Selling Health Products in China Successfully

China’s health product industry is one of the fastest-growing consumer markets in the world. For foreign brands and cross-border sellers, the opportunity is enormous. But the barriers — regulatory, legal, and platform-specific — are equally significant.

This guide breaks down everything you need to know: market size, compliance requirements, platform entry rules, advertising red lines, and the latest enforcement trends in 2026. Whether you are entering the market for the first time or reviewing your existing compliance posture, this article gives you a clear, structured roadmap.

At Yucheng IP Law (YCIP), we help foreign health brands protect their intellectual property and navigate China’s complex regulatory environment. This article reflects our front-line experience advising brands entering this market.

How Big Is China’s Health Products Market in 2026?

A Market Measured in the Hundreds of Billions

China’s health product market has reached a scale that few industries can match. According to iMedia Research, China’s health supplement market size reached RMB 377.5 billion in 2025, representing year-on-year growth of 5.8%, with the figure projected to exceed RMB 400 billion in 2026.^[1]

Looking at the broader nutrition and health food retail segment, data from the China Industry Research Institute shows that retail sales grew from RMB 324.9 billion in 2021 to RMB 447.7 billion in 2025, reflecting a compound annual growth rate (CAGR) of approximately 8.3%, with 2026 projections pointing to RMB 494.7 billion.^[2]

These are not speculative numbers. They are driven by fundamental, structural demand forces — not trends that can be reversed easily.

Two Engines Powering Growth

The market is being driven by two very different consumer groups pulling in the same direction.

The Silver Economy: China’s population of adults aged 65 and older has surpassed 220 million people — one of the largest elderly populations on the planet. This group drives consistent, high-frequency demand for bone and joint health products, cardiovascular supplements, and cognitive support formulas. Spending in this segment is stable, predictable, and growing year after year.

Gen Z and the “Light Wellness” Movement: At the other end of the age spectrum, China’s younger consumers are redefining health purchasing. Products like functional gummies, probiotic drinks, collagen shots, and adaptogens have become mainstream purchases for consumers in their 20s and 30s. In 2025, approximately 47% of young Chinese consumers reported purchasing health products regularly, with an annual per-person spend of between RMB 1,000 and RMB 5,000.^[3]

What This Means for Foreign Brands

For foreign health brands, these figures signal one clear message: the demand is there. The question is not whether the market is worth entering — it is whether your brand is legally and operationally prepared to enter it correctly.

The regulatory complexity of China’s health products sector is significant. Without proper registration, trademark protection, and advertising compliance, a brand can face product seizures, platform delistings, financial penalties, and lasting reputational damage. Getting the foundation right from day one is not optional — it is the price of entry.

Understanding China IP compliance for foreign companies is often the critical first step before any product launch.

Online Sales Dominate — What That Means for Your Strategy

E-Commerce Is Now the Primary Sales Channel

If you are selling health products in China without a strong e-commerce strategy, you are operating in the wrong channel. Online retail has decisively overtaken physical stores as the primary venue for health product purchases.

According to Guotou Securities, the online sales share of China’s total health product sales is projected at 63.3% in 2025 — up significantly from previous years and still growing.^[4] Data from the China Chamber of Commerce for Import and Export of Medicines and Health Products shows that the total e-commerce channel sales value for nutritional health foods reached RMB 153.7 billion in 2025.^[5]

Double 11 as a Market Barometer

China’s annual “Double 11” (11.11) shopping festival is the single most important sales event in Chinese e-commerce. For health products specifically, it is a reliable indicator of market momentum.

During the 2025 Double 11, total nutritional health product sales across Tmall, JD.com, Douyin, and Kuaishou reached RMB 23.8 billion.^[6] On JD Health alone, more than 2,500 nutritional supplement brands doubled their sales year-on-year, and nearly 100 sub-categories saw over 100% growth compared to the prior year’s event.

These figures confirm that health products are among the highest-performing categories in Chinese e-commerce — and that consumer appetite continues to accelerate.

Platform Strategy: Choose Your Channel Carefully

Not all platforms are equal — and not all are equally accessible to foreign brands. The main channels available to health product sellers include:

• Tmall International (天猫国际): The flagship cross-border platform for premium foreign brands. Requires brand authorization, trademark documentation, and country-of-origin certificates.
• JD Worldwide (京东全球购): Strong logistics infrastructure, well-suited for supplement and nutrition brands targeting health-conscious consumers.
• Douyin Global Shopping (抖音全球购): Livestream-commerce dominant; explosive growth but demanding content compliance obligations.
• Xiaohongshu (小红书): A content-discovery and social commerce platform used heavily by younger female consumers. New restrictions in 2026 limit health product promotions significantly.

Each platform has its own entry requirements, product category rules, and advertising restrictions. Foreign brands must understand the compliance obligations of each channel before committing resources — especially given the regulatory tightening occurring across all major platforms in 2026.

Protecting your brand identity across all of these platforms requires proactive trademark registration. China’s first-to-file trademark system means that if you have not filed in China yet, a third party can legally claim your brand name before you do.

The “Blue Hat” — China’s Core Regulatory Gate for Health Products

What Is the Blue Hat?

The “Blue Hat” (蓝帽子) is the common name for China’s mandatory approval mark for health food products. It is a blue shield-shaped logo that must appear on the packaging of any product legally classified and sold as a health food in China.

The Blue Hat is issued by the State Administration for Market Regulation (SAMR) — formerly the China Food and Drug Administration (CFDA). Without this mark, a product cannot legally be marketed, sold, or advertised as a health food in China, whether through domestic retailers or traditional e-commerce channels.

As of March 2025, there are 13,000 valid Blue Hat registration certificates in force across China.^[7] That number reflects the substantial investment of time and resources that compliant brands have made to enter this market properly.

