The Retail Committee appreciates the government’s continued efforts to support public health and economic development. To build on the momentum gained through the Agreement on Reciprocal Trade (ART) between the United States and Taiwan, the Committee urges improving the business climate through more efficient governance, improved regulatory transparency, and enhanced digitalization. The Committee strongly believes these proposals will benefit both consumers and the retail industry while delivering high confidence in the Taiwan market.

Suggestion 1: Fulfill trade-related commitments made under the Agreement on Reciprocal Trade.

1.1   Provide a clear timeline for dietary supplement tariff reductions and regulatory definitions. The Committee supports the Healthy Taiwan and 888 Health Program initiatives proposed by President Lai Ching-te and the Executive Yuan. The dietary supplement industry plays a critical role in advancing these aims. Furthermore, we applaud Vice Premier Cheng Li-chiun for her success in February in concluding the U.S.-Taiwan ART, which established reduced tariff rates to 10% on dietary supplements, yielding direct benefits to consumers. We therefore urge the government to establish a clearly defined dietary supplement category aligned with the World Customs Organization’s Harmonized System to enable Taiwan’s Customs Administration to efficiently implement the tariff reduction. Having a clear timeline will be key to attaining the goal.

1.2   Balance food safety, food sustainability, and the diversity of imported foods.

To avoid unnecessary trade interruptions and potential waste of food, we recommend that the Taiwan Food and Drug Administration (TFDA) rigorously implement Article 19 of the Act Governing Food Safety and Sanitation. When a maximum residue limit (MRL) has not been set for use of a certain pesticide on a known crop, a temporary MRL standard (such as that of a country/region where the diet is similar to Taiwan’s, such as Japan) should be assigned after a proper risk assessment.

In 2019, Taiwan announced MRL standards for the herbicide glyphosate, but later removed them for certain applications. In the absence of an established MRL for specific commodities, Taiwan’s positive list system effectively applies a non-detective standard, which can restrict the import of some U.S.-produced crops.

We believe that continuing to ban products from being imported merely because their raw materials used a specific pesticide is detrimental to the diversity of imported foods and the positive development of U.S.-Taiwan trade. The Committee urges the TFDA to conduct another risk assessment of glyphosate with an eye to re-introducing the MRL. Re-establishing MRLs where appropriate will reduce the risk of recurring technical barriers to trade for U.S.-produced crops.

Suggestion 2: Enhance the efficiency of food import procedures using appropriate tools and forms.

2.1   Use AI to avoid issues with company-name declarations during border inspections. For the purpose of border food inspection, importers are required to provide the name of the manufacturing facility. However, due to trade usage and language differences, it often happens that the name is presented differently at different times as a result of common variations such as Company and Co., Limited and Ltd., Corporation and Corp. or Inc., or Chinese-language variations like 株式会社 and (株). These differences create inconsistencies in the eyes of inspectors and require explanation, which may take a week or more to resolve. We urge the TFDA to utilize large language models (LLMs) to enhance recognition of company names and avoid unnecessary delays in the food inspection process at the border.

In addition, on the application form for inspection of food imports, we suggest that when the same company operates multiple factories in the same country, the TFDA allow the company name to be used to identify the “manufacturer,” rather than requiring the actual production premises.

2.2   Adopt a mechanism to manage naturally occurring substances. The Committee recommends that border inspections, instead of relying solely on literature-based background values, transition to a multi-evidence, science-based approach for naturally occurring substances, including benzoic and salicylic acid which are part of a plant’s natural defense mechanism, combining literature values, manufacturing data, and lab testing.

To prevent inconsistencies in which a product may face requests for additional documentation even when previous case-number protocols exist for an identical product, review standards need to be harmonized with international norms and historical custom inspection internal inspection data to eliminate non-tariff trade barriers and ensure administrative reliability.

Recommendations:

• • Adopt “natural origin” standards. Reference Korea’s Food Additives Code to establish scientific thresholds for common naturally occurring components (e.g., benzoic acid up to 0.02 g/kg; propionic acid up to 0.10 g/kg). We suggest that importers be permitted to submit manufacturing data, raw material certifications, and accredited laboratory results to substantiate natural occurrence.
  • Institutionalize review guidelines. Formalize these criteria within the Common Supplement Patterns for Imported Food Inspection to ensure procedural transparency and predictability.
  • Adopt a data-driven approach to regulation. Utilize historical inspection data to calibrate scientific thresholds and improve regulatory efficiency.

