On July 24, 2017, CFDA issued the “Notice of General office of China Food and Drug Administration about soliciting public opinions on specification principles for the name of formula food for special medical purpose (trial)”, and solicited public opinions on it, the deadline for soliciting opinions is August 6, 2017.

The exposure draft specified the product name of formula food for special medical purpose, and clearly states that the product name shall not include the naming rules of content and the general name.

The name of formula food for special medical purpose did not have the corresponding national name specification principles previously, the implementation of this exposure draft will improve the chaotic market of naming to a certain degree, some of the naming combinations that are often seen in the Chinese market will disappear. The implementation of specification principles for the name of formula food for special medical purpose will also be a major change for production and trading enterprises. It is especially important to timely track the changes of regulations to ensure product compliance. Foodmate summarizes the exposure draft for insider reference.


The product name of formula food for special medical purpose is made up of product name and general name. Each product can have only one product name and must not be the same as the approved product name for formula food for special medical purpose. Except trademarks, the product name shall use the standard Chinese characters. “Standard Chinese characters” refers to the Chinese characters in “Common Standard Chinese Characters Table” excluding traditional characters, letters, graphics, symbols and so on. The product name can be marked with English product name at the same time, but the English name shall have a corresponding relationship with the Chinese name.

Product names shall be clear, eye-catching, durable, easy to identify and read. Content of each part of general name shall not be marked separately.

The product name of formula food for special medical purpose can use trademark name and grade name, etc., and shall not be the same as the approved and registered brand name of drug and health food. Where the trademark is used in product name, the product name shall comply with relevant provisions of naming of product name.


(I) False, exaggerated and absolute contents and those in violation of scientific principle, such as “Golden packaged”, “Super”, “Upgrade”, “Special grade”, “Top grade”, “Ultimate”, “Transcendency”, “Doctor”, “Champion”, “Special effects”, “Full effect” and “Comprehensive”, etc.;

(II) The contents concerning function of prevention, remission and treatment of disease, such as “Reducing blood sugar”, “Losing weight”, “Weight reduction”, “Treatment”, “Anti-inflammation”, etc.;

(III) The contents explicitly or implicitly declaring the functions like “Be beneficial to intellectual development”, “Increase the resistance or immunity” and “Protect the intestinal function”, etc., such as “Reinforcing intelligence”, “Probiotics”, “Easily-digestible”, “Protect gastrointestinal”, “Boost immunity”, “Body training”, “Salubrity”, etc.;

(IV) Words or words with feudalistic superstition colour, such as “Upper class”, etc.;

(V) Other words that can mislead the consumer, such as the use of homophonic or Chinese characters in similar shape may cause the misunderstanding of the consumers.


The general name of formula food for special medical purpose shall reflect the true nature of the food, use the category name or equivalent name specified in the relevant national food safety standards.

According to the product category, the general name shall be named according to the following rules:

(I) The format of general name of infant formula food for special medical purpose is “Special medical purpose + infant formula food + (product category name)”, such as infant formula food for special medical purpose (no lactose formula).

(II) The format of general name of full nutritional formula food is “Special medical purpose+ full nutritional formula food”, such as “Full nutritional formula food for special medical purpose”.

(III) The format of general name of specific full nutritional formula food is “Formula food for special medical purpose+(product category name)”, such as formula food for special medical purpose (full nutritional formula for obesity surgery).

(IV) The format of general name of non-full nutritional formula food is “Non-full nutritional formula food for special medical purpose+(product category name)”, such as non-full nutritional formula food for special medical purpose (Carbohydrate module).