On January 2, 2020, the National Health Commission and the State Administration for Market Regulation issued the “Notice on Launching a Pilot Program for the Management of Nine Substances, Including Codonopsis pilosula, as Both Food and Traditional Chinese Medicinal Materials.”
The notice states that, in accordance with the Food Safety Law and following a safety assessment and extensive public consultation, a pilot program will be launched for the production and operation of nine substances—namely Codonopsis pilosula, Cistanche deserticola, Dendrobium officinale, American ginseng, Astragalus membranaceus, Ganoderma lucidum, Cornus officinalis, Gastrodia elata, and Eucommia ulmoides leaves—that are traditionally regarded as both food and medicinal materials (hereinafter referred to as “food–medicine substances”).
Based on the pilot implementation in various regions, the National Health Commission, in collaboration with the State Administration for Market Regulation, will conduct research and feasibility studies on including the aforementioned substances in the Catalog of Food-and-Drug Substances for regulatory purposes.
Since ancient times, Traditional Chinese Medicine has upheld the theory of “medicine and food sharing a common origin” (also known as “medicine and diet sharing a common origin”)—a principle that holds that many foods are both nourishment and medicine, capable of preventing and treating disease just as effectively as medicinal remedies.
The Tang-dynasty text Huangdi Neijing Taisu once stated: “When consumed on an empty stomach, it serves as food; when consumed by the sick, it serves as medicine,” thereby reflecting the principle of “medicine and food share a common origin.”
The Huangdi Neijing also states: “For highly toxic conditions, ten parts of treatment remove six; for moderately toxic conditions, ten parts remove seven; for mildly toxic conditions, ten parts remove eight; and for non-toxic conditions, ten parts remove nine. Grains, meats, fruits, and vegetables—through dietary nourishment, all such conditions may be fully cured.” This passage underscores the disease-clearing efficacy of dietary therapy.
Previously, the former Ministry of Health issued the “Notice on Further Standardizing the Management of Raw Materials for Health Food,” which sets out specific provisions regarding substances that are both food and medicine, substances that may be used in health food, and substances prohibited for use in health food. The lists of these three categories of substances are as follows:
List of traditional Chinese medicines that are both food and medicine, as published by the National Health Commission:
Cloves, star anise, fennel, sword bean, small fennel, thistle, Chinese yam, hawthorn, purslane, black rat snake, black plum, papaya, hemp seed, orange blossom, polygonatum, licorice, angelica root, ginkgo nut, white hyacinth bean, white hyacinth bean flower, longan pulp (longan), cassia seeds, lily, nutmeg, cinnamon, emblic myrobalan, fingered citron, apricot kernel, sea buckthorn, Euryale seed, Sichuan pepper, adzuki bean, donkey-hide gelatin, chicken gizzard lining, malt, kelp, jujube (large jujube, black jujube, sour jujube), monk fruit, prunus mume seed, honeysuckle, green fruit, fishmint, ginger (fresh ginger, dried ginger), forsythia fruit, goji berry, gardenia fruit, amomum, Sterculia lychnophora seed, poria, citron, elsholtzia, peach kernel, mulberry leaf, mulberry fruit, tangerine peel, platycodon root, alpinia seed, lotus leaf, radish seed, lotus seed, galangal, bamboo leaf, fermented soybean, chrysanthemum, chicory, yellow mustard seed, polygonatum rhizome, perilla, perilla seed, kudzu root, black sesame, black pepper, sophora buds, sophora flowers, dandelion, honey, torreya seed, sour jujube seed, fresh imperata rhizome, fresh reed rhizome, viper, tangerine peel, peppermint, coix seed, allium tuberosum, raspberry, patchouli. (The above list comprises the 86 herbs publicly announced in 2012.)
Fifteen new Chinese medicinal material substances were added in 2014:
Ginseng, Lonicera japonica flower, coriander, rose, pine pollen, kudzu root, Broussonetia papyrifera leaf, Prunella vulgaris, angelica root, amomum kravanh, saffron, tsaoko, turmeric, and long pepper may be used as both food and medicine within the specified scope of use and dosage.
In 2018, nine additional Chinese medicinal materials were designated as substances that, according to tradition, are both food and Chinese medicinal materials.
Dangshen, Cistanche, Dendrobium officinale, American ginseng, Astragalus, Ganoderma, Gastrodia elata, Cornus fruit, and Eucommia leaf are classified as both medicinal and food resources, provided their use is confined to the specified scope and dosage.