Registration vs. Filing: Two Pathways to the Blue Hat

China’s health food regulatory framework provides two distinct approval pathways, governed by the Measures for the Administration of Health Food Registration and Filing (保健食品注册与备案管理办法).

For most foreign brands seeking to import health products through general trade channels, registration (注册制) is the applicable pathway. This is a more demanding process involving technical review of safety and efficacy data.

Key Legal Requirements Under Chinese Law

The Blue Hat system is grounded in China’s primary food safety legislation. Two provisions are especially important for foreign brands to understand:

Article 77, Food Safety Law of the People’s Republic of China
Health food products subject to registration must submit to SAMR: a research and development report, product formula, production process documentation, safety and health function evaluation materials, sample products, and proposed label and instruction sheet content.

Article 78, Food Safety Law of the People’s Republic of China
Labels and instruction sheets for health food products must not reference disease prevention or treatment functions. All content must be truthful, consistent with the registered or filed content, and must carry the disclaimer: “This product cannot replace medicine” (本品不能代替药物).

These two provisions define the outer boundaries of what you can and cannot claim about your product in China. Violating them — even through labeling that is legal in your home country — can result in administrative penalties, product recalls, and reputational damage.

Approval Number Format

Every legitimately registered health food carries a unique approval number visible on its packaging. The format is:

• Domestic products: 国食健注G + 4-digit year + 4-digit sequence number (e.g., 国食健注G20210001)
• Imported products: 国食健注J + 4-digit year + 4-digit sequence number (e.g., 国食健注J20210001)

Before entering any commercial relationship with a Chinese distributor or retailer, always verify that the product’s Blue Hat number is valid and current in the SAMR public database. Selling products with expired or fraudulent approval numbers carries serious legal consequences — including criminal liability for repeat offenders.

IP Implications of the Blue Hat Process

The Blue Hat registration process has a direct and often overlooked connection to intellectual property. Your product’s registered name, formula description, and label design — all submitted as part of the registration dossier — become part of the legal record. If your brand name or Chinese-language product name is not already protected by a registered trademark in China, you risk a third party claiming it during or after the registration process.

This is why trademark registration in China for foreign companies should always precede — or at minimum run concurrently with — the Blue Hat application. Our team at YCIP’s trademark and copyright practice regularly advises health brands on sequencing their IP filings to protect both the brand identity and the registration investment.

Cross-Border E-Commerce as a Market Entry Route

The Policy Window Created by Document 486

One of the most important regulatory provisions for foreign health brands is Document 486 — formally, the Notice on Improving the Supervision of Cross-Border E-Commerce Retail Import Goods (商财发〔2018〕486号), issued jointly by six government ministries including MOFCOM.

Article 3 of Document 486 provides a critical exemption:

Article 3, Document 486 (商财发〔2018〕486号)
Cross-border e-commerce retail import goods shall be supervised as personal use items for individuals. The first-time import permit, registration, or filing requirements applicable to ordinary commercial imports do not apply.

In plain terms: a foreign dietary supplement that has not obtained a Blue Hat can still be legally sold to Chinese consumers — provided it is sold through a qualifying cross-border e-commerce channel (such as Tmall International or Douyin Global Shopping), on the permitted goods list, and delivered from a bonded warehouse or directly from overseas.

This exemption has been the primary driver of the explosive growth in cross-border health product sales over the past five years. It allows foreign brands to test the Chinese market, generate revenue, and build brand recognition — without the cost and time commitment of a full Blue Hat registration.

The Limits of the Document 486 Exemption

However, Document 486 is not a compliance free pass. Several important obligations still apply:

• The product must appear on the Cross-Border E-Commerce Retail Import Permitted Goods List (跨境电商零售进口商品清单). Not all health product categories are included.
• The overseas manufacturer must complete registration with Chinese customs authorities. Without this registration, the product cannot pass through bonded warehouse facilities.
• All ingredient declarations must be complete and accurate. Since June 2026, this includes both active ingredients and excipients (详见下节 — see next section on Order 280).
• Chinese labeling requirements still apply to products sold through cross-border channels, including the prohibition on disease treatment claims.
• Advertising and marketing content must comply fully with China’s Advertising Law — the cross-border channel exemption does not extend to marketing claims.

Cross-Border E-Commerce ≠ Unregulated Commerce

A common and costly misconception among foreign brands is that selling through cross-border channels means operating in a regulatory gray area. This is no longer accurate — and in 2026, it has become actively dangerous to operate on this assumption.

Chinese customs, market regulators, and platform operators have significantly tightened cross-border compliance over the past 18 months. Brands that have relied on informal arrangements, incomplete ingredient disclosures, or misleading product descriptions are increasingly being identified and penalized.

The IP dimension of cross-border e-commerce is also frequently underestimated. If your product becomes popular in China through a cross-border channel without a registered trademark, you are exposed to trademark squatting — a well-documented risk where third parties register your brand name in China before you do, then demand payment or legal action to recover it.

Our firm has helped numerous foreign health brands address exactly this scenario. The cost of recovering a squatted trademark is almost always higher — in time, money, and operational disruption — than the cost of proactive registration. Learn more about our trademark registration services in China.

