Regulatory Pathways for Plant-Based Dairy in China

Regulatory Considerations: Ensuring Market Compliance

As plant-based dairy gains momentum, businesses looking to enter or expand in China must prioritize regulatory compliance. This includes ensuring food safety, aligning with local standards, and meeting labeling and quality control regulations.

Several government agencies oversee the regulation of plant-based dairy in China:

• State Administration for Market Regulation (SAMR): Responsible for food safety supervision, market access, and labeling requirements.
• National Health Commission (NHC): Oversees food safety standards, new food raw material approvals, and food additives.
• General Administration of Customs (GACC): Handles the inspection and quarantine of imported plant-based dairy and the registration of foreign food manufacturers.

Regulatory Requirements

1. Novel Food Evaluation

If a plant-based dairy ingredient has no traditional history of consumption in China or utilizes innovative processing methods, it must undergo safety evaluation and approval by the NHC before use.

Legal Basis: "Administrative Measures for the Safety Review of New Food Raw Materials," Article 2

2. Food Additive Approval

If an ingredient used in plant-based dairy is not listed in China’s food additive catalog or requires an expanded application scope, companies must apply for approval as a new food additive.

• Legal Basis: "Administrative Measures for New Varieties of Food Additives," Article 2

• Products claiming to be "high-protein" or "nutritionally equivalent to dairy" must meet China’s national standards for nutritional content in pre-packaged foods.

• Legal Basis: "National Food Safety Standard for Nutrition Labeling of Prepackaged Foods" (GB28050-2011), Appendix C.

4. Manufacturing and Import Requirements

• Domestic production: Companies must obtain a food production license and comply with Good Manufacturing Practices (GMP) for quality control.
• Imports: Foreign manufacturers must register with the GACC before exporting plant-based dairy to China.
• Legal Basis: "Administrative Measures for Food Production Licensing," Article 2.

Opportunities and Challenges

With growing consumer interest in sustainable and health-conscious food choices, China presents a dynamic market for plant-based dairy. However, regulatory complexity and evolving compliance requirements remain significant hurdles for new entrants.

To successfully navigate this landscape, businesses must stay informed of regulatory changes, collaborate with compliance experts, and proactively address approval processes. As China continues to refine its regulatory approach to plant-based dairy, aligning with its framework will be key to long-term success in this booming industry.