Which Chinese Herbs Can Go into a Food-Grade Herbal Tea? China’s Food-Medicine Homology List Explained for Buyers

When a botanical is also a Chinese medicinal material, the first question a licensed food factory in China asks is whether it has a lawful food basis. For most medicinal botanicals used in tea, that basis is the national food-medicine homology list. Some others are covered by a specific new food ingredient approval. Ordinary food ingredients with an established food status, such as fruit, flowers and grains, sit outside the list altogether, so absence from the list does not by itself mean an ingredient is prohibited. Availability on the medicinal market, however, never counts as a food basis.

This is the first check we run on every formula a buyer sends, and it is the most common reason a proposed blend has to change before production. The list currently holds 106 substances; the full list is in the appendix at the end of this guide.. This guide explains what it is, which common tea ingredients are on it, which need a different basis, and what happens when a formula includes something that has none.

1. What the list is

Article 38 of China’s Food Safety Law prohibits adding medicines to food, with one exception: substances that are traditionally both food and Chinese medicinal materials. The national health authority (NHC) publishes the list of those substances jointly with the market regulator (SAMR) and revises it from time to time. The management rules issued in 2021 set the bar for adding a substance: it must be in the Chinese Pharmacopoeia and have a documented history of use as food, with safety evidence reviewed before it is added.

Two points matter for buyers. First, the six substances added in 2019, including angelica root (dang gui), turmeric and saffron, are permitted only as spices and seasonings, not as general herbal tea ingredients. Second, do not assume that a related species or another plant part is covered. Mulberry leaf and mulberry fruit are separate entries; ginkgo nut is listed but ginkgo leaf is not. Newer additions specify the botanical source and edible part, and older entries should be checked at the same level before production.

2. Four food-basis checks for botanical ingredients

Being absent from the homology list is not the end of the check. We look for the legal food basis that applies to the exact ingredient. Four situations cover almost every tea formula.

The fourth category catches out many buyers. The 2002 health food ingredient list includes well-known medicinal herbs such as bai zhu (Atractylodes), san qi (Panax notoginseng), he shou wu and ginkgo leaf. Those herbs can be used in registered health food products in China, but a food factory producing ordinary tea cannot use them. Health food registration is a separate regulatory route with its own product approval, and it is not what a private label herbal tea buyer is asking for.

3. Common tea ingredients and their status

Two entries deserve a note. Cultivated ginseng, which appears in several of our stock blends, is permitted as a new resource food only for artificially cultivated Panax ginseng of five years or younger, with a daily intake limit and required label wording; wild or older ginseng is not covered. And “cordyceps” is not one ingredient: cultivated Cordyceps militaris fruiting body has a new food ingredient approval, while traditional Ophiocordyceps sinensis (dong chong xia cao) does not have an ordinary food basis. The two are not interchangeable.

4. Where buyer formulas usually run into trouble

From formulas we have reviewed over the past year, the ingredients that most often lack a Chinese food basis are:

• Ashwagandha, neem leaf, holy basil (tulsi) and valerian. None is on the homology list, and we have not identified a national approval that would allow them in an ordinary tea produced in China. Formulas built around these ingredients cannot be produced on a Chinese food line as written.
• Medicinal-market herbs that buyers assume are food: huang lian (Coptis), huang qin (Scutellaria), chai hu (Bupleurum), chuan bei mu (Fritillaria). These are pharmacopoeial materials available from any herb trader, and none can go into an ordinary tea.
• Chamomile and some other Western herbal ingredients need an ingredient-specific check. They should not be rejected simply because they are absent from the homology list; the next step is to see whether another Chinese food basis applies. Rooibos is a good example of why: it is not on the homology list, but it has been an approved new food ingredient since 2014, for leaf and fine stem, for infusion. Where a production partner declines an ingredient, we say so as a factory policy rather than presenting it as a legal prohibition.