References

1. iMedia Research, 2025 China Health Supplement Industry Report. Source Role: Industry Research. Support Status: Supports. Relevance: Provides 2025 market size (RMB 377.5 billion) and 2026 projection exceeding RMB 400 billion.
2. China Industry Research Institute (中商产业研究院), China Nutrition and Health Food Retail Report 2025. Source Role: Industry Research. Support Status: Supports. Relevance: Confirms CAGR of 8.3% (2021–2025) and 2026 projection of RMB 494.7 billion for broader nutrition/health food segment.
3. iMedia Research, 2025 China Young Consumer Health Purchasing Survey. Source Role: Consumer Research. Support Status: Supports. Relevance: 47% of young Chinese consumers purchase health products regularly; annual per-person spend RMB 1,000–5,000.
4. Guotou Securities (国投证券), Health Supplement E-Commerce Channel Research Report, 2025. Source Role: Securities Research. Support Status: Supports. Relevance: Online sales projected at 63.3% of total health product sales in 2025.
5. China Chamber of Commerce for Import and Export of Medicines and Health Products (中国医药保健品进出口商会), 2025 Annual E-Commerce Data Report. Source Role: Industry Association. Support Status: Supports. Relevance: E-commerce channel total sales for nutritional health foods reached RMB 153.7 billion in 2025.
6. 2025 Double 11 National E-Commerce Sales Analysis Report. Source Role: Industry Data. Support Status: Supports. Relevance: Total nutritional health product sales across major platforms during 2025 Double 11 reached RMB 23.8 billion.
7. State Administration for Market Regulation (SAMR / 国家市场监督管理总局), Health Food Registration Certificate Database, March 2025. Source Role: Official Government Data. Support Status: Supports. Relevance: 13,000 valid Blue Hat registration certificates as of March 2025.

Selling Health Products in China Successfully

China’s health product industry is one of the fastest-growing consumer markets in the world. For foreign brands and cross-border sellers, the opportunity is enormous. But the barriers — regulatory, legal, and platform-specific — are equally significant.

This guide breaks down everything you need to know: market size, compliance requirements, platform entry rules, advertising red lines, and the latest enforcement trends in 2026. Whether you are entering the market for the first time or reviewing your existing compliance posture, this article gives you a clear, structured roadmap.

At Yucheng IP Law (YCIP), we help foreign health brands protect their intellectual property and navigate China’s complex regulatory environment. This article reflects our front-line experience advising brands entering this market.

How Big Is China’s Health Products Market in 2026?

A Market Measured in the Hundreds of Billions

China’s health product market has reached a scale that few industries can match. According to iMedia Research, China’s health supplement market size reached RMB 377.5 billion in 2025, representing year-on-year growth of 5.8%, with the figure projected to exceed RMB 400 billion in 2026.^[1]

Looking at the broader nutrition and health food retail segment, data from the China Industry Research Institute shows that retail sales grew from RMB 324.9 billion in 2021 to RMB 447.7 billion in 2025, reflecting a compound annual growth rate (CAGR) of approximately 8.3%, with 2026 projections pointing to RMB 494.7 billion.^[2]

These are not speculative numbers. They are driven by fundamental, structural demand forces — not trends that can be reversed easily.

Two Engines Powering Growth

The market is being driven by two very different consumer groups pulling in the same direction.

The Silver Economy: China’s population of adults aged 65 and older has surpassed 220 million people — one of the largest elderly populations on the planet. This group drives consistent, high-frequency demand for bone and joint health products, cardiovascular supplements, and cognitive support formulas. Spending in this segment is stable, predictable, and growing year after year.

Gen Z and the “Light Wellness” Movement: At the other end of the age spectrum, China’s younger consumers are redefining health purchasing. Products like functional gummies, probiotic drinks, collagen shots, and adaptogens have become mainstream purchases for consumers in their 20s and 30s. In 2025, approximately 47% of young Chinese consumers reported purchasing health products regularly, with an annual per-person spend of between RMB 1,000 and RMB 5,000.^[3]

What This Means for Foreign Brands

For foreign health brands, these figures signal one clear message: the demand is there. The question is not whether the market is worth entering — it is whether your brand is legally and operationally prepared to enter it correctly.

The regulatory complexity of China’s health products sector is significant. Without proper registration, trademark protection, and advertising compliance, a brand can face product seizures, platform delistings, financial penalties, and lasting reputational damage. Getting the foundation right from day one is not optional — it is the price of entry.

Understanding China IP compliance for foreign companies is often the critical first step before any product launch.

Online Sales Dominate — What That Means for Your Strategy

E-Commerce Is Now the Primary Sales Channel

If you are selling health products in China without a strong e-commerce strategy, you are operating in the wrong channel. Online retail has decisively overtaken physical stores as the primary venue for health product purchases.

According to Guotou Securities, the online sales share of China’s total health product sales is projected at 63.3% in 2025 — up significantly from previous years and still growing.^[4] Data from the China Chamber of Commerce for Import and Export of Medicines and Health Products shows that the total e-commerce channel sales value for nutritional health foods reached RMB 153.7 billion in 2025.^[5]

Double 11 as a Market Barometer

China’s annual “Double 11” (11.11) shopping festival is the single most important sales event in Chinese e-commerce. For health products specifically, it is a reliable indicator of market momentum.

During the 2025 Double 11, total nutritional health product sales across Tmall, JD.com, Douyin, and Kuaishou reached RMB 23.8 billion.^[6] On JD Health alone, more than 2,500 nutritional supplement brands doubled their sales year-on-year, and nearly 100 sub-categories saw over 100% growth compared to the prior year’s event.

These figures confirm that health products are among the highest-performing categories in Chinese e-commerce — and that consumer appetite continues to accelerate.

Platform Strategy: Choose Your Channel Carefully

Not all platforms are equal — and not all are equally accessible to foreign brands. The main channels available to health product sellers include:

• Tmall International (天猫国际): The flagship cross-border platform for premium foreign brands. Requires brand authorization, trademark documentation, and country-of-origin certificates.
• JD Worldwide (京东全球购): Strong logistics infrastructure, well-suited for supplement and nutrition brands targeting health-conscious consumers.
• Douyin Global Shopping (抖音全球购): Livestream-commerce dominant; explosive growth but demanding content compliance obligations.
• Xiaohongshu (小红书): A content-discovery and social commerce platform used heavily by younger female consumers. New restrictions in 2026 limit health product promotions significantly.

