Classification
Product TypeIngredient
Product FormPowder (dried botanical)
Industry PositionBotanical ingredient (food flavoring and dietary supplement ingredient)
Market
Licorice root powder in the United States functions mainly as a botanical ingredient used in food/flavor applications and in dietary supplements. U.S. compliance focus is driven by FDA’s dietary supplement and food oversight framework, including requirements to avoid adulteration/misbranding and, where applicable, new dietary ingredient (NDI) notification considerations. For use as a direct food substance/flavoring ingredient, U.S. requirements include the specifications and use limitations described for licorice and licorice derivatives in 21 CFR 184.1408. Importers also face heightened supply-chain diligence expectations, including CBP forced-labor enforcement (UFLPA) and APHIS Lacey Act declaration obligations for certain plant and plant-product HTS classifications.
Market RoleImport-dependent consumer and processing market
Domestic RoleIngredient used by U.S. food/flavor and dietary supplement sectors; also present in some tobacco-related flavoring contexts
Risks
Forced Labor HighCBP enforces the UFLPA rebuttable presumption that any goods mined, produced, or manufactured wholly or in part in China’s Xinjiang Uyghur Autonomous Region (or by an entity on the UFLPA Entity List) are prohibited from U.S. entry unless the importer can overcome the presumption with clear and convincing evidence; licorice root powder supply chains that include China-linked sourcing or opaque intermediaries face detention/exclusion risk that can block trade.Implement end-to-end supply-chain mapping and chain-of-custody documentation (farm/collection area, processor, exporter), avoid Xinjiang-linked inputs, and maintain an evidence package aligned to CBP UFLPA guidance for rapid response to detentions.
Food Safety MediumBotanical powders can face U.S. border enforcement and market actions related to toxic elements (e.g., lead, arsenic, cadmium, mercury); FDA maintains import alerts for foods (including dietary supplements) due to heavy metal contamination.Use a risk-based testing plan for toxic elements and retain certificates of analysis and method documentation; set supplier specifications and corrective-action triggers aligned to U.S. regulatory and compendial expectations.
Consumer Safety MediumLicorice contains glycyrrhizin/glycyrrhizic acid, which has been associated with serious adverse effects in susceptible individuals and at higher intakes; international safety evaluations note the critical effect and that an ADI was not established for glycyrrhizinic acid.Control and document glycyrrhizin/glycyrrhizic acid content (where relevant), use compliant food-use levels when used as a flavoring ingredient, and ensure consumer-facing products do not make impermissible disease claims.
Regulatory Compliance MediumDietary supplements in the U.S. are regulated under DSHEA; manufacturers are responsible for ensuring products are not adulterated or misbranded, and NDI notification requirements may apply for certain botanical ingredients depending on marketing history and conditions of use.Perform regulatory status assessment (food ingredient vs dietary supplement ingredient; NDI applicability), maintain substantiation files for labeling, and implement GMP-aligned quality systems for incoming botanical ingredients.
Documentation Gap LowCertain plant and plant-product imports require an APHIS Lacey Act declaration depending on HTS code classification, entry type, and other conditions; missing or incorrect declaration data can cause clearance friction and compliance exposure.Classify correctly and determine whether the shipment triggers Lacey Act declaration requirements; file electronically via ACE or LAWGS as required and retain supporting origin/species documentation.
Sustainability- Illegal harvesting and illegal plant-product trade risk screening (relevant to U.S. Lacey Act compliance expectations for certain regulated plant and plant-product imports).
Labor & Social- Forced-labor due diligence for China-linked supply chains: CBP enforces 19 U.S.C. 1307 via UFLPA rebuttable presumption for any Xinjiang-linked inputs; importers need robust supply-chain mapping and evidence packages to reduce detention/exclusion risk.
FAQ
What are the main U.S. compliance areas to plan for when importing licorice root powder?Plan for (1) FDA food/dietary supplement compliance (including DSHEA responsibilities for preventing adulteration or misbranding and, where applicable, new dietary ingredient considerations), (2) USDA APHIS plant and plant-product admissibility checks and any Lacey Act declaration obligations tied to HTS classification and entry type, and (3) CBP enforcement risks such as UFLPA forced-labor detentions for Xinjiang-linked supply chains.
Why is glycyrrhizin/glycyrrhizic acid content an important quality and risk metric for licorice ingredients in the U.S.?Glycyrrhizin (glycyrrhizic acid) is the characteristic licorice constituent tied to both food-use specifications and human safety concerns. U.S. rules for licorice and licorice derivatives used in food (21 CFR 184.1408) reference assay and contaminant specifications, and WHO JECFA safety evaluations note that sensitive individuals can experience physiological effects and that an ADI was not established for glycyrrhizinic acid.
What is the most serious trade-disruption risk for U.S. imports of licorice root powder from certain China-linked supply chains?The most serious risk is CBP detention or exclusion under the Uyghur Forced Labor Prevention Act (UFLPA) if any part of the product is linked to Xinjiang or an entity on the UFLPA Entity List. UFLPA creates a rebuttable presumption that such goods are prohibited from entry unless the importer can overcome it with clear and convincing evidence, so weak traceability can effectively block shipments.