List of Chinese medicinal materials approved for use in health food, as published by the National Health Commission:
Ginseng, ginseng leaves, ginseng fruit, Panax notoginseng, Smilax glabra, Cirsium japonicum, Ligustrum lucidum fruits, Cornus officinalis, Achyranthes bidentata, Fritillaria cirrhosa, Ligusticum chuanxiong, deer fetus, deer antler velvet, deer bone, Salvia miltiorrhiza, Acanthopanax bark, Schisandra chinensis, Cimicifuga foetida, Asparagus cochinchinensis, Gastrodia elata, Pseudostellaria heterophylla, Morinda officinalis, Aucklandia lappa, Equisetum arvense, Arctium lappa seeds, Arctium lappa root, Plantago seeds, Plantago asiatica, Glehnia littoralis, Fritillaria thunbergii, Scrophularia ningpoensis, Rehmannia glutinosa (raw), Polygonum multiflorum (raw), Bletilla striata, Atractylodes macrocephala, Paeonia lactiflora, Amomum kravanh, Haliotis shell, Dendrobium, Lycium cortex, Angelica sinensis, Bamboo shavings, Carthamus tinctorius, Rhodiola rosea, American ginseng, Evodia rutaecarpa, Achyranthes bidentata (from Henan), Eucommia bark, Eucommia leaves, Semen Astragali complanati, Moutan cortex, Aloe vera, Atractylodes lancea, Psoralea corylifolia, Coix seed, Red peony root, Polygala tenuifolia, Ophiopogon japonicus, Testudinis carapax, Agastache rugosa, Platycladus orientalis leaves, processed rhubarb, processed Polygonum multiflorum, Eleutherococcus senticosus, Rosa rugosa fruit, Lysimachia christinae, Alisma plantago-aquatica, Rose flower, Roselle, Anemarrhena asphodeloides, Apocynum venetum, Kuding tea, Fagopyrum esculentum, Vaccaria segetalis, Citrus peel, Magnolia flower, Curcuma longa, Citrus aurantium pericarpium, Citrus aurantium immaturus, Platycladus seed, Pearl, Gynostemma pentaphyllum, Trigonella foenum-graecum, Rubia cordifolia, Piper longum, Allium tuberosum seeds, Polygonum multiflorum vine, Cyperus rotundus, Drynaria fortunei, Codonopsis pilosula, Morus alba bark, Mulberry branches, Fritillaria thunbergii (Zhejiang variety), Leonurus cardiaca, Centella asiatica, Epimedium, Cuscuta, Wild chrysanthemum, Ginkgo biloba leaves, Astragalus membranaceus, Fritillaria hupehensis, Senna leaf, Geckos, Vaccinium myrtillus, Sophora japonica seeds, Typha pollen, Tribulus terrestris, Propolis, Tamarind, Eclipta prostrata, processed rhubarb, processed Rehmannia, turtle plastron.
List of Traditional Chinese Medicines Prohibited for Use in Health Foods (Note: Traditional Chinese Medicines with significant toxicity or adverse side effects)
Eight-angled lotus, eight-li hemp, thousand-gold seed, earth green wood fragrance, mountain henbane, Sichuan aconite, Guangfangji, masan leaf, strychnos seed, six-angled lotus, heavenly child, croton seed, mercury, periwinkle, galega, raw tian nan xing, raw banxia, raw bai fu zi, raw lang du, white descending pill, lycoris, guan mutong, nong ji li, oleander, cinnabar, poppy husk, red ascending pill, yew, red fennel, red powder, sheep-horn poison, sheep’s foot, Lijiang water chestnut, Beijing euphorbia, Kunming mountain begonia, pufferfish, shepherd’s purse flower, green ladybug, fishvine, digitalis, golden flower, morning glory seed, arsenic (white arsenic, red arsenic, arsenic trioxide), caustic black root, fragrant bark (stemona bark), camel thorn, podophyllum, wild sassafras, iron mace, lily of the valley, snow-on-the-mountain, yellow-flowered oleander, blister beetle, sulfur, realgar, leigong vine, belladonna, veratrum, toad venom.
List of products explicitly designated by the National Health Commission as not being ordinary food (summary of annual announcements):
American ginseng, cod liver oil, Ganoderma (red Ganoderma), purple Ganoderma, cordyceps, lotus seed heart, lavender, soy isoflavones, Ganoderma spore powder, deer antler, and turtle plastron. (Please refer to the attached approval document for details.)