Each platform has its own entry requirements, product category rules, and advertising restrictions. Foreign brands must understand the compliance obligations of each channel before committing resources — especially given the regulatory tightening occurring across all major platforms in 2026.

Protecting your brand identity across all of these platforms requires proactive trademark registration. China’s first-to-file trademark system means that if you have not filed in China yet, a third party can legally claim your brand name before you do.

The “Blue Hat” — China’s Core Regulatory Gate for Health Products

What Is the Blue Hat?

The “Blue Hat” (蓝帽子) is the common name for China’s mandatory approval mark for health food products. It is a blue shield-shaped logo that must appear on the packaging of any product legally classified and sold as a health food in China.

The Blue Hat is issued by the State Administration for Market Regulation (SAMR) — formerly the China Food and Drug Administration (CFDA). Without this mark, a product cannot legally be marketed, sold, or advertised as a health food in China, whether through domestic retailers or traditional e-commerce channels.

As of March 2025, there are 13,000 valid Blue Hat registration certificates in force across China.^[7] That number reflects the substantial investment of time and resources that compliant brands have made to enter this market properly.

Registration vs. Filing: Two Pathways to the Blue Hat

China’s health food regulatory framework provides two distinct approval pathways, governed by the Measures for the Administration of Health Food Registration and Filing (保健食品注册与备案管理办法).

For most foreign brands seeking to import health products through general trade channels, registration (注册制) is the applicable pathway. This is a more demanding process involving technical review of safety and efficacy data.

Key Legal Requirements Under Chinese Law

The Blue Hat system is grounded in China’s primary food safety legislation. Two provisions are especially important for foreign brands to understand:

Article 77, Food Safety Law of the People’s Republic of China
Health food products subject to registration must submit to SAMR: a research and development report, product formula, production process documentation, safety and health function evaluation materials, sample products, and proposed label and instruction sheet content.

Article 78, Food Safety Law of the People’s Republic of China
Labels and instruction sheets for health food products must not reference disease prevention or treatment functions. All content must be truthful, consistent with the registered or filed content, and must carry the disclaimer: “This product cannot replace medicine” (本品不能代替药物).

These two provisions define the outer boundaries of what you can and cannot claim about your product in China. Violating them — even through labeling that is legal in your home country — can result in administrative penalties, product recalls, and reputational damage.

Approval Number Format

Every legitimately registered health food carries a unique approval number visible on its packaging. The format is:

• Domestic products: 国食健注G + 4-digit year + 4-digit sequence number (e.g., 国食健注G20210001)
• Imported products: 国食健注J + 4-digit year + 4-digit sequence number (e.g., 国食健注J20210001)

Before entering any commercial relationship with a Chinese distributor or retailer, always verify that the product’s Blue Hat number is valid and current in the SAMR public database. Selling products with expired or fraudulent approval numbers carries serious legal consequences — including criminal liability for repeat offenders.

IP Implications of the Blue Hat Process

The Blue Hat registration process has a direct and often overlooked connection to intellectual property. Your product’s registered name, formula description, and label design — all submitted as part of the registration dossier — become part of the legal record. If your brand name or Chinese-language product name is not already protected by a registered trademark in China, you risk a third party claiming it during or after the registration process.

This is why trademark registration in China for foreign companies should always precede — or at minimum run concurrently with — the Blue Hat application. Our team at YCIP’s trademark and copyright practice regularly advises health brands on sequencing their IP filings to protect both the brand identity and the registration investment.

Cross-Border E-Commerce as a Market Entry Route

The Policy Window Created by Document 486

One of the most important regulatory provisions for foreign health brands is Document 486 — formally, the Notice on Improving the Supervision of Cross-Border E-Commerce Retail Import Goods (商财发〔2018〕486号), issued jointly by six government ministries including MOFCOM.

Article 3 of Document 486 provides a critical exemption:

Article 3, Document 486 (商财发〔2018〕486号)
Cross-border e-commerce retail import goods shall be supervised as personal use items for individuals. The first-time import permit, registration, or filing requirements applicable to ordinary commercial imports do not apply.

In plain terms: a foreign dietary supplement that has not obtained a Blue Hat can still be legally sold to Chinese consumers — provided it is sold through a qualifying cross-border e-commerce channel (such as Tmall International or Douyin Global Shopping), on the permitted goods list, and delivered from a bonded warehouse or directly from overseas.

This exemption has been the primary driver of the explosive growth in cross-border health product sales over the past five years. It allows foreign brands to test the Chinese market, generate revenue, and build brand recognition — without the cost and time commitment of a full Blue Hat registration.

The Limits of the Document 486 Exemption

However, Document 486 is not a compliance free pass. Several important obligations still apply:

• The product must appear on the Cross-Border E-Commerce Retail Import Permitted Goods List (跨境电商零售进口商品清单). Not all health product categories are included.
• The overseas manufacturer must complete registration with Chinese customs authorities. Without this registration, the product cannot pass through bonded warehouse facilities.
• All ingredient declarations must be complete and accurate. Since June 2026, this includes both active ingredients and excipients (详见下节 — see next section on Order 280).
• Chinese labeling requirements still apply to products sold through cross-border channels, including the prohibition on disease treatment claims.
• Advertising and marketing content must comply fully with China’s Advertising Law — the cross-border channel exemption does not extend to marketing claims.

