关键词: 保健食品；政府监管；监管改革；膳食成分；功能声称

Abstract: Regulation of health foods in China and the United States show different institutional positions. For the regulatory object, the US highlights the dietary component orientation and defines a relatively clear legal content and type of health foods, while China pays attention to the expected function claims and has formulated a directory of health function with strict standards. For the regulatory scale, the US adopts loose and weak supervision, while China exercises strict and strong supervision. Accordingly, there is a value difference between the safety of consumption and the freedom of choice in these two countries. For the regulatory focus, the US emphasizes post-market surveillance, while China focuses on market access regulation, which reflects that the two countries have different regulatory risk perception, tolerance and governance strategies. China’s and the US’ reform strategies for the regulation of health foods are moving in the same direction. Building a market-oriented health food supervision system beyond “access-based supervision” has become an effective way to promote reform in the health food supervision system in China.

Key words: health food; government regulation; regulation reform; dietary component; function claims