The list of foods explicitly designated as ordinary foods in the announcement:
White-haired Silver Dew Plum, Yellow Gelatin, Trehalose, Five-fingered Hairy Peach, Medium-chain Triglycerides, Burdock Root, Fructooligosaccharides, Sea Buckthorn Leaves, Tempeh, Wintergreen Family Bitter Tea, Pear Cactus, Corn Silk, Resistant Dextrin, Prostrate Gynura (Gynura Procumbens (Lour.) Merr), Barley Leaves, Other By-products of Farmed Sika Deer (excluding velvet antler, antlers, deer fetus, and deer bones), Pear Cactus, Oleaceae Strong-leaved Privet Bitter Tea, Stachyose, Rose Flowers (Double Red Rose, Rose rugosa cv. Plena), Mesona Herb (Mesona chinensis Benth.), Tamarind, Acerola Fruit, Broccoli Pollen, Corn Pollen, Pine Pollen, Sunflower Pollen, Purple Clover Pollen, Buckwheat Pollen, Sesame Pollen, Sorghum Pollen, Konjac, Spirulina with Blunt Apex, Maxi Spirulina, Chinese Gooseberry, Roselle, Silkworm Pupae, and Earleaf Cowherb.
List of foods with health-promoting properties as recorded in pharmacopoeial literature throughout the ages:
Foods that enhance or improve hearing: lotus seeds, Chinese yam, water chestnuts, water celery, mustard greens, and honey.
Foods that are believed to improve or enhance vision: Chinese yam, goji berries, water celery, pig liver, sheep liver, wild duck meat, black carp, abalone, snails, and clams.
Hair-growing (hair growth-promoting) foods: white sesame seeds, chives seeds, and walnut kernels.
Hair-nourishing (moisturizing and adding shine to hair) foods: abalone.
Foods that darken the beard and hair: black sesame seeds, walnut kernels, and barley.
Foods that promote beard growth (beneficial for men who do not grow beards): turtle meat.
Foods that enhance beauty and complexion (promoting rosy, radiant skin): goji berries, cherries, lychees, black sesame seeds, Chinese yam, pine nuts, milk, and lotus stamens.
Foods that strengthen and whiten teeth: Sichuan pepper, water bamboo shoots, and lettuce.
Foods for weight loss and fat reduction: water caltrops, jujubes, Chinese torreya nuts, longan, lotus leaves, oats, and green millet.
Foods for “fattening” (improving the constitution of thin individuals and strengthening the body): wheat, japonica rice, sour jujube, grapes, lotus root, Chinese yam, black sesame, and beef.
Foods that enhance intelligence (such as improving cognitive function and nourishing the brain): japonica rice, buckwheat, walnuts, grapes, pineapple, lychee, longan, jujubes, lily bulbs, Chinese yam, tea, black sesame seeds, black wood ear mushrooms, and cuttlefish.
Foods that enhance willpower: lily bulbs and Chinese yam.
Foods that calm the mind and promote restful sleep include: lotus seeds, sour jujubes, lilies, plums, lychees, longans, Chinese yam, quail, oyster meat, and yellow croaker.
Foods that invigorate the spirit and reduce fatigue: tea, buckwheat, and walnuts.
Foods that enhance vitality (such as strengthening energy and improving mobility): buckwheat, barley, mulberries, and hazelnuts.
Foods that strengthen the muscles and bones (i.e., enhance overall physical constitution, including tendons, bones, muscles, and stamina): chestnuts, sour jujubes, loaches, and table salt.
Foods that enhance hunger resistance (i.e., help the body tolerate hunger and delay the urge to eat): buckwheat, pine nuts, water caltrops, shiitake mushrooms, and grapes.
Appetite-enhancing and digestion-promoting foods: scallions, ginger, garlic, chives, cilantro, pepper, chili peppers, carrots, and white radish.
Foods that tonify kidney yang (to regulate sexual function and treat conditions such as impotence and premature ejaculation): walnuts, chestnuts, sword beans, pineapple, cherries, chives, Sichuan pepper, dog meat, dog penis, lamb, lamb fat, sparrow meat, venison, deer penis, bird’s nest, sea shrimp, sea cucumber, eel, and silkworm pupae.
Foods that are considered “seeds” (which enhance fertility, also known as “continuing the lineage,” and include the effect of stabilizing pregnancy): lemon, grape, black hen, sparrow meat, sparrow brain, chicken egg, deer bone, common carp, sea bass, and sea cucumber.