Cross-Border E-Commerce ≠ Unregulated Commerce

A common and costly misconception among foreign brands is that selling through cross-border channels means operating in a regulatory gray area. This is no longer accurate — and in 2026, it has become actively dangerous to operate on this assumption.

Chinese customs, market regulators, and platform operators have significantly tightened cross-border compliance over the past 18 months. Brands that have relied on informal arrangements, incomplete ingredient disclosures, or misleading product descriptions are increasingly being identified and penalized.

The IP dimension of cross-border e-commerce is also frequently underestimated. If your product becomes popular in China through a cross-border channel without a registered trademark, you are exposed to trademark squatting — a well-documented risk where third parties register your brand name in China before you do, then demand payment or legal action to recover it.

Our firm has helped numerous foreign health brands address exactly this scenario. The cost of recovering a squatted trademark is almost always higher — in time, money, and operational disruption — than the cost of proactive registration. Learn more about our trademark registration services in China.

References

1. iMedia Research, 2025 China Health Supplement Industry Report. Source Role: Industry Research. Support Status: Supports. Relevance: Provides 2025 market size (RMB 377.5 billion) and 2026 projection exceeding RMB 400 billion.
2. China Industry Research Institute (中商产业研究院), China Nutrition and Health Food Retail Report 2025. Source Role: Industry Research. Support Status: Supports. Relevance: Confirms CAGR of 8.3% (2021–2025) and 2026 projection of RMB 494.7 billion for broader nutrition/health food segment.
3. iMedia Research, 2025 China Young Consumer Health Purchasing Survey. Source Role: Consumer Research. Support Status: Supports. Relevance: 47% of young Chinese consumers purchase health products regularly; annual per-person spend RMB 1,000–5,000.
4. Guotou Securities (国投证券), Health Supplement E-Commerce Channel Research Report, 2025. Source Role: Securities Research. Support Status: Supports. Relevance: Online sales projected at 63.3% of total health product sales in 2025.
5. China Chamber of Commerce for Import and Export of Medicines and Health Products (中国医药保健品进出口商会), 2025 Annual E-Commerce Data Report. Source Role: Industry Association. Support Status: Supports. Relevance: E-commerce channel total sales for nutritional health foods reached RMB 153.7 billion in 2025.
6. 2025 Double 11 National E-Commerce Sales Analysis Report. Source Role: Industry Data. Support Status: Supports. Relevance: Total nutritional health product sales across major platforms during 2025 Double 11 reached RMB 23.8 billion.
7. State Administration for Market Regulation (SAMR / 国家市场监督管理总局), Health Food Registration Certificate Database, March 2025. Source Role: Official Government Data. Support Status: Supports. Relevance: 13,000 valid Blue Hat registration certificates as of March 2025.

New Import Rules Taking Effect June 2026 — What Changed Under Order 280

What Is Order 280?

On June 1, 2026, General Administration of Customs Order No. 280 (海关总署令第280号, “Order 280”) officially came into force. This regulation fundamentally upgrades China’s import food registration management system — and it directly affects every foreign brand selling health products into China through any channel.

Order 280 replaces an older, more static approval framework with a dynamic, risk-tiered system. The core principle is full-chain oversight: from the overseas manufacturer, through customs clearance, to the end consumer. For health product brands, this means the margin for error in documentation, ingredient disclosure, and supply chain management has narrowed considerably.

Three Major Changes Under Order 280

The following table summarizes the most operationally significant changes for health product importers:

The Hong Kong Transit Rule

One frequently overlooked provision in Order 280 concerns products routed through Hong Kong. Under the new rules, health products entering mainland China via Hong Kong are now subject to mandatory inspection — commonly referred to as entering the “compulsory inspection era” for Hong Kong transit goods.

Complete country-of-origin documentation and unbroken logistics records are now required at every stage. This provision specifically targets “origin washing” — a practice where products manufactured in one country are re-labeled or re-routed through Hong Kong to misrepresent their origin. Customs and platform operators have established a joint screening mechanism to identify these arrangements.

What Brands Must Do Before Shipment

To remain compliant under Order 280, foreign health product brands should take the following steps before any shipment arrives at a Chinese port:

• Complete overseas manufacturer registration with Chinese customs. Without this, your products cannot be cleared through bonded warehouses.
• Prepare a full ingredient dossier — including active ingredients and all excipients — and verify it matches your registered formula, Chinese label, and third-party test reports exactly.
• If your product contains any ingredient on the monitored watchlist (NMN, Q10, melatonin, etc.), obtain and retain a formal compliance certificate from your home country’s regulatory authority.
• Review your logistics chain to ensure no gaps in origin documentation, particularly for products transiting through Hong Kong.

Order 280 compliance intersects directly with broader IP compliance obligations for foreign companies in China. If your product formula, brand name, or packaging design is not properly protected before customs registration, the registration process itself can expose your IP to third-party risks.

Marketing Red Lines — What You Cannot Say or Do in China

Why Advertising Compliance Is Your Second Legal Gate

After product registration, advertising compliance is the most consequential legal obligation for health product brands in China. In 2026, market regulators have launched a dedicated national campaign targeting false claims and misleading health product marketing — described internally as the “strictest-ever rectification” of online food advertising.

The consequences of non-compliance are not theoretical. Brands have faced fines, platform delistings, license revocations, and criminal referrals — all arising from advertising content that would have been legal in their home markets but violated Chinese law.

Article 18 of China’s Advertising Law — The Six Absolute Prohibitions

The primary legal framework governing health food advertising is Article 18 of the Advertising Law of the People’s Republic of China (中华人民共和国广告法第18条). This provision contains six categorical prohibitions that apply to all health food advertising in China — including online content, livestreams, short videos, social media posts, and product listing pages.

