023 — makes this a critical question for foreign food executives. Over 70% of Chinese consumers trust the Blue Hat logo, creating a powerful incentive to pursue registration. However, the binary distinction between “Regular Food” and “Health Food” means that any health-oriented marketing on a standard imported snack or beverage is illegal. Below, we break down exactly what you can say, what you cannot say, and how to navigate China’s rigid advertising framework.

Health Food (保健食品) vs. Regular Food (普通食品) — The Strict Binary

China operates on a zero-tolerance binary system. If your product is classified as a Regular Food (普通食品, pǔtōng shípǐn), you cannot use any language that suggests a physiological benefit, disease prevention, or treatment effect. This includes indirect implications in your brand name, slogan, packaging design, and social media content.

Regular foods are limited strictly to Nutrient Function Claims (营养成分功能声称, yíngyǎng chéngfèn gōngnéng shēngchēng) as defined by the national standard GB 28050-2011. For example, you may state: “Calcium contributes to normal bone function,” but you CANNOT say: “Prevents osteoporosis” or “Improves bone health.” The latter requires a Blue Hat registration. Similarly, “Contains dietary fiber” is an ingredient statement allowed on regular food, but “Relieves constipation” is a health function claim reserved exclusively for registered Health Foods.

This distinction creates a significant trap for foreign brands used to Western markets, where structure-function claims are often permitted without pre-approval. In China, regulators monitor e-commerce platforms (Tmall, JD.com) and social media (WeChat, Douyin) for unsubstantiated health claims. A single violation can lead to your store being shut down temporarily.

The 24 Officially Approved Health Function Claims

If your product is successfully registered as a Health Food with the Blue Hat logo, you may only advertise using claims from the official “Health Function Claim List” (保健功能目录, bǎojiàn gōngnéng mùlù). This list is periodically updated by SAMR. The claims are grouped into categories such as Immune System, Bone Health, and Blood Lipid Management.

Each approved claim has a specific, legally required wording that you must use verbatim. You cannot paraphrase. For example, the claim “Assists in Blood Lipid Reduction” (辅助降血脂, fǔzhù jiàng xuèzhī) must be stated exactly as such in your advertising copy, including Chinese nutrition information labels and promotional materials.

As of 2023, SAMR proposed a reform to the health function claim list, introducing a “Recommended” list and a “Supplement” list. This reform is still in draft stage but signals a potential future expansion beyond the 24 static claims. However, for now, foreign brands must map their product’s scientific evidence to one of these 24 claims during the registration process, which typically takes 18 to 36 months and costs between RMB 500,000 and RMB 2,000,000.

Penalties for Illegal Health Claims in Advertising

The Advertising Law of the People’s Republic of China (中华人民共和国广告法, zhōnghuá rénmín gònghéguó guǎnggào fǎ) imposes some of the strictest penalties globally for false or illegal health advertising. Article 17 prohibits any connection between regular food and disease prevention or treatment. Article 18 specifically governs health food advertising, banning the use of language implying “cure,” “treatment,” or “therapeutic effect.”

Enforcement is swift and public. In 2021, a well-known yogurt brand was fined RMB 10 million for claiming its product could prevent COVID-19. Smaller brands frequently face fines of RMB 50,000 to RMB 200,000 for minor infractions like using the word “health” in a regular food brand name. Your advertising materials — including your Tmall product page, WeChat articles, and even employee training scripts — are subject to spot checks by local SAMR bureaus.

The “Blue Hat” Logo (蓝帽子, Lán Màozi) — Your Only Gateway

The Blue Hat logo is a mandatory icon that must appear on the packaging of all registered health foods. It is followed by the approval number (e.g., 国食健字G2024XXXX or 国食健注J2024XXXX for imported products). Without this logo, no health claim is legally permissible, regardless of the scientific evidence or international certifications you possess.

Chinese consumers are highly educated about this logo. Surveys indicate that over 70% of shoppers actively look for the Blue Hat before purchasing a health product. This means that investing in the Blue Hat registration not only grants you legal access to health claims but also serves as a powerful trust signal that can significantly boost conversion rates on platforms like Tmall Global and JD Worldwide.

The registration process for imported health foods requires submitting safety and efficacy evidence from clinical trials, stability tests, and a full product formula review. The product must be manufactured in a facility that meets China’s GMP (Good Manufacturing Practice) standards. For foreign companies, this often requires appointing a China-based legal agent to handle the application.

What About “Functional Foods” or “Nutraceuticals”?

Foreign executives often ask about marketing their product as a “Functional Food” (功能性食品, gōngnéng xìng shípǐn) or “Nutraceutical.” Legally, these categories do not exist in China’s Food Safety Law. You are either a Regular Food (普通食品) or a Health Food (保健食品).

In recent years, a gray market has emerged where brands market regular foods with “implied” health benefits through lifestyle advertising (e.g., “Boost your morning energy”). While these campaigns may avoid explicit claims, they are increasingly targeted by SAMR’s digital enforcement teams, who use AI to scan e-commerce listings for prohibited language. The safest strategy is to clearly define your regulatory path from the start: either fully comply as a Regular Food (no health claims) or invest in the Blue Hat registration process.

NEXT STEPS

1. Evaluate Your Product for Health Food Registration. Determine if your product formula, manufacturing process, and clinical evidence meet the requirements for a Blue Hat application. Read our detailed guide: How to Register a Health Food (Blue Hat) in China.
2. Conduct a Full Advertising Audit. Review all existing Chinese labels, e-commerce listings, and marketing collateral for any implied or explicit health claims that violate the Advertising Law. Download our checklist: China Food Labeling Compliance Checklist for Imported Products.
3. Engage a Regulatory Specialist. Navigating the SAMR approval process and interpreting the 24 approved health claims requires specialized legal support. Schedule a consultation with our China market entry team: Book a Market Entry Strategy Session.

— China Gateway 360 —
Remote China market entry support, built around execution.