2.3   Advance trade facilitation and regulatory transparency for dual-use Chinese herbal ingredients.

2.3.1        Streamline clearance processes and update regulations for the traditional Chinese medicine (TCM) industry. Despite the integration of the Customs-Port-Trade (CPT) Single Window with the licensing and inspection system of the Department of Chinese Medicine and Pharmacy (DCMP) of the Ministry of Health and Welfare, there continues to be redundant batch-by-batch notifications, creating significant administrative duplication. We recommend:

• • • Implement a single-reporting mechanism. The Committee calls for enabling real-time data-sharing of botanical origin, quantity, and item details submitted through the CPT Single Window to the DCMP, eliminating the requirement for separate batch-by-batch reporting.
    • Introduce an integrity green channel. We urge establishment of a C1-style fast-track (Customs low-risk clearance category with no file review or inspection) for importers with a proven record of compliance, aligned with Customs Administration practices.
    • Establish an update mechanism for TCM regulation, with periodic reviews every two or three years following stakeholder consultation, to align with global scientific trends.

2.3.2        Update regulatory frameworks for TCM to align with global scientific trends. Regulatory progress regarding the medicine-food homology list has stalled due to divergent opinions, causing Taiwan’s therapeutic food sector to lag behind regional competitors. We recommend:

• • • Establish a biennial update cycle and conduct a mandatory review of the medicine-food homology list to ensure regulatory agility by harmonizing with regional standards and replaces blanket bans with risk-level management.
    • Adopt international risk-based standards. The Committee calls on the government to reference regional catalogs (China, Japan, and South Korea, for example) to implement risk-stratified management strategies, rather than blanket prohibitions. We further urge the introduction of reasonable usage limits with mandatory warning labels to balance safety with flexibility.
    • Conduct industry impact-assessment reports. We suggest quantifying the projected output value contribution to the food processing industry of specified products (for example, functional beverages or ready-to-drink meals) to shift the regulatory paradigm from prevention of non-compliance to economic facilitation.

2.4   Harmonize wording and usage limits for food additives and nutrient sources. In Category 8 “Nutritional Additives” under the “Standards for Specification, Scope, Application, and Limitation of Food Additives,” inconsistencies exist in the wording used to describe usage limits for general foods, which may create ambiguity in interpretation. In addition, the usage limits for nutritional additives often differ from those for food raw materials that provide the same nutrients (e.g., zinc, selenium, iron, magnesium, and molybdenum). To enhance regulatory consistency and clarity, and to safeguard consumer interests, we propose the following:

• • Harmonize the wording used for usage limit descriptions. We recommend replacing the word “limit” from the expression “daily intake limit” with “daily intake” or “recommended daily intake.” This change will help avoid misunderstandings due to semantic inconsistencies and serve to improve the clarity and precision of the regulation.
  • Align usage limits between nutritional additives and food raw materials that provide the same nutrients. An example of such discrepancy is the usage limit in the daily intake for zinc yeast as a raw material, which differs from that for zinc sulfate as a nutrient additive (30 mg vs 22.5 mg). Except where considerations related to special dietary foods apply, consistent regulatory standards should be adopted so that nutritional additives and food raw materials providing the same nutrients follow the same usage limits. This practice will facilitate industry compliance and protect consumer interests.

Suggestion 3: Promote digitalization, transparency, and international alignment in government regulation of food products.

3.1   Replace paper requirements with electronic processes to enhance digital governance and efficiency. We are grateful for the progress made by the Ministry of Agriculture (MOA) last year planning the establishment of a website designed to take online applications for import permits for organic agricultural products. The Committee looks forward to implementation of this initiative to enhance the efficiency of the application process.

3.2   Promote digitalization of cross-border retail customs-clearance processes. The Taiwan government continues to advance digital governance, with the Ministry of Digital Affairs (MODA) actively promoting the use of electronic signatures. Electronic signatures strengthen the security and efficiency of online procedures and are essential for improving cross-border retail and supply chain operations. However, many customs-related processes still rely on paper documents, and existing online procedures remain limited and burdensome due to requirements such as use of the Citizen Digital Certificate, which increase user difficulty and processing time.

The Committee encourages the government to prioritize the digitalization of key processes, including long-term customs-clearance authorization through the Customs Administration, self-use declarations for high-dosage dietary supplements under the TFDA, and Bluetooth device declarations through the National Communications Commission. These improvements can be implemented while fully meeting regulatory requirements. A consistent, cross-agency application of electronic signatures would enhance trade facilitation and improve the consumer digital experience.

3.3   Prohibit the sale of imported alcoholic beverages with altered or removed original manufacturing lot codes. The Committee continues to seek solutions to this longstanding issue impacting consumer safety. The crux of the issue lies in Article 32 of the Tobacco and Alcohol Administration Act (TAAA), which explicitly stipulates that packaged alcoholic products for sale must bear a lot code. This code indicates the quantity of a product manufactured at a specified time on a specific production line. Some parallel importers have been removing the original lot codes and replacing them with their own serial numbers, which do not contain the information needed for tracing. We have previously noted that many jurisdictions require such labeling. The UK, France, Italy, Canada, and the EU all mandate that alcoholic products bear lot codes. In some countries that do not currently prohibit the removal of lot codes, discussions are underway to amend the law.