Article 18, Advertising Law of the People’s Republic of China
Health food advertisements must not contain any of the following:

1. Assertions or guarantees about efficacy or safety;
2. Content involving disease prevention or treatment functions;
3. Claims or implications that the product is necessary to maintain health;
4. Comparisons with drugs or other health food products;
5. Endorsements or testimonials by advertising spokespersons;
6. Any other content prohibited by law or administrative regulation.

Article 8 of the Anti-Unfair Competition Law — False Commercial Promotion

A second important statute applies beyond the Advertising Law. Article 8 of the Anti-Unfair Competition Law of the People’s Republic of China (反不正当竞争法第8条) prohibits any operator from making false or misleading commercial representations about a product’s performance, functions, quality, sales volume, or user evaluations in a way that deceives or misleads consumers.

Article 8, Anti-Unfair Competition Law of the People’s Republic of China
Business operators shall not make false or misleading commercial promotions regarding the performance, functions, quality, sales status, user evaluations, or accolades of their goods or services, thereby deceiving or misleading consumers.

This provision captures a wide range of common marketing tactics — including fabricated user reviews, exaggerated “bestseller” claims, misleading before-and-after comparisons, and implied endorsements from healthcare professionals.

The Three Red Lines in 2026 Enforcement

Livestreaming and Short Video — The New Enforcement Frontier

The Regulations on the Supervision and Administration of Livestream E-Commerce (直播电商监督管理办法), which came into effect in February 2026, officially classified livestream commerce as commercial advertising under Chinese law. This has significant practical implications:

• All six prohibitions of Article 18 of the Advertising Law now apply explicitly to health product promotions conducted via livestream or short video.
• Health food brands may no longer use KOLs, influencers, or any spokesperson to endorse or testify on behalf of health products in a commercial context.
• The disclaimer “This product cannot replace medicine” must be visibly displayed during health food livestreams.

For brands building a social commerce strategy on Douyin or Xiaohongshu, this is a material change. Content that was previously acceptable under influencer marketing norms is now formally categorized as commercial advertising — subject to full regulatory scrutiny.

Platform Entry Requirements in 2026

Regulators Put Platforms on Notice

On April 2, 2026, the State Council Food Safety Office, SAMR, and General Administration of Customs jointly convened meetings with three major platforms — Douyin, Alibaba (Tmall), and Xiaohongshu — issuing formal regulatory notices. The core demand: platforms must shift from formality-based review to substantive, penetrating verification, and from post-event enforcement to front-end prevention.

This regulatory intervention has triggered a wave of updated entry requirements across all major platforms. For foreign health brands seeking to enter or expand in the Chinese market, understanding these requirements is now a prerequisite to any launch planning.

Douyin Global Shopping (抖音全球购)

Douyin has moved to a directed invitation and whitelist system (定向邀约+报白制) for new health product merchants in 2026. Prospective new merchants must:

• Submit a pre-registration form and receive brand eligibility approval before any product listing is permitted;
• Provide a certificate of origin from the manufacturing country;
• Submit proof of overseas sales — accepted formats include screenshots of active online store listings or on-site video footage of physical retail locations (“one continuous shot” format);
• Demonstrate active brand authorization through a formal letter — generic distributor agreements are no longer sufficient.

Tmall International (天猫国际)

Tmall International continues to be the highest-credibility channel for foreign health brands entering China, but its entry standards have become correspondingly more rigorous:

• Brand operators are strongly advised to hold a registered trademark with the ® mark in the country of origin, plus a formal exclusive authorization letter for the Chinese market. This combination significantly improves application approval rates.
• Overseas product photography and retail environment documentation should be prepared in advance to verify authentic market presence.
• For any domestic Chinese entity operating a Tmall flagship store, a Food Business License or registration certificate, trademark registration certificate, and manufacturer production permit are all required at entry.

This is where trademark strategy becomes directly commercial. Brands without a registered ® trademark in their home country — or without a Chinese trademark registration — face significantly longer approval timelines and higher rejection rates. Our trademark services team has helped multiple health brands structure their trademark portfolio specifically to meet Tmall’s entry criteria. You can also get a quote for trademark registration here.

Xiaohongshu (小红书)

Xiaohongshu has implemented the most restrictive health product rules of any major Chinese platform in 2026. Pharmaceuticals, health foods, and medical devices have been added to its prohibited promotion list. Specifically:

• Health food “discovery content” (种草笔记) is now subject to significant restrictions, with many product categories limited or suspended;
• Livestream selling of health products is restricted and requires pre-approval;
• Violations — including content that implies health claims without explicit Blue Hat authorization — result in progressive penalties: reduced content reach (限流), suspension of product functions, and account termination.

For brands that have historically relied on Xiaohongshu’s organic content marketing as a low-cost entry strategy for health products, 2026 represents a significant channel risk requiring immediate strategy review.

2026 Enforcement Trends — Three Violation Types Under Scrutiny

Regulators Have Shifted to Active Enforcement Mode

China’s approach to health product regulation has historically been criticized for inconsistent enforcement. That dynamic has changed materially in 2026. The combination of new legislation, inter-agency coordination, platform accountability requirements, and dedicated national campaigns has created an enforcement environment that foreign brands cannot afford to treat casually.

Three categories of violations are receiving disproportionate regulatory attention this year — and each carries specific, documented risks for foreign operators.

Type 1 — False Claims and Efficacy Exaggeration

This is the highest-volume enforcement category. It encompasses both ordinary food products that make health function claims they are not entitled to make, and registered health foods that cross the line into implying disease treatment or prevention.

The Beijing Municipal Market Regulation Bureau has explicitly identified three prohibited behaviors as its primary enforcement focus for online food platforms: unregistered health claims, disease-related marketing language, and absolute superlative descriptions (e.g., “best,” “most effective,” “clinically proven”). Brands with Chinese-language product listings on any major platform should conduct an immediate content audit against these criteria.

