Regulatory divergence and convergence: A comparative analysis of plant-based food governance in China and the European Union

This article offers a structured comparison of regulatory frameworks governing plant-based protein foods in China and the European Union (EU), two of the world’s most influential markets. It explores key compliance dimensions—including product naming, allergen and nutrition labeling, food additives, contaminant limits, and the regulation of novel ingredients, health foods, and foods for special medical purposes (FSMP). China emphasizes pre-market authorization, positive list management, and risk prevention through administrative oversight. In contrast, the EU applies harmonized legislation grounded in science-based risk assessment, transparency, and post-market surveillance. Despite divergent approaches, both systems aim to ensure product safety, functionality, and consumer protection. The paper identifies opportunities for regulatory convergence and provides practical insights for stakeholders navigating the complex compliance landscape of the global plant-based food sector.

Introduction

As global interest in health and sustainable diets continues to grow, plant-based foods have become a key driver of innovation and market expansion in the food sector. Mainland China, one of the world’s largest consumer markets, is actively fostering the development of its plant-based industry. Meanwhile, the European Union (EU) has established a relatively mature regulatory system under its policies for sustainable agriculture and food innovation. This article provides a comparative analysis of the regulatory frameworks governing plant-based foods in China and the EU. Starting from an overview of the market landscape in both regions, it outlines differences and commonalities in legal provisions, technical standards, regulatory structures, and the roles of competent authorities.

Special attention is given to key stages of the regulatory process, including legislation, product approval, and enforcement. By examining the institutional design and regulatory logic in both jurisdictions, the article identifies opportunities for mutual learning and convergence in the governance of plant-based foods-an area of increasing global relevance.

Overview of market development of plant-based foods in China and the EU

In recent years, China’s plant-based food market has shown strong growth momentum. According to data from Euromonitor International (2023), the market size of plant-based meat in China reached approximately USD 13 billion in 2023 (about RMB 94.5 billion); the market for plant-based snacks is also rapidly expanding, reaching around USD 50 billion in 2024 (approximately RMB 360 billion). In the plant-based milk sector, the Qianzhan Industry Research Institute (2023) predicts that the average annual growth rate will remain above 20% from 2023 to 2025, with the market size expected to exceed RMB 300 billion by 2025. Among all categories, oat milk stands out, with a year-on-year growth rate of 50% in 2022, making it the fastestgrowing plant-based milk product. According to authoritative data from GFI Europe and Data Bridge Market Research (2022), the plant-based milk and meat markets in the EU have continued to grow since 2020. In the plant-based milk sector, sales in 2022 reached EUR 2.2 billion, accounting for 11% of the entire milk market.