China · Advertising framework
Email, SMS and direct-message marketing for food supplements in China
General market orientation, not campaign clearance. Research scope and dates
Product and service rules
Health food is not interchangeable with an ordinary supplement category
Legal requirement — paraphrased
Determine whether the product is health food, ordinary food, a medicine or another category. Health-food advertising requires review and the prescribed identification and statements, including that it is not a substitute for medicine. Claims must follow the approved or filed scope and cannot promise disease prevention or treatment.
Sources: SAMR Order 21 — regulated product advertising review; Advertising Law of the People’s Republic of China
Track approval expiry and the approved creative version
Legal requirement — paraphrased
Under Order 21, advertising approval expires with the earliest relevant underlying product or production document; where those documents have no expiry, the advertising approval lasts two years. Changes to approved content require renewed review. Do not treat a shortened or rearranged video as automatically covered by the original approval.
Sources: SAMR Order 21 — regulated product advertising review
Keep the applicable warning visible throughout video
Legal requirement — paraphrased
SAMR Order 21 requires category-specific warnings and the advertising approval number. OTC ads need the OTC symbol and the instruction to purchase/use according to the leaflet or pharmacist guidance; personal-use devices have their own instruction and applicable contraindication notice. Health-food ads must state that the product is not a medicine and cannot replace medicine for disease treatment, and identify suitable and unsuitable users. Required prominent information must remain visible throughout video, with clear type and colour.
Sources: SAMR Order 21 — regulated product advertising review · Articles 5–10; use the exact Chinese wording from the approved creative.
Channel rules
Check the complete consumer-facing message
Regulator guidance
Advertising must be truthful and clear. Review the accuracy of stated functions, benefits, provider details, prices and promises under the Advertising Law. Sector review requirements and prohibited claims continue to apply even when the advertiser identifies the commercial nature of a message.
Do not disguise regulated advertising as health education
Legal requirement — paraphrased
Reviewed health advertisements must remain within the approved content. Internet rules prohibit disguised medical, medicine, device and health-food advertisements presented as health knowledge; related supplier contacts or shopping links alongside that knowledge are specifically restricted. Paid search needs clear advertising identification.
Health information and automated marketing need separate review
Legal requirement — paraphrased
PIPL treats medical and health information as sensitive personal information, with heightened necessity and protection requirements. Assess applicable separate-consent obligations and the limited non-consent bases. Automated commercial marketing must provide the required non-personalised option or convenient refusal route; check cross-border data flows separately.
Sources: Personal Information Protection Law
Electronic advertising needs permission and an effective refusal route
Legal requirement — paraphrased
Advertising Law article 43 restricts electronic advertising sent without consent or request. Identify the sender and provide a way to refuse further messages. Apply the relevant personal-information rules as a separate layer.
Do not apply the ordinary-data threshold to health data
Regulator guidance
The CAC identifies medical and health information as sensitive personal information. Its under-100,000-person ordinary-data exemption excludes sensitive data. Subject to stated exemptions, a non-critical-infrastructure operator exporting sensitive information for fewer than 10,000 people must use the standard-contract or certification route; at least 10,000 requires a security assessment. Important data and critical-infrastructure operators have separate assessment triggers. Count people from 1 January and document the specific exemption, if any; an advertising consent checkbox does not establish a transfer mechanism.
Sources: Cross-border data provisions — official explanatory FAQ
Separate promotional and service messages
Editorial recommendation
Review the rules for the actual delivery method: email, SMS and private social messages are not interchangeable. Keep the relevant permission record, accurate sender details and a working suppression process.
Campaign workflow
Food Supplements: prepare the review
Editorial recommendation
Determine whether the local category is food, natural health product, medicine or another regulated class. Match each claim to the local permitted or notified wording and its composition and use conditions. Assess captions, testimonials and images for an implied treatment or prevention claim.
Keep a traceable campaign decision
Editorial recommendation
Keep one review record linking the offer, local market status, claim evidence, exact creative, media settings and any regulatory or professional clearance. Record who checked each condition. Reopen the review when the offer, claim, source rule or execution changes.
Pre-publication checklist
- Determine whether the local category is food, natural health product, medicine or another regulated class.
- Match each claim to the local permitted or notified wording and its composition and use conditions.
- Assess captions, testimonials and images for an implied treatment or prevention claim.
- Record product or provider eligibility before approving claims.
- Archive the final creative and its evidence, permissions and review decisions.
- Assign an owner for source updates, complaints and prompt withdrawal of inaccurate material.
Scope and unresolved questions
- Mainland only. Beijing TCM review, national online-retail display conditions, warning presentation and a cross-border data route are documented. Other provincial filing procedures, actual seller permissions, platform account rules, product-specific Chinese assets and the transfer facts still require review.
- This national baseline does not review every broadcaster rule, platform policy, regional licensing condition, promotion mechanic or data-transfer arrangement. No format-specific warning dimensions or durations should be inferred where none are supplied.
Research scope, introduction and dates
Food-supplement promotion by email, SMS and direct messages in China begins with local classification. A product sold as a supplement elsewhere may follow a different health-product route here; check the applicable claim conditions before adapting testimonials or benefit statements.
Email, SMS and private platform messages can follow different permission rules. Identify the delivery technology and the recipient relationship, then review the promotional content and withdrawal process separately.
General market orientation, not legal, regulatory or medical advice, a complete compliance plan or clearance of an advertisement. Actual requirements depend on the specific offer and campaign.
How to use this national baseline
Editorial overview
This framework combines researched national rules with editorial review steps. Mainland China only; Hong Kong, Macau and Taiwan are outside this pack. A visible channel workflow does not establish that the selected product or service may be advertised there. Read the category restrictions first.
The review date identifies when the cited provisions or regulator excerpts were checked. It does not mean that every local rule, exception, professional standard or platform policy has been reviewed.
Sources
- SAMR Order 21 — regulated product advertising review
Follow-up review of the cited issue on 25 October 2026; scope and remaining conditions are recorded in the modules and review register.
- Advertising Law of the People’s Republic of China
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- Internet Advertising Measures, SAMR Order 72
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- Personal Information Protection Law
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- Cross-border data provisions — official explanatory FAQ
Follow-up review of the cited issue on 25 October 2026; scope and remaining conditions are recorded in the modules and review register.
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