Type 2 — Cross-Border “Grey Market” Operations

The second enforcement priority targets what Chinese regulators describe as “grey market” cross-border arrangements. This includes:

• “Fake foreign brand” (假洋牌) schemes — where products are manufactured domestically but falsely presented as imported;
• Origin falsification — misrepresenting product manufacturing location on customs declarations or product labels;
• Incomplete or misleading customs declarations — particularly in the context of Order 280’s new full-ingredient disclosure requirements.

Customs authorities and platform operators have established a joint screening mechanism to identify these arrangements. The risk to legitimate foreign brands is indirect but real: if your distribution chain includes intermediaries who engage in any of these practices, your brand can be implicated in enforcement actions even if the original manufacturer is fully compliant.

Type 3 — Livestream and Content Commerce Violations

The third enforcement category reflects the regulatory reclassification of livestream commerce as commercial advertising under the February 2026 regulations. Platforms are now required to proactively screen health product content — and failure to do so creates platform-level liability.

The practical result: platforms are applying significantly more stringent pre-publication review to health product livestreams and short video content. Content that passed platform review in 2025 may be flagged or rejected in 2026. Brands should review all live and scheduled content against the Article 18 prohibitions before any broadcast.

Understanding how to navigate enforcement risk is a core part of what our team provides through YCIP’s consultation and litigation support services. Early legal review of your marketing content and supply chain structure is far less costly than responding to an enforcement action after the fact.

Real Enforcement Cases — Lessons From Recent Penalties

Why Case Studies Matter

Regulatory frameworks are only as meaningful as the enforcement behind them. The cases below — all drawn from official Chinese government enforcement actions in 2025 and 2026 — illustrate what compliance failures look like in practice, and what the consequences have been. Each case carries lessons directly applicable to foreign brands operating in or entering this market.

Key Compliance Lessons From These Cases

Reading across these four cases, three consistent themes emerge:

First, advertising language is treated as evidence. In both the Yuyao and Shanghai cases, the enforcement action was directly triggered by specific language in product marketing materials. Platform listings, livestream transcripts, and WeChat promotional content are all being monitored and treated as formal advertising under Chinese law.

Second, customs documentation errors carry serious consequences. The Jinhua case demonstrates that an incorrect HS code — even if it appears to be an administrative error rather than intentional fraud — can result in enforcement action and supply chain disruption. Under Order 280’s tightened declaration requirements, this risk is now higher than ever.

Third, platform-level enforcement has escalated to national significance. The Yousiyii event is particularly instructive: a single brand’s compliance failure triggered a regulatory intervention that affected the entry requirements for all new health product merchants across three major platforms. In China’s current enforcement environment, one brand’s violation can reshape the operating conditions for the entire sector.

For brands that have already received a warning, been flagged by a platform, or received a customs inquiry, our litigation and consultation support team can provide immediate assistance. For those still in the planning stage, proactive compliance review is strongly recommended before launch.

Frequently Asked Questions

Do I need to register in China to sell health products there?

It depends on your sales channel. If you import and sell through general trade (physical retail or standard domestic e-commerce like a Tmall flagship store), you must obtain a Blue Hat registration certificate from SAMR. Without it, your product cannot legally be marketed or sold as a health food in China. If you sell through cross-border e-commerce channels — such as Tmall International or Douyin Global Shopping — you may qualify for the Document 486 exemption from registration requirements, provided your product is on the permitted goods list and you meet all other compliance obligations, including those introduced by Order 280 in June 2026.

Can I claim health benefits in product advertising in China?

No — with very narrow exceptions. Under Article 18 of the Advertising Law, health food ads in China cannot make efficacy assertions or guarantees, reference disease prevention or treatment, or use celebrity or KOL endorsements. These rules apply to all marketing channels, including product listing pages, livestreams, short videos, and social media posts. Ordinary (non-registered) food products face even stricter limits: they cannot make any health function claims at all, regardless of how the claim is phrased.

Can cross-border health products be promoted via livestream in China?

Technically yes, but with significant restrictions. Since February 2026, livestream commerce is formally classified as commercial advertising under Chinese law. All six prohibitions in Article 18 of the Advertising Law apply in full. KOL or influencer endorsements for health foods are prohibited. The disclaimer “This product cannot replace medicine” must be visible during broadcasts. Platforms are required to pre-screen this content, and violations result in content removal, merchant suspension, or account termination.

What are the key changes under Order 280 in June 2026?

Order 280 introduces three major changes affecting imported health products. First, health foods now require official recommendation from the exporting country’s competent authority as part of the Chinese customs registration process. Second, full ingredient disclosure — including excipients — is now mandatory, and all documentation must be consistent across customs declarations, registered formulas, test reports, and Chinese labels. Third, a monitored ingredients watchlist has been established; products containing NMN, CoQ10, melatonin, glutathione, ashwagandha, and berberine must provide formal regulatory compliance evidence from the country of origin.

How do I legally obtain the Blue Hat certification for an imported product?

Foreign brands must apply through the registration pathway (注册制) for most imported health foods — unless the product uses only ingredients already approved in China’s permitted raw materials catalog, in which case the simpler filing pathway (备案制) may apply. The registration process requires submission to SAMR of: a product R&D report, complete formula, production process documentation, safety and health function evaluation, proposed Chinese-language label and instruction sheet, and physical product samples. The process involves technical review and is typically multi-year for novel ingredients. Engaging experienced IP and regulatory counsel early significantly improves approval outcomes.

What penalties apply for violating health product advertising rules in China?