The food items with therapeutic effects documented in pharmacopoeial literature throughout the ages can be summarized as follows:
Wind-Cold Dispelling Category (For symptoms of wind-cold common cold) Foods: ginger, scallions, mustard greens, and cilantro.
Wind-Heat Dispelling Type (For symptoms of wind-heat common cold) Foods: tea leaves, fermented black beans, and star fruit.
Heat-clearing and fire-draining category (For internal heat syndromes) Foods: water bamboo shoots, bracken fern, bitter greens, bitter melon, preserved duck eggs, lily bulbs, and watermelon.
Heat-clearing and yin-nourishing category (For conditions of dry-heat injury to body fluids) Foods: sugarcane, tomato, mandarin orange, lemon, apple, melon, sweet orange, and water chestnut.
Heat-Clearing and Damp-Drying Category (For conditions of damp-heat) Foods: toon, buckwheat.
Heat-clearing and blood-cooling category (For conditions of blood heat) Foods: lotus root, eggplant, black fungus, water spinach, sunflower seeds, table salt, celery, and loofah.
Heat-clearing and detoxifying class (For conditions of heat toxicity) Foods: mung beans, adzuki beans, peas, bitter melon, purslane, shepherd’s purse, pumpkin, and leafy greens.
Heat-clearing and throat-soothing category (For internal heat causing sore throat and swelling) Foods: olives, monk fruit, water chestnuts, and chicken egg white.
Heat-clearing and summer-heat-relieving category (For heat-related conditions) Foods: watermelon, mung beans, adzuki beans, green tea, and coconut water.
Clearing Heat and Resolving Phlegm Type (For conditions characterized by excess heat and phlegm) Foods: white radish, winter melon seeds, water chestnuts, laver, jellyfish, seaweed, kelp, and horned wrack.
Warming and Transforming Cold Phlegm Category (For conditions characterized by cold phlegm) Foods: onion, apricot, mustard seed, ginger, citron, citronquat, osmanthus, and tangerine peel.
Cough-suppressing and asthma-relieving class (Food for cough and wheezing conditions): Lily bulbs, pears, loquats, peanuts, almonds, ginkgo nuts, black plums, and bok choy.
Spleen-Strengthening and Stomach-Comforting Category (For conditions of spleen-stomach disharmony) Foods: pumpkin, cabbage, taro, pig stomach, milk, mango, pomelo, papaya, chestnut, jujube, japonica rice, glutinous rice, lentils, corn, fig, carrot, Chinese yam, white duck meat, vinegar, and coriander.
Spleen-strengthening and Dampness-resolving category (For conditions of dampness obstructing the spleen and stomach) Foods: Coix seed, broad beans, toon, and kohlrabi.
Insect-repelling (For treating intestinal parasitic infestations) Foods: Chinese torreya seeds, garlic, pumpkin seeds, coconut meat, pomegranate, vinegar, and black plum.
Digestive category (For conditions of food stagnation) Foods: radish, hawthorn, tea leaves, Shenqu, malt, chicken gizzard lining, and peppermint leaves.
Warming category (For conditions of interior cold) Foods: chili peppers, black pepper, Sichuan peppercorns, star anise, fennel seeds, cloves, dried ginger, garlic, scallions, chives, yardlong beans, osmanthus flowers, mutton, and chicken.
Wind-dampness-dispelling herbs (For rheumatic conditions) Foods: cherries, papaya, Acanthopanax bark, coix seed, quail, loach, and chicken blood.
Diuretics (For conditions of difficulty in urination and edema) Foods: corn, adzuki beans, black beans, watermelon, winter melon, gourd, Chinese cabbage, white duck meat, common carp, and crucian carp.
Laxative-type (For constipation) Foods: spinach, bamboo shoots, tomatoes, bananas, and honey.
Sedative class (For neurasthenia and insomnia) Foods: lotus seeds, lily bulbs, longan pulp, sour jujube seeds, wheat, glutinous millet, mushrooms, pig heart, and stonehead fish.
Qi-regulating category (For conditions of qi stagnation) Foods: citron, orange, tangerine peel, fingered citron, mandarin orange, buckwheat, sorghum, sword bean, spinach, white radish, chives, fennel, and garlic.
Blood-activating herbs (For conditions of blood stasis) Foods: peach kernels, rapeseed, arrowhead, eggplant, hawthorn, wine, vinegar, earthworms, and clam meat.
