Wasn’t sure where to put this, law, food or here. But have a feeling healthy lifestyle people would know more perhaps?
I’m wanting to know what kind of category single ingredient powered plant products put into gel caps would fit into. I read the health food act, which as one might assume has more to do with labelling and testing. But as raw foods (ginger, turmeric, cinnamon etc) that are dried, powdered. After this stage putting them into gel caps and selling that way? I already sell fresh, dried, cut and powdered spices, herbs vegetables etc. But the placing them into a pill has me curious. Because not claims are made as to health benefits I can’t see it being a health food product. But being placed into a pill has me worried they might jump on over to medical territory. I am a registered legal company that’s small, so all that is above board.
Note, not talking about pressed pills, only gel caps. I was thinking there could be an argument made that gel caps is simply a packaging style but that seems cheeky.
How do other companies register their items in this kind of situation? Very interested in any help suggestions or links. Chinese or English is ok
As long as it remains a food product and you don’t claim any health benefits, you probably remain under the food and hygiene laws, though you might want to check packaging laws as well to see if this type of “packaging” is allowed.
Consult with a lawyer who knows about food law to be safe.
Being registered as a company is not enough I guess, you probably have to apply as a registered manufacturer. Which brings you into a total different field.
Yes, we have the labeling and registering taken care of. For example we already sell powdered stuff like turmeric but not in gel cap form. A customer is asking for it so not too sure how to go forward. Probably need to find a lawyer (anyone have any experience or suggestions?)
Many common herbs and spices are listed in the Chinese Pharmacopoeia as TCM materials.
Saw a draft new regulation the other day that states TCM materials that are also common seasonings (e.g. pepper, star anise, ginger) can be freely used only as seasonings. No idea how that would be interpreted, but might well preclude encapsulated ginger, pepper, turmeric, etc., unless registered as a TCM pharmaceutical or functional health food. In Taiwan a functional health food registration is called a ‘little green man’ (小綠人) and takes loads of money and time to get.
Draft regulation only, so no idea if/when it will be implemented. Also got no idea whether the stuff on seasonings that are also TCM would represent a change to current practice.
Would probably be a good idea to speak with a regulatory consultant specialized in health foods, supplements, pharmaceuticals etc. Looking for one myself right now, so don’t really have a good recommendation.
Great thanks. I was talking to someone about possible changes to other things as well being changed to medicine status such as cinnamon. One of the other rules as I understood it was that one, presumably trading companies, had to also source it from registered Chinese medicine type companies. This leaves a grey are to me about sourcing from farmers if not registered for anything medical related.
Encapsulated surely will not be included as a seasoning.
Do you know of somewhere I can find a government list of things and where they are placed? Or does the government just copy everything from Chinese Pharmacopoeia and call it a medicine? I assume it’s a little more specific.