In addition, prohibiting the removal of original lot codes would not contradict the spirit of free trade, as some have alleged. Parallel importers could continue to import alcoholic products as long as they keep the original lot codes on the bottles, as required by law.

We consider it essential that alcoholic products remain traceable and recallable when food or alcohol safety is in doubt. To safeguard consumer interests, we again ask the Ministry of Finance to conduct systematic inspections and enforce the prohibition on the sale of products with removed lot codes, and to establish a robust and effective reporting mechanism to replace the current voluntary reporting of such products at the point of import.

3.4   Ensure transparency and predictability in the review process for novel ingredients. The Committee acknowledges the TFDA’s ongoing communication with industry regarding the management of novel ingredients. However, the overall review process for novel ingredient applications remains lengthy and lacks transparency. Each stage of the application dossier evaluation (the submission package) — including data assessment, ingredient safety evaluation, and preparation for advisory committee review — often requires extended processing time, with no specific timelines established for these steps. Furthermore, when errors arise during the evaluation (for example, omission of the intended scope of the application), applicants currently have no mechanism to provide timely clarification. These issues create unnecessary delays and unpredictable risks for companies, holding up market entry for new products and potentially discouraging investment in the development of novel ingredients.

To enhance regulatory consistency, improve procedural clarity, and support industry planning, the Committee recommends the following:

• • Provide predictability in the review process. Establish defined processing timelines for each stage of review and develop a system that allows applicants to track the status of their submissions.
  • Align the review of internationally recognized ingredients with U.S. FDA standards and complete evaluations within one year. For ingredients already recognized under the U.S. Food and Drug Administra-tion’s Generally Recognized as Safe framework, the TFDA may consider reducing nonessential evaluation steps and completing the review within one year. This approach would increase administrative efficiency and support the timely introduction of novel ingredients with established international safety data.

Enhancing the efficiency and predictability of the review process will support food technology innovation, facilitate trade, and contribute to a more internationally aligned and efficient regulatory environment.

Suggestion 4: Deploy age-verification technology to responsibly unlock restricted products in new online markets.

As Taiwan advances digital services and aligns with global AI trends, regulatory frameworks must evolve accordingly. The Committee suggests that laws designed for analog-era constraints be updated when they prevent the deployment of more effective digital safeguards.

Since MODA’s establishment in 2022, Taiwan has developed a digital identity infrastructure that enables secure, auditable remote verification at scale. The policy question is no longer technical feasibility, but regulatory adaptation. An example of where regulatory modernization is warranted is Taiwan’s existing restrictions on the online sale and delivery of alcohol and tobacco under Article 30 of the TAAA, which target situations where age cannot be effectively verified, reflecting earlier limitations in age-verification capability. Significant technology advances in age verification recently mean that there should no longer be a binary choice between protecting minors and supporting digitally-enabled sectors.

Responsible businesses share the government’s mandate to protect minors. Digital innovation and child welfare are complementary objectives, not competing priorities. The current prohibition assumes industry cannot be trusted with minor protection responsibilities, forcing a false choice between enabling industry development and safeguarding vulnerable populations. This mistrust prevents collaborative solutions that could strengthen minor protection beyond what the current mechanism alone achieves.

Modern verification technology enables industry to serve as active partners in minor protection rather than subjects of blanket exclusion. This approach has proved effective in international practice, where multi-step digital verification, including document authentication plus in-person confirmation at delivery, can exceed traditional retail safeguards while age verification relies solely on individual clerk judgment. A classic example is Japan’s experience in permitting online alcohol sales under a licensing framework that requires age verification at the point of purchase and may include additional checks at delivery, showing that regulated digital channels can protect minors while enabling legitimate commerce.

The Committee urges the government to leverage these capabilities through the following measures:

• Approve a controlled pilot program in a designated municipality to test verification effectiveness and generate empirical data on compliance outcomes. The program would have defined success metrics and a mutually agreed evaluation period, followed by scaled implementation upon successful validation.
• Establish a framework allowing exceptions to current legislative restrictions (for example, Article 30 of the TAAA) where businesses demonstrate that their age-verification technology meets government-approved standards.

Suggestion 5: Remove unnecessary quarantine requirements for dry pet food.

While dry pet food and coated ingredients after extrusion are regarded as safe commodities, Taiwan’s veterinary authorities have imposed restrictions on the importation of certain extruded dry pet food, citing the risk associated with Avian Influenza. Based on international practices, veterinary authorities should not require any conditions related to Avian Influenza, regardless of the avian influenza status of the exporting country or zone. As a member of the World Organization for Animal Health, Taiwan has pledged to fulfill its national member responsibilities, including providing member states with information on local animal disease epidemics and the formulation of relevant quarantine regulations to avoid unreasonable trade barriers.

The Committee recommends that the MOA follow up on its commitment to revise the relevant regulations and remove unnecessary quarantine requirements on dog and cat dry food products.