A formula that relies on ingredients without a food basis for most of its weight is not a formula a Chinese food factory can make. Where they are a minor component, the blend can usually be reworked with covered ingredients that serve a similar role in the cup.

5. A Chinese food basis does not mean cleared for your market

The homology list and the new food ingredient approvals decide what a Chinese food factory may produce. They say nothing about whether the finished tea can be sold in the United States, the European Union or elsewhere.

In the United States, an intentionally added ingredient in a conventional food needs a lawful basis under the FD&C Act, for example a GRAS conclusion for its intended conditions of use, an applicable food additive regulation, or another exclusion from the food additive definition. FDA describes GRAS as a conclusion about safety under specific conditions of use, not a status conferred by another country’s list. In the European Union, Regulation (EU) 2015/2283 allows a novel food on the market only once it is authorised on the Union list, and whether a Chinese herb counts as novel in the EU is assessed separately. A blend can pass the Chinese check and still fail at the destination. For how the US classification works in practice, see our guide to functional herbal tea in the US as conventional food or dietary supplement. For a US-specific, ingredient-by-ingredient check, see our guide to US herbal tea ingredient compliance.

We check the Chinese side. Destination-market clearance is confirmed with the buyer, and the testing and document requirements by market are set out in our guide to herbal tea ingredient testing by destination.

6. How a formula is checked

When a buyer sends a formula, it goes to the factory’s R&D team before sampling or a final production quotation. Each ingredient is checked for its food basis, including the specified species, plant part and any use restriction. The outcome is one of three:

• All ingredients are covered: we proceed to sampling.
• One or more ingredients are not covered: we return the formula marked with the ingredients that cannot be used, and where possible suggest covered alternatives with a similar role in the blend. Whether to change the formula is the buyer’s decision.
• The buyer’s concept depends on the uncovered ingredient: the project cannot be produced in China as a food, and we say so rather than substitute silently.

Both of the last two outcomes have happened. Some buyers reworked the formula and went into production; others considered the original ingredient essential and sourced elsewhere. Either is a reasonable result, and it is better reached before samples are made than after.

7. Checking a formula before you send it

For each ingredient, note the Chinese name if you know it, the botanical name and the plant part. Ingredients from the Western herbal tradition (chamomile, lemon balm, hibiscus) and from Ayurveda (ashwagandha, tulsi, neem) should be flagged for a check rather than assumed either way. Blends built from fruit, flowers and common Chinese herbal ingredients, such as those in our stock herbal tea range, are the least likely to need changes. If in doubt, send the formula before sampling; we can first identify which ingredients need a regulatory or factory review.

FAQ

What is China’s food-medicine homology list?
It is the national list, published by the health authority NHC with the market regulator SAMR, of substances that are traditionally both food and Chinese medicinal material. Under Article 38 of the Food Safety Law, only these substances may be used as medicinal-type ingredients in ordinary food. The list currently has 106 entries.

Can a Chinese food factory use any herb that is in the Chinese Pharmacopoeia?
No. Pharmacopoeia inclusion is a condition for being added to the list, not a substitute for it. Many pharmacopoeial herbs, such as Coptis, Scutellaria and Fritillaria, are not permitted in ordinary food.

Is ashwagandha allowed in herbal tea made in China?
Ashwagandha is not on the homology list, and we have not identified a national approval covering its use in ordinary tea. It cannot be used in food-grade tea blends produced by our partners.

Is rooibos allowed?
Yes. Rooibos (Aspalathus linearis) leaf and fine stem was approved as a new food ingredient in 2014, with infusion as the specified use.

Are astragalus and codonopsis allowed?
Yes. Both were formally added to the homology list in 2023, for the botanical sources and parts specified in the announcement.

If an ingredient has a Chinese food basis, can I sell the tea in the US or EU?
Not automatically. US GRAS status and EU novel food authorisation are separate assessments. The Chinese rules govern production in China only.

To check a tea formula against the homology list and the destination-market rules before quotation, send the ingredient list through our private label herbal tea bags page.