Can I use health claims on food products in China?

Short answer: No — you cannot use health claims on ordinary food products in China unless the product is registered as a Health Food (保健食品, bǎojiàn shípǐn) under a dedicated approval system, and even then, only 27 narrowly defined nutrient function claims are permitted under GB 28050. Over 95% of the health-related claims commonly used on Western food labels — such as “boosts immunity,” “supports heart health,” or “prevents osteoporosis” — are categorically illegal on ordinary prepackaged foods in China and can result in fines of up to three times the product value, product seizure, and criminal liability under the PRC Food Safety Law (食品安全法, shípǐn ānquán fǎ).

This article gives foreign food exporters, brand owners, and compliance officers a clear, legally grounded answer to one of the most frequently misunderstood regulatory questions in the China market. We explain which claims are permitted, which are strictly forbidden, the three laws that govern the space, and the practical steps you must take before putting any health-related language on a label destined for China.

Direct Answer: Only Under Strict Conditions — Most Claims Are Prohibited

If your product is an ordinary prepackaged food (普通预包装食品, pǔtōng yùbāozhuāng shípǐn) — meaning it has not undergone the Health Food registration or filing process — you may not make any statement that directly or indirectly suggests the product has a health benefit, disease-prevention effect, or therapeutic function. This prohibition covers everything from explicit “lowers cholesterol” claims to vague “strengthens your body’s natural defences” taglines.

The only exception for ordinary foods is the narrow category of nutrient function claims (营养成分功能声称, yíngyǎng chéngfèn gōngnéng shēngchēng) explicitly listed in the national standard GB 28050-2011 — the General Rules for Nutrition Labelling of Prepackaged Foods. There are exactly 27 approved nutrient function claims, and they follow rigid, pre-authorised wording. For example, “Calcium is necessary for normal bone structure and function” is permitted, but “Calcium prevents osteoporosis” is not.

For products registered as Health Foods (保健食品, bǎojiàn shípǐn) under the separate registration or filing track, a broader (but still strictly controlled) set of 27 health function claims (保健功能声称, bǎojiàn gōngnéng shēngchēng) is available. Each claim must map to one of the pre-approved categories published by the State Administration for Market Regulation (SAMR, 国家市场监督管理总局, Guójiā Shìchǎng Jiāndū Guǎnlǐ Zǒngjú).

Regulatory Basis: The Trio of Laws Governing Health Claims

Three interlocking pieces of legislation form the legal foundation for health claims on food products in China. Foreign companies must understand all three because a violation of any one is sufficient grounds for enforcement action.

1. PRC Food Safety Law (食品安全法)

Article 73 of the PRC Food Safety Law (promulgated 2009, revised 2015 and 2021) prohibits any false or misleading content in food labels and advertisements. Article 78 specifically requires that Health Food labels and instructions must state the appropriate人群 (target population, shìyí rénqún) and the 不适宜人群 (unsuitable population, bù shìyí rénqún), and must carry the mandatory warning: “本品不能代替药物” (This product cannot replace medicine, Běn pǐn bùnéng dàitì yàowù). Any ordinary food that implies a therapeutic or health effect violates Articles 71 and 73 directly.

2. GB 28050-2011 — General Rules for Nutrition Labelling of Prepackaged Foods

This is the most operationally important standard for foreign food companies. GB 28050 governs the use of nutrition claims (营养声称, yíngyǎng shēngchēng) and nutrient function claims (营养成分功能声称, yíngyǎng chéngfèn gōngnéng shēngchēng). It specifies which claims are allowed, the exact wording that must be used, and the minimum content thresholds that must be met before a claim can appear. Any nutrient function claim that deviates from the standard wording — even by a single character — is technically non-compliant.

3. Advertising Law (广告法, Guǎnggào Fǎ)

Article 17 of the PRC Advertising Law (revised 2018, effective 2021) explicitly prohibits the use of medical terminology or therapeutic language in the advertisement of ordinary foods. Article 18 imposes additional restrictions on Health Food advertising, including the requirement that all such advertisements must carry the warning “保健食品不是药物，不能代替药物治疗疾病” (Health Foods are not medicine and cannot replace medicine in the treatment of disease, Bǎojiàn shípǐn bùshì yàowù, bùnéng dàitì yàowù zhìliáo jíbìng).

Permitted Claims: Nutrient Function Claims

For ordinary prepackaged foods, the only health-related claims that are legally permissible are the nutrient function claims listed in GB 28050, Appendix C. These claims follow a strict format: they link a nutrient to a physiological role without implying disease prevention or treatment. Below are representative examples from the 27 approved claims.

