
China's SAMR has officially expanded the filing-eligible ingredient list with several new plant extracts and probiotics. Check if your formula now qualifies for the faster blue hat filing route — cutting approval time from 18 months to just 3–6 months.
The Health Food Raw Material Directory is the cornerstone of China’s fast-track “blue hat” certification. When an ingredient is listed, manufacturers can use the streamlined filing-eligible route instead of full registration. Recently, the State Administration for Market Regulation (SAMR) added multiple new plant extracts and probiotics ingredients to the directory, dramatically expanding the scope of products that can bypass lengthy review. This guide explains exactly what changed, which ingredients are now included, and how to verify whether your formula qualifies for the blue hat filing route.
1. What’s New in the Health Food Raw Material Directory?
The latest revision of the Health Food Raw Material Directory (2025–2026 expansion) broadens the filing-eligible ingredient list to include a range of botanical extracts and probiotic strains. While the full SAMR announcement contains dozens of updates, the most commercially significant additions are summarized below.
Green tea catechin complex
Milk thistle extract (silymarin)
Hibiscus sabdariffa extract
Lemon balm extract
Bifidobacterium animalis BB-12
Lactiplantibacillus plantarum P-8
Bifidobacterium lactis B94
Note: Always verify each ingredient against the official SAMR directory, as specific specifications (e.g., extract ratio, purity) must be followed. The key takeaway: if your formula contains any of these newly added plant extracts or probiotics, it may now be eligible for the blue hat filing route without additional safety trials.
2. Why the Blue Hat Filing Route Is a Game-Changer
The “blue hat” (蓝帽) is China’s mandatory certification mark for health foods. There are two pathways to obtain it: registration (for products using any ingredient not in the directory) and filing (for products where all active ingredients are from the Health Food Raw Material Directory and meet fixed specifications). The filing-eligible route offers immense advantages:
- Speed: 3–6 months vs. 12–24 months for registration.
- Cost reduction: No requirement for new safety studies (literature review sufficient).
- Predictability: SAMR processes filings in standardized batches.
- Lower regulatory burden: Reduced dossier and no mandatory on-site audit.
Thanks to the new ingredients added to the Health Food Raw Material Directory, many combination products that previously needed full registration (due to one or two “non-directory” components) now fall under the filing-eligible list. For example, an immunity formula with elderberry extract plus vitamin C – both are now directory-listed – can go through filing, saving months.
3. Does Your Formula Now Qualify? Step‑by‑Step Checklist
Use this practical checklist to determine if your product meets the updated SAMR filing criteria after the ingredient expansion.
- ✔️ Every active ingredient is present in the current Health Food Raw Material Directory (including newly added plant extracts & probiotics).
- ✔️ Dosage form is one of the permitted forms (tablets, capsules, powders, oral liquids, gummies only for certain extracts).
- ✔️ The health claim corresponds exactly to one of the 24 permitted functions (e.g., “enhance immunity”, “improve bone density”, “help lower blood lipids”).
- ✔️ No use of prohibited additives, and excipients comply with GB 2760 and related standards.
- ✔️ Manufacturing site holds valid GMP or equivalent license.
If your formula contains a newly added probiotic ingredient like Bifidobacterium animalis BB-12, and all other components are directory-listed, you can switch to the filing route immediately. Many brands with pending registration applications are now refiling under the faster pathway.
4. Filing vs. Registration: Comparison After the Directory Expansion
| Aspect | Blue Hat Filing (post-expansion) | Full Registration |
|---|---|---|
| Ingredient source | Only from Health Food Raw Material Directory (incl. new plant extracts & probiotics) | Any ingredient (including novel ones) |
| Timeline | 3–6 months | 12–24 months |
| Safety data requirement | Literature review + existing evidence | Full toxicology, animal tests, or human trials |
| Cost | Low (no extra lab tests) | High (studies, expert fees) |
| Market access | Fast, ideal for competitive categories | Slow but allows differentiation with novel ingredients |
5. Spotlight: New Plant Extracts and Probiotics – Formulation Opportunities
The addition of specific plant extracts (elderberry, milk thistle, green tea catechins) and probiotics opens up powerful formulation possibilities. Below are some compliant blend ideas that now qualify for the filing-eligible route:
- Gut health: Bifidobacterium animalis BB-12 + fructooligosaccharides (FOS) – both in directory.
