What qualifications are required for domestic sales of dietary supplements?

At present, domestic dietary supplements are divided into two categories based on regulatory attributes: general food and health food (blue hat). The core qualifications required for sales cover two dimensions: product compliance and entity compliance. The requirements for the two types of products are quite different. If you step on the wrong boundary, it is easy to hit the regulatory red line.

Last year, I came into contact with an entrepreneurial team that was engaged in cross-border sales to domestic sales. They finally negotiated the domestic agency rights for the popular foreign vitamin gummies. They planned to sell them directly on Douyin, but they were removed from the shelves just after more than 300 orders were placed, and they were fined 20,000 yuan. The reason was that they wanted to save the blue hat application cost, so they reported the gummies added with gamma-aminobutyric acid as ordinary food. They did not mark the unsuitable group of people, and even wrote about the effect of "improving sleep" on the details page, which just happened to be in the crosshairs of supervision.

In fact, many novice merchants tend to confuse the requirements of the two types of dietary supplements. If you are making ordinary food dietary supplements, such as simple vitamin C tablets and protein powder, the product itself must have a compliant SC food production license, and the nutritional composition list and ingredient list must comply with the labeling standards of GB28050. When promoting, the most you can say is the nutritional effects of raw materials such as "vitamin C supplement", and no words can be mentioned about disease prevention or health care functions. For health food dietary supplements with a blue hat, the requirements will be even stricter. The product must have a health food registration or filing certificate issued by the State Administration for Market Regulation. The small blue hat logo must be printed in the most conspicuous position of the package. The functions that can be promoted can only be the contents of the 27 types of health functions marked on the approval document. You can add expressions such as "anti-aging" and "anti-cancer" by yourself, and you can get it right.

After talking about the products, let’s talk about the qualifications required by the merchant itself. Whether you are opening an offline physical store or doing online live streaming, first of all, the business scope of the business license must include the corresponding categories of "food sales" and "health food sales". Now there is no need to apply for an old-fashioned food circulation license separately. You only need to submit materials on the government affairs website to register for prepackaged food sales. If you are quick, you can get the registration certificate on the same day. Without this certificate, it is easy to be targeted by professional counterfeiters for claiming compensation. Oh, by the way, if you are selling on an online platform, there are additional thresholds for different platforms. For example, if you sell blue hat products on Tmall and JD.com, you must additionally upload the official inquiry certificate of brand full-link authorization and approval. For Douyin live broadcast, the anchor must complete the food category qualification test in advance, otherwise he may be cut off as soon as the broadcast starts.

If you are selling imported dietary supplements, you need to prepare a few more materials. Those who import through general trade must have customs declaration forms and entry cargo inspection and quarantine certificates. If they are ordinary foods, they must be labeled in Chinese according to domestic requirements. Blue hat products must also obtain domestic health food approval before they can be imported through general trade. If we adopt the cross-border e-commerce bonded warehouse model, it will be a little looser. There is no need to apply for domestic SC or blue hat, as long as it is in the cross-border e-commerce retail import positive list. However, products under this model can only be sold directly to end consumers and cannot be redistributed, otherwise it will be considered a violation.

There is still a vague area in the industry that is not completely unified, that is, whether dietary supplements made from new food ingredients are considered ordinary food or health food. The regulatory standards in different places vary quite a bit. I used to know a businessman in Guangzhou who sold white kidney bean tablet candy. The OEM said that white kidney bean extract was considered an ordinary food ingredient. However, when it was sold to Jiangsu, consumers complained. The local city supervisor believed that the product was not labeled as unsuitable for people according to the requirements of new food ingredients. It also claimed to have the effect of "blocking carbohydrates" and was suspected of violating regulations. In the end, the company paid a small sum of RMB 100,000. If you are making this kind of new raw material product, it is best to go to the food section of the local city supervisor with the packaging and raw material test reports to confirm in advance. Don’t just listen to the supply chain’s words.

Don't think these qualification requirements are troublesome. In fact, the logic is the same as that of opening a restaurant and requiring a business license and health certificate. After all, it is a product that is eaten. If the qualifications are smoothed out, you will be able to sell with peace of mind. If you really save some money and save a few steps, you may be fined more than you make.