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2026-09-297 min read0

Health Functional Food GMP Harmonization Amendment 2026 — New Standards for Reprocessing, Compressed Air and Lubricants, Mandatory Tamper-Proof QC Record Systems, and a Readiness Guide for SME Manufacturers

MFDS's July 2026 draft amendment aligns Korean health functional food GMP with international standards by adding rules for reprocessing, compressed air and lubricants and by requiring a QC record management system. This guide lays out, step by step, how SME manufacturers can prepare SOPs, choose a LIMS and schedule the switch to the new marks.

KITIM Consulting Team

What Is Changing — The Draft Amendment to the Health Functional Foods Act Enforcement Rule

On July 21, 2026, Korea's Ministry of Food and Drug Safety (MFDS) published a draft amendment to the Enforcement Rule of the Health Functional Foods Act. The public comment period closed on August 31, and the amendment is now awaiting promulgation. Its goal is to bring Korean health functional food (HFF) GMP in line with international benchmarks such as U.S. cGMP.

The amendment has three pillars:

  • New GMP standards for reprocessing, compressed air and lubricants
  • Mandatory use of a quality control (QC) record management system
  • A dedicated mark and a "This is not a medicine" statement for personalized HFFs
  • Because this is still a draft, you should check the final wording, effective date and any grace period once the rule is officially promulgated. Separately, the already-finalized redesign of the HFF and GMP marks takes effect on January 1, 2028. These are two different timelines, so plan for them separately.

    What Changes on the Shop Floor — Reprocessing, Compressed Air and Lubricants

    Reprocessing

    Reprocessing records will have to be kept. You'll need written criteria for when reprocessing is allowed, a QA approval step, and traceability that links each reprocessed lot back to its original lot.

    Compressed air

    Compressed air that touches product directly is treated as a potential source of cross-contamination and must be managed on a regular schedule. The key steps are setting filter replacement intervals and moisture and oil limits, then recording every check.

    Lubricants

    Food-grade lubricants must be used wherever product contact is possible, and you need to keep a list of where each lubricant is used along with its replacement history.

    Items commonly missing from existing SOPs

  • A decision table listing when reprocessing is and isn't allowed
  • A list of compressed-air points of use and the filter specifications for each
  • Lubricant product names, proof of food grade, and application logs for each piece of equipment
  • Procedures for handling deviations and assessing their impact on product
  • The Biggest Task — A Tamper-Proof QC Record System

    All QC results, including in-house self-testing, will have to be managed in a record management system. Paper test logs and Excel files will no longer be enough.

    There are two main options:

  • Build your own LIMS: you can design it around your equipment and workflows, but the upfront cost and validation effort are significant.
  • Use the MFDS-operated LIMS: this option is meant for companies that can't build their own. It costs less, but you should check its features and integration limits in advance.
  • Either way, the system must meet data integrity (ALCOA+) principles. Treat audit trails, role-based access control, electronic signatures and scheduled backups as non-negotiable. A practical approach is to decide how much instrument data (from HPLC and similar equipment) will flow in automatically, and to control any remaining manual entry with second-person verification and required reasons for every change.

    Extra Steps for Personalized HFF Businesses

  • Adopt the new dedicated mark and print "This is not a medicine" on both outer and inner packaging
  • Show the expiration date on inner packaging
  • Sellers must provide precautions about taking the product with medicines, either at the store or electronically. Build this into counseling procedures and customer materials at stores that repackage and sell products.
  • Readiness Roadmap for SME Manufacturers

  • Phase 1 (now): Run a gap analysis against the draft. Review your reprocessing, compressed-air and lubricant SOPs and your current recordkeeping.
  • Phase 2 (around promulgation): Choose your LIMS approach, draw up a validation plan and train staff.
  • Phase 3 (before the effective date): Hold a mock GMP inspection, migrate existing records, and build the January 1, 2028 mark changeover into your packaging procurement plan.
  • Costs can be reduced by pairing this work with government programs such as the Smart Factory deployment initiative or quality-related support schemes. Whether LIMS or equipment upgrades qualify varies by call, so check each announcement.

    How KITIM Can Help

    KITIM supports HFF manufacturers with GMP gap assessments, SOP revisions, consulting on QC record system adoption, and applications for related government programs. If you'd like to settle your scope and budget before the rules take effect, request a consultation through KITIM's Contact page. One of our consultants will review your current setup and help you decide what to tackle first.

    Health Functional Food GMPHFF Enforcement Rule AmendmentLIMSQC Record ManagementData IntegrityPersonalized Health Functional FoodMFDS
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