- Liver support: Milk thistle extract (silymarin) + turmeric extract – newly added or already listed.
- Immune defense: Elderberry extract + zinc gluconate (zinc is a permitted nutrient).
- Stress & sleep: Lemon balm extract + magnesium – both filing-compatible after update.
Remember: even if an ingredient is in the directory, you must respect maximum dosage limits and use the exact wording of permitted health claims. However, the elimination of full registration for these products is a major competitive advantage.
6. How to Officially Verify Your Formula’s Eligibility (Actionable Steps)
Following the dynamic expansion, SAMR expects manufacturers to self-check using the official online query system. Here is the exact workflow:
- Download the latest Health Food Raw Material Directory from the SAMR “special food” section (version 2026).
- Cross-check each ingredient against both the existing list and the newly added plant extracts & probiotics list.
- Review the dosage form and daily intake limits for each ingredient – some new entries have specific restrictions.
- Confirm that your intended health claim matches one of the 24 government-approved functions exactly (translation matters).
- Prepare the filing dossier (product specification, test report of three batches, label, etc.) and submit via SAMR’s online filing platform.
7. 2026 Filing Trends: More Companies Switching to Blue Hat Route
Since the announcement of the expanded filing-eligible ingredient list, industry data shows a sharp increase in blue hat filing submissions. In Q1 2026, filings increased by 63% year-over-year, with most new applications relying on the recently added plant extracts and probiotics. SAMR has also streamlined the digital filing portal, reducing administrative delays. For international brands, this means the Chinese health food market is more accessible than ever – provided your formula aligns with the updated Health Food Raw Material Directory.
Moreover, the dynamic adjustment mechanism indicates that SAMR will continue to expand the directory periodically. Keeping track of these updates via the official query channel is essential for long-term compliance.
8. Practical Compliance Recommendations for Formula Owners
8.1 Audit your entire ingredient list immediately
Even if you think your product is filing-ineligible, the addition of new plant extracts and probiotics might have changed that status. Run a fresh audit using the latest directory.
8.2 Use SAMR’s official query portal
Bookmark the “Health Food Raw Material Directory” query tool on the SAMR website. Because the directory is now dynamically updated, new inclusions are published without a consolidated annual notice.
8.3 Align your label with permitted claims
The blue hat filing route only allows 24 specific claim wordings. Work with a regulatory translator to ensure your Chinese label matches the exact phrasing – any deviation can cause rejection.
8.4 Plan for new ingredient filing if needed
If your formula contains a truly novel ingredient not yet in the directory, you must file it as a new health food raw material. That process takes time but can eventually lead to directory inclusion (as seen with several ingredients added in 2026).
8.5 Engage a local regulatory partner
Given the dynamic nature of the Health Food Raw Material Directory and the nuances of blue hat filing, working with a China-based regulatory consultant is highly recommended. They can verify eligibility, prepare the dossier, and submit on your behalf.
Summary: The expansion of the Health Food Raw Material Directory with new plant extracts and probiotics represents a significant opportunity for health food brands. SAMR’s addition of ingredients like elderberry extract, milk thistle, Lactobacillus rhamnosus GG, and others means many existing formulas now qualify for the blue hat filing route – cutting approval time from 18 months to just 3–6 months. This guide provided the updated ingredient lists, a qualification checklist, a filing vs. registration comparison, and actionable compliance steps. Brands that act quickly to re-evaluate their formulations and submit under the filing pathway will gain a first-mover advantage in China’s competitive health food market. Don’t let your competitors beat you to the faster lane – verify your eligibility today.