To use any of these claims, the product must meet the minimum content requirement for that nutrient as specified in GB 28050. For example, to make a calcium function claim, the product must contain at least 15% of the Nutrient Reference Value (NRV) for calcium per 100 g (or 100 mL, or per serving if the package contains a single serving).

Prohibited Claims: Disease Prevention and Treatment

The prohibition on disease-related claims is absolute and covers both ordinary foods and Health Foods — though the scope and penalties differ. The following table summarises the key categories of prohibited claims.

The GB 28050 Nutrition Labelling Standard

GB 28050-2011 is the single most important document for any foreign food company placing products on the Chinese market. It is a mandatory national standard (强制性国家标准, qiángzhìxìng guójiā biāozhǔn) that applies to all prepackaged foods sold in China. Understanding its three-tier classification of claims is essential.

1. Nutrition Claims (营养声称, yíngyǎng shēngchēng): Statements about the level of a nutrient in a product, such as “High in Calcium,” “Low Fat,” “Sugar-Free,” or “Source of Dietary Fiber.” These are permitted only if the nutrient content meets specific threshold values set out in GB 28050, Appendix A. A “Low Fat” claim, for example, requires ≤ 3 g fat per 100 g (solids) or ≤ 1.5 g fat per 100 mL (liquids).
2. Nutrient Function Claims (营养成分功能声称, yíngyǎng chéngfèn gōngnéng shēngchēng): The 27 pre-approved statements described earlier. These may only be used when the corresponding nutrition claim is also present. For example, if you use the calcium function claim, you must also display a nutrition claim such as “High in Calcium” or “Contains Calcium” and meet the relevant content threshold.
3. Comparative Claims (比较声称, bǐjiào shēngchēng): Statements comparing the nutrient level of a product to a reference, such as “Reduced Sodium” or “Increased Fiber.” These are permitted but must strictly follow the formulae in GB 28050, and the difference must exceed 25% relative to the reference product.

It is important to note that non-compliant nutrition labels are one of the most common reasons for customs rejection at China’s ports. According to the China Entry-Exit Inspection and Quarantine Bureau (CIQ, 出入境检验检疫局, Chūrùjìng Jiǎnyàn Jiǎnyì Jú), approximately 15–20% of imported food shipments are held or rejected annually due to labelling violations, with health-claim irregularities being the leading cause.

Health Foods vs Ordinary Foods

A common source of confusion among foreign companies is the distinction between ordinary foods (普通食品, pǔtōng shípǐn) and Health Foods (保健食品, bǎojiàn shípǐn). The table below clarifies the key differences as they relate to health claims.

If your product naturally contains a nutrient with a recognised health benefit — for example, a probiotic yoghurt drink — you still cannot make health claims for it unless it is registered as a Health Food. The mere presence of a beneficial ingredient does not confer the right to make health claims on an ordinary food label.

Enforcement and Penalties for False Claims

China has significantly strengthened enforcement against illegal health claims in recent years. The regulatory environment under the 2019 revision of the PRC Food Safety Law Implementation Regulations (食品安全法实施条例, shípǐn ānquán fǎ shíshī tiáolì) introduced substantially higher penalties and personal liability for company executives. Foreign companies should be aware of the following enforcement mechanisms:

• Administrative fines: Violations of Article 73 of the Food Safety Law (false or misleading health claims) can result in fines of up to three times the value of the non-compliant products. For repeat offences, the business license may be revoked.
• Product seizure and recall: SAMR has the authority to order immediate recall of non-compliant products at the company’s expense, including destruction costs. Brands found with illegal health claims may also be placed on a public blacklist (黑名单, hēimíngdān).
• Criminal liability: If an illegal health claim is determined to have led to consumer harm or to constitute fraud, company directors and responsible officers may face criminal prosecution under the PRC Criminal Law (Article 144 — producing or selling counterfeit or substandard food, carrying penalties of up to life imprisonment).
• Advertising penalties: Under the Advertising Law, false or misleading health advertisements carry fines of three to five times the advertising expenditure, and in serious cases, the advertisement must be withdrawn from all media channels within 24 hours.
• Cross-border e-commerce liability: Overseas sellers selling through cross-border e-commerce platforms (跨境电子商务, kuàjìng diànzǐ shāngwù) are also subject to Chinese food labelling law. In 2024, SAMR and the General Administration of Customs began jointly enforcing labelling compliance for cross-border food products, with nearly 400 SKUs delisted for health-claim violations in the first quarter alone.

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