Comparison of the policies on dietary supplements among the USA, China, and South Korea

Background and objectives: As interest in and demand for dietary supplements have increased worldwide, many countries are developing policies to regulate them. This study aimed to compare the policies on dietary supplements in the USA, China, and South Korea. Methods: The data was collected from the websites of government agencies in each country. We compared the terms, definitions, and policies of dietary supplements and the institutions establishing and implementing policies on dietary supplements among these three countries. Results: The terminology for dietary supplements varies slightly among the three countries: 'dietary supplement' in the USA, 'health food' in China, and 'health functional food' in South Korea. Nevertheless, they are all defined as foods that are beneficial to health. In the USA and South Korea, it is the food and drug government agencies that administrate policies on dietary supplements, while the State Administration for Market Regulation assumes this role in China. There is no approval for pre-marketing dietary supplements in the USA, hence the word "dietary supplement" is usually displayed on the products. In contrast, China and South Korea allow the "health food" or "health functional food" mark to be attached on the products only if they are approved by government agencies. Because the USA has no singular official standards regarding ingredient management, a set procedure is required only when a new dietary ingredient (NDI) is used for a dietary supplement. 87 types of ingredients are subject to the Chinese registration system for dietary supplements. Korean functional raw materials are managed separately from publicly announced raw materials (96 types) and individually recognized raw materials (33 types). China indicates the suitable group in addition to the basic product information on the label, while the other two nations indicate the allergy ingredients. These three countries all implement laws and regulations such as ingredients, labeling, good manufacturing practice (GMP), and guides for dietary supplements in common. Conclusions: Despite the above differences in the policies on dietary supplements, the USA, China, and South Korea all actively implement them. Considering such national differences may be helpful in benchmarking for future promotion in the field for dietary supplement policies.