Are dietary supplements food or health care products

Some dietary supplements with blue hats are health products, while others without blue hats are ordinary foods.

You have probably come across two types of vitamin C effervescent tablets when you go to the supermarket: one is on the ordinary snack shelf, with only the SC food production license mark on the package. It costs more than ten yuan a piece, and it is okay to drink one or two tablets a day; the other is in the health products section of the drug store, with a blue "health food" hat logo printed on the package, and "Suitable group: people with low immunity" next to it. You can only drink one tablet a day at most. Both are dietary supplements, but they belong to completely different categories.

What’s interesting is that there have always been two completely different cognitive logics on this issue in the industry. There is no absolute right or wrong, but the positions are different.

Most regulators and researchers in academia adhere to the "qualification definition theory." When I helped new consumer brands register dietary supplements, I reviewed the documents of the State Administration for Market Regulation. In 2022, the State Administration issued a special announcement to include fish oil, coenzyme Q10, and melatonin, supplement raw materials familiar to consumers, into both the health food raw material catalog and the general food raw material catalog. That is to say, if the brand wants to make the product into a health product, it must go through the health food registration process, conduct safety and efficacy evaluations, and only after obtaining the blue hat can it claim health functions and fall under the category of health care products. If it does not want to go through such a complicated process, as long as the amount of raw materials meets the standards of ordinary food, it can be registered as ordinary food. This type of supplement is an ordinary food and cannot claim any health effects.

However, many people on the consumer side and channel side agree more with the "functional classification theory" and believe that as long as they are used to supplement nutrients such as protein, vitamins, and minerals, and are not used to fill the stomach, they are all "health products" in a broad sense. This understanding is not unreasonable. When I was working as a volunteer in the nutrition department, I would meet more than ten aunts a week with protein powder registered as ordinary food and ask, "Can this health product replenish my wife's health after surgery?" In the perception of ordinary consumers, as long as it is nutritious and not a regular meal, it is naturally linked to "health care", which is different from ordinary biscuits and drinks.

Another point of confusion is the overseas classification standards. Dietary supplements purchased overseas by many people are in the separate category of "dietary supplements" under the US FDA rules. They are between food and drugs and are neither ordinary foods nor health products. If they do not go through blue hat registration after entering the country, they will be registered as ordinary foods. This is why we often see supplement details pages purchased overseas boasting about their efficacy, while the domestic version of the same product does not dare to write any efficacy on the packaging.

To be honest, we ordinary consumers don’t have to worry about whether it is a food or a health product. Rather than classifying it, it is more useful to scan the packaging twice when buying: if it has a blue hat, eat it according to the suitable group and consumption amount written on the package, and don’t exceed the amount; if it doesn’t have a blue hat, treat it as a nutritionally fortified ordinary food, and don’t expect it to improve any disease symptoms. No matter what kind of food it is, it cannot replace normal meals, which is the core.