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The current application status of traditional Chinese medicinal materials in food

May 30, 2024

Traditional Chinese medicinal materials are an important component of traditional Chinese medicine and a cornerstone for improving the health quality of the people. With the continuous development of the health concept of "replacing medicine with nourishment", many traditional Chinese medicinal materials are transforming from "medicine" to "food" and gradually integrating into people's lives. Traditional Chinese medicinal materials and health foods are the two main areas of application in the food industry.

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Clarify the homology between medicine and food and health food

Medicinal and food homologous food is a food developed based on prescribed medicinal and food homologous substances, managed according to ordinary food management. Medicinal and edible homologous substances refer to the edible parts of animals and plants that meet the traditional eating habits specified in the List of Items that are Both Food and Medicine in China, and are included in the national standards for traditional Chinese medicinal materials (including the Pharmacopoeia of the People's Republic of China and related standards for traditional Chinese medicinal materials).
As of now, there are 102 types of medicinal and food homologous substances officially released, including: in March 2002, the former Ministry of Health issued the "Notice on Further Standardizing the Management of Health Food Raw Materials" (Wei Fa Jian Fa [2002] No. 51), which includes the "List of Articles that are Both Food and Drug", involving 87 substances; On January 6, 2020, the National Health Commission issued Announcement No. 8 of 2019, which included six substances, including Angelica sinensis, Kaempferol, saffron, Caoguo, turmeric, and Piper longum, as both food and traditional Chinese medicine, and included them in the dual-use catalog of medicine and food; On November 17, 2023, the National Health Commission and the State Administration for Market Regulation issued Announcement No. 9 of 2023, which included nine substances, including Codonopsis pilosula, Cistanche deserticola (desert), Dendrobium officinale, Panax quinquefolium, Astragalus membranaceus, Ganoderma lucidum, Cornus officinalis, Gastrodia elata, and Eucommia ulmoides leaves, in the traditional list of substances that are both food and traditional Chinese medicinal materials.
In fact, relying on China's rich resources of traditional Chinese medicine, there are far more edible medicinal and edible homologous substances, and a considerable portion have been included in the management of local specialty foods. For example, the "Management Measures for the Catalogue of Traditional Chinese Medicinal Materials Used in Guangxi Local Specialty Foods" released by Guangxi specifies the list of Chinese medicinal materials that can be used in food. They are: Cinnamomum cassia (including cassia twigs), Momordica grosvenorii, Illicium verum, Guangxi zedoary (including Guiyujin), longan meat (longan), mountain bean root, Spatholobus suberectus, chicken bone herb, Zanthoxylum nitidum, and Guangzhou earthworm.
There are 31 types of characteristic medicinal herbs in Guangxi region, including Chuanxinlian, Zhongjiefeng (Grass Coral), Artemisia annua, Pueraria lobata, Five Fingered Peach, Lonicera japonica, Amomum villosum, Sophora japonica, Lysimachia officinalis, Tianqi, Tiandong, Gouteng, Hepu Pearl, Orange Red, Magnolia officinalis, Ganoderma lucidum, Polygonum multiflorum, Dendrobium officinale, Golden Flower Tea, Gynostemma pentaphyllum, Eucommia ulmoides, Fufangteng, Cherry Blossom (Root), Mahonia cordata, Baibu, Talcum powder, Chinese yam, Jasmine, Turmeric, Yizhiren, and Geji.
Health food refers to food that claims to have specific health functions or is intended to supplement vitamins and minerals. Food that is suitable for specific populations, has the function of regulating the body, is not intended for treating diseases, and does not cause any acute, subacute, or chronic harm to the human body. Although it belongs to food, it is different from food with the same origin as medicine and food. It belongs to special foods and requires functional evaluation before being put into the market, and is subject to stricter supervision.

From the perspective of permitted Chinese medicinal materials, in addition to containing common food ingredients such as medicinal and food homologous substances and new food ingredients, there are also 114 types of Chinese medicinal materials that can be added to health food. Health food containing traditional Chinese medicine ingredients is also the mainstream product in the domestic health food market. According to statistics, from 2014 to 2019, there were 6006 health foods approved by regulatory authorities in China, including 2820 traditional Chinese medicine health foods, accounting for 46.95%.

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Food regulation is increasingly tightening

Since the concept of medicinal and food homology is based on traditional Chinese medicine, "treating diseases and saving people, strengthening the body" seems to have become an invisible label of medicinal and food homologous substances, which is also the root cause of the chaos in the application of medicinal and food homologous substances. For this reason, when traditional Chinese medicine products are applied in the food industry, in addition to meeting the requirements of the same origin of medicine and food and the catalog of health foods, the National Administration of Traditional Chinese Medicine has issued the "Norms for Traditional Chinese Medicine Health Care Services (Trial)" to limit the standardized application of health foods. The regulations clearly state that institutions and their personnel providing traditional Chinese medicine health care services shall not engage in diagnostic and treatment activities, including the following situations:
(1) Using acupuncture, scar moxibustion, foaming moxibustion, traction, pulling method, minimally invasive traditional Chinese medicine techniques, traditional Chinese medicine enema, and other techniques that are traumatic, invasive, or dangerous;
(2) Provide medication prescriptions;
(3) Oral administration of traditional Chinese medicine slices to service recipients that do not comply with the provisions of the List of Items that are both Food and Medicine and the List of Items that can be Used for Health Food;
(4) Carry out medical qigong activities;
(5) Other diagnostic and treatment activities prescribed by the national department in charge of traditional Chinese medicine.
The regulations also require that institutions and their personnel providing traditional Chinese medicine health and wellness services shall not publicize the therapeutic effects, shall not carry out false advertising under the pretext of traditional Chinese medicine prevention, health preservation, disease prevention, health consultation, or use traditional Chinese medicine theories and terminology to deceive consumers and seek improper benefits, and shall not use medical language in advertisements.

A recent hot topic is during the 2024 National People's Congress and Chinese People's Political Consultative Conference. Representative Zhang Boli suggested implementing a "negative list" management for medicinal and edible health foods, clearly listing negative lists that cannot be used as medicinal and edible health foods, and strengthening the investigation, analysis, and evaluation of literature, clinical and social applications of medicinal and edible health foods. From the current management mode, the Notice on Further Standardizing the Management of Health Food Raw Materials has issued a clear list of prohibited traditional Chinese medicine raw materials for health food, while the same source of medicine and food has provided a clear admission list. However, considering the vast quantity of traditional Chinese medicinal materials in China, it is currently difficult to achieve the management concept of "if not prohibited, then proceed", after all, "safety" is the prerequisite for "health".


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2024-05-30


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