Penalties operate on two levels. Administratively, the Advertising Law empowers regulators to order cessation of the illegal advertisement and impose fines. Under Article 20 of the Anti-Unfair Competition Law, companies face fines of RMB 200,000 to RMB 1,000,000 for false commercial promotion; for serious violations, fines can reach RMB 1,000,000 to RMB 2,000,000, and the business license may be revoked. On the criminal side, individuals responsible for false advertising that causes consumer harm may face criminal liability for the offense of false advertising (虚假广告罪). Platform delistings and reputational consequences frequently compound the legal penalties.

Is the China health products market still growing in 2026?

Yes, and the growth trajectory remains strong despite increased regulation. The market reached RMB 377.5 billion in 2025 and is projected to exceed RMB 400 billion in 2026, driven by the silver economy (220+ million people aged 65+) and the Gen Z “light wellness” consumer trend. The regulatory tightening of 2026 is, paradoxically, creating opportunity for compliant foreign brands: as grey-market operators are forced out, legitimate brands with proper registration, trademark protection, and advertising compliance are gaining market share in a cleaner competitive environment.

What trademark considerations apply specifically to health product brands entering China?

This is one of the most practically important IP questions for health brands. China operates a first-to-file trademark system — meaning the first party to register a mark owns it, regardless of prior use elsewhere. For health brands, this creates several specific risks: your brand name, Chinese-language brand name, product names, and packaging design elements all require separate trademark registrations. Tmall entry requires an ® trademark. Blue Hat registration embeds your brand name into a legal record that third parties can use to identify filing opportunities. Our team recommends that trademark registration precede market entry — ideally by 12 to 18 months given standard approval timelines. Learn more about trademark registration for foreign companies in China, or request a trademark registration quote from our team today.

Conclusion: Entering China’s Health Products Market the Right Way

China’s health product market offers one of the most significant commercial opportunities available to foreign brands today — a market already worth RMB 377.5 billion, projected to exceed RMB 400 billion in 2026, with e-commerce penetration above 63% and consumer demand accelerating across both older and younger demographics.

But this market also carries a compliance burden that is unlike almost any other consumer products sector globally. The Blue Hat registration system, the Document 486 cross-border framework, Order 280’s new full-chain customs requirements, the Advertising Law’s absolute prohibitions, and the platform-level entry standards that were tightened across Tmall, Douyin, and Xiaohongshu in April 2026 — all of these create a legal landscape that rewards preparation and punishes shortcuts.

The brands that succeed in China’s health product market share a common characteristic: they treat legal and IP compliance as a strategic investment, not a cost to be minimized. They register trademarks early. They understand which channel — general trade or cross-border e-commerce — best fits their product and timeline. They review their advertising content against Chinese law before it goes live. And they work with counsel who understands both the regulatory framework and the commercial realities on the ground.

At Yucheng IP Law (YCIP), we work with foreign health brands at every stage of China market entry — from initial trademark clearance and registration, through product regulatory strategy, to platform compliance review and enforcement response. Our team has the on-the-ground experience and the legal expertise to help you build a market position in China that is sustainable, protectable, and commercially viable.

Whether you are at the research stage, actively preparing a market entry, or managing an existing presence that needs a compliance review, we are ready to assist.

→ Contact YCIP for a consultation on your China health product market entry strategy
→ Get a trademark registration quote for your health brand in China
→ Explore our full range of China IP legal services

References (Continued)

8. Yuyao Municipal Market Regulation Bureau (余姚市市场监督管理局), Administrative Penalty Decision — False Health Claims in Imported Food Promotion, 2025. Source Role: Official Enforcement Record. Support Status: Supports. Relevance: Confirms RMB 50,000 fine for “cure-all” advertising language applied to imported food product.
9. Jinhua Customs (金华海关), Administrative Penalty Case — Cross-Border Health Supplement HS Code Misclassification, 2025. Source Role: Official Enforcement Record. Support Status: Supports. Relevance: Documents administrative penalty for customs declaration misclassification of cross-border e-commerce health products.
10. State Council Food Safety Office / SAMR / General Administration of Customs, Joint Regulatory Notice Following Yousiyii Platform Enforcement Action, April 2026. Source Role: Official Government Notice. Support Status: Supports. Relevance: Documents platform-wide regulatory intervention triggered by single brand compliance failure; confirms upgraded merchant review obligations across Douyin, Tmall, and Xiaohongshu.
11. Putuo District Market Regulation Bureau (上海市普陀区市场监督管理局), “Iron Fist Action” Typical Case Bulletin, 2025. Source Role: Official Enforcement Bulletin. Support Status: Supports. Relevance: Shanghai cross-border operator named in national enforcement bulletin for substandard food production and illegal health advertising.

Further Reading and Official Resources

• State Administration for Market Regulation (SAMR) — Official Website — Primary authority for Blue Hat health food registration in China.
• General Administration of Customs of China — Official Website — Source for Order 280 full text and overseas manufacturer registration portal.
• Ministry of Commerce of China (MOFCOM) — Official Website — Source for Document 486 and cross-border e-commerce permitted goods list updates.
• China National Intellectual Property Administration (CNIPA) — Trademark and patent filing authority; verify Blue Hat product brand name availability before registration.
• Food Safety Law of the People’s Republic of China — Full Text (NPC) — Primary legislative source for Articles 77 and 78 cited in this article.

Disclaimer: The content of this article is for general informational purposes only and does not constitute legal advice. Regulatory requirements applicable to health product sales in China are subject to frequent change. For advice specific to your products, business structure, or market entry strategy, please consult a qualified legal professional with relevant expertise. For inquiries regarding China IP matters, you are welcome to contact Yucheng IP Law (YCIP) at yciplaw.com/contact-us.