Hemostatic agents (For bleeding disorders) Foods: daylily buds, chestnuts, eggplant, black fungus, thistle, black plum, banana, lettuce, loquat, lotus root nodes, sophora flowers, and pig intestines.
Astringent category (For conditions involving slipping and instability) Foods: pomegranate, black plum, Euryale seed, sorghum, Chinese crabapple, lotus seed, yellow croaker, and catfish.
Liver-soothing category (For conditions of excessive liver yang) Foods: celery, tomato, green tea.
Qi-tonifying category (Food for conditions of Qi deficiency): Japonica rice, glutinous rice, millet, yellow millet, barley, Chinese yam, naked oat, indica rice, potato, jujube, carrot, shiitake mushroom, tofu, chicken, goose, quail, beef, rabbit, dog meat, black carp, and silver carp.
Blood-tonifying (Food for blood-deficiency conditions): mulberries, lychees, pine nuts, black fungus, spinach, carrots, pork, lamb, beef liver, sheep liver, soft-shelled turtle, sea cucumber, and grass carp.
Yang-tonifying category (Food for Yang-deficiency conditions): Goji vegetables, goji berries, walnut kernels, yardlong beans, chives, cloves, sword beans, goat’s milk, mutton, dog meat, venison, pigeon eggs, sparrow meat, loach, sea shrimp, and mussels.
Yin-nourishing category (Food for yin-deficiency conditions): white fungus, black fungus, Chinese cabbage, pear, grape, mulberry, milk, egg yolk, soft-shelled turtle, cuttlefish, and pork skin.
Attachment: Catalog of Substances That Are Both Foods and Traditional Chinese Medicinal Materials
(Draft for Comments)
Note: Sorting is done by plant, then by animal; then by number of strokes.
Note: Basis for the inclusion of newly added substances in the “Catalogue of Substances That Are Both Foods and Traditional Chinese Medicinal Materials”
I. Ginseng. Announcement No. 17 of 2012 issued by the former Ministry of Health approved ginseng (cultivated) as a novel food resource; the Chinese Pharmacopoeia records that the botanical source and the parts used are consistent with its entries.
II. Mountain Honeysuckle. Honeysuckle was included in the “List of Substances That Are Both Food and Medicinal” promulgated by the former Ministry of Health in 2002. The sources of honeysuckle are Lonicera japonica Thunb., Lonicera hypoglauca Miq., Lonicera confusa DC., and Lonicera dasystyla Rehd. In the Chinese Pharmacopoeia, honeysuckle and mountain honeysuckle are not distinguished from one another, and the pharmacopoeial handling method is followed. According to literature review and field surveys, mountain honeysuckle has a long history of cultivation in southern China, a local tradition of consumption, and no reports of toxic or adverse reactions.
3. Pueraria lobata. According to the Chinese Pharmacopoeia (2005 edition), it is one of the botanical sources of the root of Pueraria thomsonii Benth.
IV. Rose Flowers. According to Announcement No. 3 of 2010 issued by the former Ministry of Health, rose flowers are classified as ordinary food; the Chinese Pharmacopoeia records that the botanical source and the parts used are consistent with its own specifications.
V. Pine Pollen. Announcement No. 17 of 2004 issued by the former Ministry of Health designated pine pollen as a novel food resource; the Chinese Pharmacopoeia records that the botanical source and the parts used are consistent with its entries.
VI. Blumea balsamifera leaves and Prunella vulgaris. According to Announcement No. 3 of 2010 issued by the former Ministry of Health, Prunella vulgaris and Blumea balsamifera leaves are permitted for use as raw materials in herbal cooling beverages; the Chinese Pharmacopoeia records that the botanical source and the parts used are consistent with its specifications.
VII. Angelica sinensis. According to 21 CFR 182.10 of the U.S. Code of Federal Regulations, the European Food Safety Authority (EFSA) classifies Angelica sinensis as a spice, with a recommended daily intake of 3–15 grams of the root or 3–6 grams of the root powder; in Japan, Angelica sinensis is listed on the “List of Natural Flavorings Derived from Plants or Animals” for use as a food spice; and the Chinese Pharmacopoeia records that the botanical source and the parts used are consistent with its specifications.
VIII. Amomum kravanh, saffron, Amomum tsao-ko, turmeric, and Piper longum. These are listed in the “Standards for Spices and Seasonings” (GB/T 12729.1–2008); they are also documented in the Chinese Pharmacopoeia; and their botanical origins and parts used are consistent with the records in the Chinese Pharmacopoeia.
