China's food-as-medicine list now covers 106 substances — and it decides what you can sell

In this trade, whether a product can go on sale — or whether an ingredient can appear on a label — does not depend on how refined the formula is. It depends on whether the substance is on the National Health Commission's catalogue of food-and-medicine substances.

That catalogue currently lists 106 substances, and it keeps growing. For anyone running a tea shop, making tonic foods or selling online, it is worth reading before any industry report.

The catalogue governs access, not quality

The catalogue is, first of all, a list.

China's Food Safety Law is blunt: medicines may not be added to food, but substances that are traditionally both food and Chinese medicinal materials may be. How wide that opening is, the catalogue decides.

On 10 November 2021, the National Health Commission, with the agreement of the State Administration for Market Regulation, issued the Provisions on the Administration of the Catalogue of Substances That Are Traditionally Both Food and Chinese Medicinal Materials. It fixed the definition: substances traditionally used as food and listed in the Pharmacopoeia of the People's Republic of China. Two locks turn at once — the substance must be in the pharmacopoeia, and it must have a history of traditional consumption.

Many assume compliance starts with production processes. It actually starts with a list.

Expansion is normal: once in 2019, once in 2023

The catalogue is not fixed for life.

Public information shows that in 2019, six substances including danggui (angelica) were added; in 2023, nine more including dangshen (codonopsis) entered the catalogue. According to Beijing Business Today, the total now stands at 106.

The later expansion came with several detailed rules that product people should read line by line:

These substances are recommended for moderate consumption in traditional form; special groups such as pregnant and breastfeeding women and infants are not advised to consume them. When used as a raw material for health foods, they are managed under health food rules; when used as Chinese medicinal materials, under those rules. "Traditional form" means crushing, slicing, pressing, pan-firing, boiling in water or steeping in alcohol.

Safety indicators are explicit: lead, cadmium, arsenic, mercury and sulphur dioxide are measured by the methods set out in national standards, and pesticide limits follow the relevant rules of the Ministry of Agriculture and Rural Affairs.

The heaviest line is this one — the same raw material, put into ordinary food, into health food or sold as a medicinal material, falls under three different sets of rules. They cannot be mixed.

"If it's on the list, I can use it freely" is only half right

A common view in the market holds that since a substance is on the catalogue, adding more formats and saying a little more about its benefits is not a big problem.

That reading misses twice.

One error is treating "may be used" as "may be used at will". The catalogue grants permission for traditional forms of consumption; concentrated or extracted forms and different dosages are no longer the same thing and require a separate compliance route.

The other is treating "compliant" as "unpoliced". According to Huxiu's review of the industry, 50 new national food safety standards have taken effect, raising requirements for raw material traceability and the wording of claims; medicalised and exaggerated claims are an explicit red line. The same review notes that substances such as sanqi (notoginseng), danshen (red sage), heshouwu (fleeceflower root) and fuzi (aconite) are strictly prohibited as additions to ordinary food.

This boundary belongs on the procurement department's wall: outside the catalogue is a hard line; inside the catalogue there are still rules on how to use. Hold both, and you are compliant.

Money and policy have arrived together

Why watch this especially closely now?

According to Huxiu, China's food-as-medicine consumer market was worth about RMB 370 billion in 2025, up 21.6 per cent year on year; in the first half of 2026 it had already sold about RMB 224 billion, with a full-year forecast of RMB 450 billion to 500 billion. Online channels account for about RMB 126.6 billion in annual sales, growing 28.9 per cent a year, with Gen Z and the post-1990 generation making up more than 60 per cent.

On the policy side, the 15th Five-Year Plan for the Revitalisation and Development of Traditional Chinese Medicine was issued on 23 July 2026 by the National Administration of Traditional Chinese Medicine and the National Development and Reform Commission; the 15th Five-Year Plan for National Health also calls for advancing the inheritance and innovative development of traditional Chinese medicine.

Money is flowing in; rules are being written down. At such a moment, those who understand the rules first have the lowest rework costs.

What it means for operators

For anyone opening a shop or selling goods, this comes down to one concrete action: the first step in product selection is not testing a formula, not comparing prices, but checking the catalogue.

Whether an ingredient is among those 106, and if so in what form, for which consumers and with what label wording — these decide whether a product can be sold steadily. Checking takes little time; missing it can cost a whole batch.

Our own approach follows that order. PAKONTONG's twenty-four herb tea gift box is made in individual small tins, convenient for daily brewing; at the Zhuhai City Balcony store, by day it serves freshly brewed herbal tea, using chenpi (dried tangerine peel), guihua (osmanthus) and longjing (Dragon Well tea) in coffee, and by night it switches to herbal craft brews and herbal cocktails — putting food-and-medicine substances back into everyday eating and drinking, rather than selling them as "something else". That is the road that lasts.

Those who stay in this trade are mostly not the ones with the most mystical formulas, but the ones clearest about where their raw materials come from and where the compliance line sits.